10 Program, Fiscal Monitoring, and Audit, 2605(b)(10) - Assurance 10

10.1. How do you ensure good fiscal accounting and tracking of funds? The LHC financial operations manual establishes the framework and procedures for budgeting, reporting, internal controls, cost allocation,and accountability as described in the costs principle applicable to the grant. Contractors submit weekly electronic copies of the Request for Payment to LHC for their benefit payments based on eligible households and monthly Request for Payment to LHC for actual administrative, program, and client education expenditures. LHC conducts monthly reconciliation of funds and expenditures with sub-recipients to ensure accuracy and reliability for data reporting. All LIHEAP expenditures are tracked and monitored using the web-based software, Hancock Energy Software (HES) and MS Excel spreadsheets. 10.1a Provide your definitions of the following: Obligation The State of Louisiana’s definition of “obligation” can be found in LA Civ Code 1756: An obligation is a legal relationship whereby a person, called the obligor, is bound to render a performance in favor of another, called the obligee. Performance may consist of giving, doing, or not doing something. The State of Louisiana’s definition of “encumbrances” aka “obligations” can be found in the Louisiana Division of Administrations’ Control Agencies Policies and Procedures Manual, Chapter 6.1.1 (Exhibit 9): An obligation for which the State is committed, but for which goods and services have not yet been received or and accepted. Expenditures The State of Louisiana’s definition of “payments” aka “expenditures” can be found in the Louisiana Division of Administrations’ Control Agencies Policies and Procedures Manual, Chapter 7.1.1 (Exhibit 9): The liquidation of a liability and the final event in the purchasing process. Expenditure timeframe Louisiana obligates 90%-100% of funds by September 30th of the first year. Remaining funds are obligated or reobligated by September 30th of the second year not to exceed 10% Carryover. All remaining obligations are liquidated by December 31st following the second year. Any refunds received after September 30th of the second year are returned to HHS. Administrative costs The term administrative costs means costs necessary for the proper administration and management oversight of the Louisiana LIHEAP program, including all costs, both direct and indirect, associated with the general administration and coordination of the program; supportive services including accounting, human resource, and procurement; development of policies, goals and objectives; participant intake and eligibility determination; and monitoring. All Federal funds used to administer LIHEAP activities (except for the costs associated with client education – Assurance 16) count against the 10% State limit and are considered an administrative cost. Audit Process 10.2. Is your LIHEAP program audited annually under the Single Audit Act and OMB Circular A - 133? Yes No 10.2a - if yes, describe your auditor selection process. A Request for Proposals is issued every 3-5 years, and it is issued by LHC on behalf of the Louisiana Legislative Auditors Office. 10.3. Describe any audit findings of the grant recipient (i.e. State/Tribe/Territory) rising to the level of material weakness or reportable condition cited in the single audits, inspector general reviews, or other government agency reviews from the most recently audited fiscal year. No Findings Finding Type Brief Summary Resolved? Action Taken 1 10.4. Audits of Local Administering Agencies What types of annual audit requirements do you have in place for local administering agencies/district offices? Select all that apply. Local agencies/district offices are required to have an annual audit in compliance with Single Audit Act and OMB Circular A-133 Local agencies/district offices are required to have an annual audit (other than A-133) Local agencies/district offices' A-133 or other independent audits are reviewed by Grant recipient as part of compliance process. Grant recipient conducts fiscal and program monitoring of local agencies/district offices Local agencies and district offices are required to have an annual audit in compliance with Single Audit Act and OMB Circular A-133 Compliance Monitoring 10.5. Describe your monitoring process for compliance at each level below. Check all that apply. Grant recipients have a policy in place for appropriate separation of duties and internal controls. Internal program review Departmental oversight Secondary review of invoices and payments Other program review mechanisms are in place. Describe: LHC utilizes the available reporting system of the Hancock Energy Software (HES) to monitor contractor's production and service delivery to timely ensure all contractors are maintaining service delivery in accordance with contractual obligations. Local Administering Agencies/District Offices: On - site evaluation Annual program review Monitoring through central database Desk reviews Client File Testing/Sampling Other program review mechanisms are in place. Describe: In the event of a natural disaster, statewide pandemic, or other emergency, LHC may adapt monitoring methods as a result of the event and the Agencies' resources. Those methods will be determined based on circumstances surrounding the event and the associated timelines. 10.6 Explain, or attach a copy of your local agency monitoring schedule and protocol. Louisiana Housing Corporation (LHC) has adopted a systems approach to monitoring Contractors for compliance with applicable regulations and achievement of performance goals. Program activities are monitored both electronically and by conducting on-site visits annually. The State mandated software is used to record application input and monitor Contractor's production, i.e., how many applications are taken in a given time frame; how many of those applications were Heating/Cooling applications; how many were Crisis applications; how many households were served; and how many priority members were included in those households. We are also able to monitor the rate of benefit delivery to the specific service area. This information is utilized, to not only monitor the rate of service delivery, but also the areas being served. Those areas can be identified within a service provider's geographical service area, needing extra attention and outreach. During the on-site monitoring visits, the physical files are reviewed for documentation of various program mandated activities, such as: (A) Written policies and procedures that prohibit discrimination in both service delivery and employment, (B) Compliance with Minimum Wage laws, (C) Written policies regarding grievance procedures for both applicants and employees, (D) Written policies regarding providing services to eligible applicants on a first come, first served basis, (E) Written policies that document adherence to written Program Guidelines approved by Louisiana Housing Corporation, (F) Documentation of employee training on program guidelines, (G) A review of various documents that demonstrate program outreach activities including newspaper ads, radio and/or television advertising, copies of any printed material distributed in the community to applicants and potential applicants, social media, (H) A review of Client Education material distributed to applicants regarding energy conservation activities, (I) A review of a random sample of applicant files to verify the collection of required support docoumentation from eligible applicants, including income, vulnerability of the client for the cost of the energy bill, confirmation of residence at the service address indicated on the bill, copies of Social Security Cards or other government documents that contain social security numbers for each member of the household being served, (J) Written policies and procedures to detect, minimize, and eliminate waste, fraud, and abuse. Eligibility and benefit determination is handled through the web-based computerized application system adopted by the LHC. The program is designed to calculate benefit based on parameters that are entered at the state level and that are unalterable at the service provider level. Benefit calculations are based on income levels for each household, the number of eligible household members, and the identification of priority members of the household, i.e., persons over 60 years of age, persons disabled, or persons under the age of 6. The benefit calculation is totally, automated requiring only data input from the agency provider. Eligibility is also determined by the same system utilizing social security numbers of applicants and flagging those applicants or household members that may have received a benefit within the prohibited timeframe. Applicants may currently apply for non-crisis benefits once in the heating season and once in the cooling season, and if necessary, applicants may also apply for a crisis benefit once in a twelve month period. 10.7. Describe how you select local agencies for monitoring reviews. Attach a risk assessment if subrecipients are utilized. Site Visits: LHC, as the state grantee, conducts annual on-site compliance monitoring visits to all LIHEAP contractors. Desk Reviews: LHC staff conducts ongoing desk monitoring of agency reports, budget tracking and statistical reports, and rate of expenditures. 10.8. How often is each local agency monitored? Please attach a monitoring schedule if one has been developed. Annually 10.9. How many local agencies are currently on corrective action plans? 1 If any of the above questions require further explanation or clarification that could not be made in the fields provided, attach a document with said explanation here.