10.1. How do you ensure good fiscal accounting and tracking of funds? See the following sections of the ND State Plan attachments document: P (Distribution of Grant Funds by Priority) Q (Benefits Excluded as Income) R (Administrative/Service Costs) S (Control of Fraud, Waste and Abuse) T (Fiscal Controls, Fund Accounting and Annual Audit) U (Reporting and Investigations) 10.1a Provide your definitions of the following: Obligation In the North Dakota Century Code (NDCC) "50-06-05.1. Powers and duties of the department"; item #18, states that/or the energy assistance program: “For purposes of the administration of the energy assistance program, funds are obligated at the earlier of the time a written commitment is m vendor or contractor for services or supplies delivered or to be delivered, or at the time payment is made to a vendor or contractor for services or sup delivered or to be delivered.” Expenditures ND follows the LIHEAP definition of expenditure: “Expenditure means any amount of Federal LIHEAP or State MOE funds that a State expends, spends, pays out, or disburses consistent with requirements of parts 260 through 265 of this chapter. It may include expenditures on the refundable portions of State or local tax credits, if they are with the provisions at § 260.33. It does not include any amounts that merely represent avoided costs or foregone revenue. Avoided costs include suc contractor penalty payments for poor performance and purchase price discounts, rebates, and credits that a State receives. Foregone revenue include provisions—such as waivers, deductions, exemptions, or nonrefundable tax credits—that reduce a State's tax revenue.” Expenditure timeframe North Dakota State law allows the department to follow 31 USC § 1552(a) in determining the end date for expenditure of funds. 31 USC § 1 the following: § 1552. Procedure for appropriation accounts available for definite periods a) On September 30th of the 5th fiscal year after the period of availability for obligation of a fixed appropriation account ends, the account s and any remaining balance (whether obligated or unobligated) in the account shall be canceled and thereafter shall not be available for obligation or for any purpose. Administrative costs The North Dakota Department of Human Services (DHS) has adopted TANF rules in determining administrative costs. 45 CFR 263.0 (b) The term “administrative costs” means costs necessary for the proper administration of the TANF program or separate Sta (1) It excludes direct costs of providing program services.(i) For example, it excludes costs of providing diversion benefits and services, providing p information to clients, screening and assessments, development of employability plans, work activities, post-employment services, work supports, a management. It also excludes costs for contracts devoted entirely to such activities.(ii) It excludes the salaries and benefits costs for staff providing p services and the direct administrative costs associated with providing the services, such as the costs for supplies, equipment, travel, postage, utilities office space and maintenance of office space.(2) It includes costs for general administration and coordination of these programs, including contract indirect (or overhead) costs. Examples of administrative costs include:(i) Salaries and benefits of staff performing administrative and coordination f Activities related to eligibility determinations;(iii) Preparation of program plans, budgets, and schedules;(iv) Monitoring of programs and projects;(v abuse units;(vi) Procurement activities;(vii) Public relations;(viii) Services related to accounting, litigation, audits, management of property, payroll personnel;(ix) Costs for the goods and services required for administration of the program such as the costs for supplies, equipment, travel, postage, rental of office space and maintenance of office space, provided that such costs are not excluded as a direct administrative cost for providing progra under paragraph (b)(1) of this section;(x) Travel costs incurred for official business and not excluded as a direct administrative cost for providing pr services under paragraph (b)(1) of this section;(xi) Management information systems not related to the tracking and monitoring of TANF requireme personnel and payroll system for State staff); and(xii) Preparing reports and other documents. 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. The State Auditor's Office (SAO) is responsible for conducting the Single Audit under state law. The selection of auditors is determined by t which assigns audit teams with the expertise to evaluate compliance and internal controls over federal programs, including LIHEAP. The audit is co accordance with generally accepted auditing standards (GAAS) and Government Auditing Standards. 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: The Low Income Home Energy Assistance Program in North Dakota is a state- supervised, county-administered program. The Department of Human Services established a LIHEAP administrative unit within the Economic Assistance Policy Division and delegated responsibility for program planning, direction, supervision, monitoring, training and evaluation. DHS also has the responsibility of building and maintaining the computer system that determines eligibility and benefits state-wide. The department’s Fiscal Administration Division, LIHEAP Administrator and Economic Assistance Director monitor the funding of the program. Various units of the Fiscal Administration Division will provide research, reporting, accounting, and data processing services. The local human service zone offices, formerly known as county social service offices are responsible for local program administration, outreach and the delivery of services. Program supervision, training and monitoring are provided by the state office staff in the Economic Assistance Policy Division. Fair hearings are managed by the Department’s Appeals Supervisor. An Administrative Law Judge (ALJ) from the Office of Administrative Hearings (OAH) conducts hearings for the Department concerning appeals. See 448-01-30-35, Fair Hearings Procedure, for additional information. The four Indian tribes, located on the North Dakota reservations, will administer a program of low income home energy assistance to eligible Indian households that reside within the boundaries of the reservations. Indians and non-Indians residing on the North Dakota part of the Lake Traverse Reservation are within the scope of this plan administered by the State and by HSZ boards. See 448-01-15, Responsibilities, for additional information. Policy and Procedure Development As part of its responsibility, the state also develops and maintains policy and procedures regarding appeals and fair hearings, waste, fraud, and abuse, overpayment recovery, and civil rights complaints as well as grievance procedures. Maintenance of Verification Interface System interfaces are used to verify information needed to determine eligibility. Acceptable interfaces are addressed in the Administrative Procedures Manual. Refer to section 448-01-50 of the Administrative Procedures Manual. In addition to these interfaces/sources, eligibility workers also have access to additional verifications received through other program interfaces such as the Income and Eligibility Verification System (IEVS), Social Security Administration and Public Assistance Reporting Information System (PARIS). Quality Assurance Coordinator The State Office institutes a continuing performance reporting system to monitor program administration and program operations. The components of the system are: • Data collection through quality assurance reviews • Analysis of data collected by Quality Assurance and all other management information sources • Corrective action planning • Corrective action implementation, monitoring, and evaluation Corrective Action Planning The objectives of corrective action planning are to develop appropriate measures to correct LIHEAP deficiencies based upon the results of data analysis performed by the Quality Assurance Coordinator. The State is responsible for the development of two types of corrective action: • Remedial involves rectifying past errors in individual cases. • Preventative involves correcting patterns of deficiencies. Corrective action plans are monitored by HSZ and state personnel to determine if they are completed in a timely manner. Case Monitoring State Low Income Home Energy Assistance staff monitor heating assistance and emergency assistance continuously to identify errors in eligibility determination and benefit issuance. Numerous monitoring reports from the central office and field staff are also reviewed by state office. Reports from the HSZ boards’ supervisors and staff, on-site visits to local offices and energy suppliers, and/or fiscal and recipient data from the LIHEAP system are also incorporated as monitoring tools. Corrective action plans are initiated appropriately. In addition, numerous data edits exist within the LIHEAP system to ensure that data is accurate and benefits are issued correctly. The state office employs the following monitoring tools: Estimated Cost of Heating Report – list of households whose cumulative payment amount for the heating season deviates from the estimated cost of heating by $250 or more. Report is reviewed and questionable payment amounts are investigated. Payment Summary Notice – when a case closes or at the end of the heating season, households are sent a payment summary notice that lists all payments that have been made on behalf of the household. Household is instructed to review and report any discrepancies. Quality Assurance Reviews - a statewide monthly random sample of fifteen (15) LIHEAP cases that received a payment are reviewed by the Quality Assurance Unit staff. The sample consists of one (1) case per region along with an additional two (2) random selections from the statewide sample. In addition, a statewide monthly random sample of five (5) denied/closed cases are selected and reviewed. The results of the reviews are shared with the eligibility worker, zone director and the Policy and System Support (PaSS) Unit. If overpayments exist as a result of the review, overpayments are established regardless if it is due to an agency or recipient error. At the time an overpayment is established, the family is informed of the overpaid amount and their responsibility for repayment. Error trends are used to identify areas of the program in need of training or possible policy revisions. LIHEAP e-Learning courses are available online 24 hours a day for eligibility workers to develop competency and skills in applying LIHEAP policy. Policy and System Support (PaSS) provides training for zone eligibility workers on new policy and revisions. In addition, they work one-on- one with eligibility workers as needed. Statistical Reports - local agency utilization of LIHEAP is monitored monthly through statistical reports that are generated for review of caseload and expenditures by Human Service Zone (HSZ). These reports are shared within DHS and eachHuman Service Zone (HSZ) for their review and information. If there are any discrepancies identified, they are reviewed by the LIHEAP Administrator. Returned LIHEAP Checks – returned checks are investigated to obtain current address and to determine if eligibility is ongoing. On-site or Virtual Visits – Human Service Zone (HSZ) visits, as determined, to conduct training or monitoring program administration Fiscal Monitoring An abstract is created each week of payments authorized by the eligibility worker in the LIHEAP eligibility system along with payments requested by energy vendors. The abstract is reviewed by DHS policy staff and Fiscal Administration and authorized payments are reconciled with system reports before payments are released and paid through the PeopleSoft payment system. In addition, Fiscal Administration provides monthly spenddown tables on the utilization of program funds to the Economic Assistance Director. Program Monitoring For weatherization and emergency furnace services, monitoring is flagged in the Department’s electronic contract system on a specified schedule throughout the life of the contract. Training The State Office is responsible for providing continued training opportunities for workers, supervisors, Policy and System Support (PaSS) staff, performance reporting system reviewers, vendors and subgrantees. The zones are responsible to ensure staff attend training sessions and enroll in e-learning training opportunities. North Dakota’s open meeting law permits attendance of non-employees at training sessions. However, the role of public participants must be limited to observation only. 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: Weatherization Monitoring by Department of Commerce (See attached document). 10.6 Explain, or attach a copy of your local agency monitoring schedule and protocol. The LIHEAP Program's organizational structure is designed to ensure rigorous oversight and implementation of internal controls that bolster integrity and accountability. The structure involves regular monthly meetings between the LIHEAP administrator, the Director of Program Adminis the fiscal team. In these meetings, they review case counts, cost trends, application guidelines, and spend-down reports, addressing any significant c caseloads or benefit amounts due to policy changes. On a weekly basis, the Director of Program Administration oversees benefit issuance, which th Specialist prepares. The specialist verifies the accuracy of benefits reports by cross-referencing outputs from the integrated eligibility system and cli information. Once the Director signs off on these reports, they are stored in SharePoint and then forwarded to the fiscal department for a final check payment disbursement. This layered review process ensures meticulous verification and accountability at each step. The LIHEAP Program maintains policies and procedures on subrecipient monitoring for all grant contracts. Grant contract monitoring activi risk assessment of the subrecipient, completion of a Program Checklist, completion of a Contract Closure Assessment, and periodic documentation contract. Program administrators review requests for reimbursement and supporting documentation to ensure that contracted vendors are expending accordance with the requirements. To prepare and submit the required state and federal fiscal reports, the processes involve a thorough and coordinated effort by the fiscal depa department carefully reviews and compiles expenditure data from the fiscal management system, ensuring accuracy through cross-referencing with reports and system case counts. After assembling the reports, an additional layer of security and verification is provided by the Director of Program Administration, who reviews and signs off on them before submission. This systematic approach ensures compliance with regulatory standards and integrity of financial reporting. Effective fiscal management practices involve regular monitoring, transparent accounting procedures, and adherence to federal and state gui ensure proper allocation and use of LIHEAP funds. This includes detailed monthly meetings, rigorous expenditure tracking, and multiple controls fo supported by advanced fiscal projection tools. The LIHEAP Program measures the effectiveness of fiscal management through performance indicators such as expenditure rates, complian budget allocations, and audit results. Tools like expenditure tracking systems and monthly financial reporting are utilized to monitor these indicator The results from tracking and measuring fiscal management practices are used to refine budget planning, improve allocation strategies, and e oversight mechanisms. This continuous feedback loop ensures that fiscal practices directly support program objectives and compliance requirement Additionally, the LIHEAP Program employs technology-based solutions to automate financial reporting and uses predictive analytics to fore financial scenarios, improving decision-making and fiscal responsiveness. Each month, the Department's Quality Assurance Unit generates a random sample of LIHEAP cases for which a payment was made during t review month. A state-wide monthly random sample of fifteen (15) Low Income Home Energy Assistance Program (LIHEAP) cases are selected fo the Quality Assurance Unit staff. The sample consists of one (1) case per region along with an additional two (2) random selections from the state-w In addition, a state-wide monthly random sample of five (5) denied/closed cases are selected and reviewed. The necessary outcome of this process is the assurance that clients are qualified, and that they receive the benefits for which they are eligible The results of the reviews are shared with the eligibility worker, Human Service Zone director, and program administrators. If overpayments result of the review, overpayments are established regardless of whether it is due to an agency or recipient error. At the time an overpayment is estab family is informed of the overpaid amount and their responsibility for repayment. Any corrections (over or underpayment) are the responsibility of t worker. Error trends are used to identify areas of the program in need of training or possible policy revisions. LIHEAP eLearning courses are availab hours a day for eligibility workers to develop competency and skills in applying LIHEAP policy. Economic Assistance Training Team provides trai eligibility workers on new policy and revisions. In addition, they work one-on-one with eligibility workers as needed. The LIHEAP Program sends all policy and procedure changes to other program staff for review before implementation. This allows for ques comments to be answered and reviewed before policy is finalized. Quality Control Unit staff notify the LIHEAP administrator and the policy and sy (PaSS) Training team of all errors or potential fraud found through case reviews, this includes but is not limited to improper payments. This allows training team to build and implement trainings based on actual case errors. Eligibility workers also go through a strict training and integrity protocol on how to determine eligibility, cases worked by new workers in their first six months are reviewed by senior eligibility workers before approval or determined. The LIHEAP Program closely monitors application rates, denials, approvals, and application churn to identify any barriers to the progra application process. The LIHEAP Program also has access to a data dashboard which shows case payments and can assist in identifying ongoing ca fiscal team for the LIHEAP Program meets monthly to monitor expenditures and review any unusual trends. Risk assessments are conducted with varying frequencies to ensure comprehensive oversight. Benefit issuance is cross-referenced daily to m accuracy. Overall expenditures are reviewed monthly in conjunction with fiscal and the LIHEAP team to track financial health. Additionally, the all LIHEAP funds between programs is thoroughly evaluated on a quarterly basis. These assessments include additional checks as needed if any discre inconsistencies are noted during regular reviews. This tiered approach ensures continuous monitoring and timely resolution of potential issues. The LIHEAP Program utilizes risk assessment results to inform program improvements by integrating financial projection tools that calculat expenditures based on policy changes. By comparing actual outcomes with projected results, discrepancies are identified and addressed. Additionall counts and trends are continuously monitored via dashboards, enabling the program to refine processes and address discrepancies in real-time. This review helps in enhancing program accuracy and efficiency. The effectiveness of the risk assessment processes is confirmed through the alignment of financial projections with actual expenditures. Whe diverge from actual results, the program conducts detailed analyses using dashboards that track applications, benefit issuance, and case progress. Th to detect and investigate trends, including potential fraud, through correlation studies of overpayments and regional comparisons, demonstrates the r reliability of the risk assessment processes. The fiscal team creates comprehensive reports that are accessible to program administrators and the Director of Economic Assistance and du the Commerce Department. These reports and the associated dashboards ensure transparency and facilitate ongoing monitoring, contributing to the integrity and improvement of the LIHEAP program. Policy changes are sent to the Human Service Zones in the month prior to the changes becoming effective to give workers time to review an questions before the policy is implemented. Training guides are created and distributed statewide as areas of needed training are identified or when procedures are changed. The LIHEAP Program utilizes the policy and system support (PaSS) unit to deliver periodic program and policy training. A the program utilizes E-Learning courses that cover policies and case processing that are available statewide. New workers have all cases reviewed b for six months during a probationary period to ensure understanding and correct procedures are consistently followed when determining eligibility. The policy and system support (PaSS) unit monitors staff member trainings and takes feedback directly from participants. The Quality Control unit reviews LIHEAP cases monthly, which provides the PaSS unit with common errors to help create needed training. North Dakota is a state-supervised, county-administered program. DHHS has the responsibility of building and maintaining the computer sy determines eligibility and benefits state-wide. DHHS Fiscal Administration, LIHEAP Administrator and Economic Assistance Director monitor the program. Local agency utilization of LIHEAP is monitored monthly through statistical reports that are generated for review of caseload and expenditu These reports are shared within DHHS and each Human Service Zone for their review and information. If there are any discrepancies identified, the reviewed by the LIHEAP Administrator. Sub-Recipient Monitoring The LIHEAP program conducts in-person visits to the physical locations of sub-grantees and local LIHEAP administering offices. The key e our on-site monitoring plan are as follows: • Region-based On-Site Visits: We will conduct regular on-site visits for each of the four regions at least once every biennium. This ap allow our monitoring team to be physically present at each region, enabling direct and in-depth observation of operations. Please see the attachment example of the monitoring selection tool. • Sampling Strategy: Our team will implement a systematic sampling strategy during on-site monitoring visits. This involves interview worker and one supervisor at each location to gain insights into their roles, responsibilities, and adherence to LIHEAP policies. • Review of Cases and Applications: As part of the on-site monitoring process, we will review 10 randomly selected cases and 10 appr applications for accuracy and compliance. This detailed review will enable us to identify and address potential discrepancies. • Priority based on Emergency LIHEAP Cases: We recognize the urgency of addressing emergency cases promptly. Therefore, we wil scheduling on-site monitoring visits based on the number of emergency LIHEAP cases reported in each human service zone. • Collaboration with DOC: Our commitment to effective monitoring extends to collaborating closely with the Department of Commer will work together to ensure regular updates on their monitoring of weatherization sub-recipients. This collaborative approach will facilitate the reso issues promptly and comprehensively. In implementing this on-site monitoring plan, our goal is to fully comply with federal policies and ensure that our sub-grantees provide valua to low-income households across the state. We firmly believe that on-site monitoring strengthens our oversight capabilities and provides valuable op for improvement. The North Dakota Department of Health and Human Services uses a variety of verification interfaces to obtain verification electronically. The following interfaces/sources may be used: Birth/Death Records (ND Vital Records) • Health Insurance (DEERS) • ND Child Support • ND Department of Corrections • ND Motor Vehicle/Watercraft (Motor Vehicle/Game & Fish) • ND State Directory of New Hire • ND State Hospital Admission/Discharge • ND Unemployment Insurance Benefits (Job Service) • ND Wages (Job Service) • Other Benefit Information (SSA) • SNAP Intentional Program Violations • WSI Medical Claims Status • Request UPA • Request 40 Quarters • SAVE • Equifax • In addition to these interfaces/sources, eligibility workers also have access to additional verifications received through other program interfa the Income and Eligibility Verification System (IEVS), Social Security Administration and Public Assistance Reporting Information System (PARI For weatherization and emergency furnace services, monitoring is flagged in the Department’s electronic contract system on a specified sche throughout the life of the contract. 10.7. Describe how you select local agencies for monitoring reviews. Attach a risk assessment if subrecipients are utilized. Site Visits: LIHEAP will conduct in-person visits to the physical locations of sub-grantees and local LIHEAP administering offices. The key elements o monitoring plan are as follows: Region-based On-Site Visits: We will conduct regular on-site visits for each of the four regions at least once every biennium. This approach will monitoring team to be physically present at each region, enabling direct and in-depth observation of operations. Please see the attachment for an e monitoring selection tool. • Sampling Strategy: Our team will implement a systematic sampling strategy during on-site monitoring visits. This involves interviewing one wor supervisor at each location to gain insights into their roles, responsibilities, and adherence to LIHEAP policies. • Review of Cases and Applications: As part of the on-site monitoring process, we will review 10 randomly selected cases and 10 approved applica accuracy and compliance. This detailed review will enable us to identify and address potential discrepancies. • Priority based on Emergency LIHEAP Cases: We recognize the urgency of addressing emergency cases promptly. Therefore, we will prioritize sc site monitoring visits based on the number of emergency LIHEAP cases reported in each human service zone. • Collaboration with DOC: Our commitment to effective monitoring extends to collaborating closely with the Department of Commerce (DOC). W together to ensure regular updates on their monitoring of weatherization sub-recipients. This collaborative approach will facilitate the resolution o promptly and comprehensively. • If actual LIHEAP funding is more or less than estimated in the Final Plan, or funding runs out, North Dakota's LIHEAP may increase or decrease monitoring activities. Additionally, North Dakota's LIHEAP reserves the right to shorten or extend the program depending on the availability of increased demand, or other factors that impact the expenditures of LIHEAP funds. • Desk Reviews: The Quality Assurance Unit conducts monthly case file reviews. The human service zone office provides the case file or an electronic case file is retrieved from FileNet for the review process. A standard form is used for the review process. The form includes LIHEAP policy and procedures, i.e. verification of income, household members, etc. The results of the case file reviews are shared with the eligibility worker and Human Service Zone director. If overpayment exists as a result of the review, overpayments are established regardless if the overpayment is due to agency error or recipient error. At the time an overpayment is established, the family is informed of the overpaid amount and that they are responsible for repayment of the overpayment. Weatherization Monitoring by DOC; see attached document. 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? 0 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.
