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									                                                                                              APRIL 2003

93.926                         HEALTHY START COMMUNITIES


                           U. S. Department of Health and Human Services

Federal Authorization:         PHS Title III, Section 301, 42USC241 P.L. 104-208
                               SSA Title V, Section 502 (A) 42 USC702 P.L. 107 - 116
State Authorization:
                            N.C. Department of Health and Human Services
                                      Division of Public Health

Agency Contact Person – Program                   N.C. DHHS Confirmation Reports:
                                                  SFY 2003 audit confirmation reports for payments
Judy Ruffin                                       made to Counties, Area Programs, Councils of
(919) 733-0302                                    Government and District Health Departments will be
judy.ruffin@ncmail.net                            available by around late August to early September at
                                                  the following web address:
Agency Contact Person – Financial                 http://www.dhhs.state.nc.us/control/
                                                  At this site, page down to “Letters/reports/forms for
Allen Hawks                                       ALL Agencies" and click on "Audit Confirmation
                                                  Reports (State Fiscal Year 2002-2003)”.
(919) 715-6766

The auditor should not consider the Supplement to be “safe harbor” for identifying audit
procedures to apply in a particular engagement, but the auditor should be prepared to justify
departures from the suggested procedures. The auditor can consider the supplement a “safe
harbor” for identification of compliance requirements to be tested if the auditor performs
reasonable procedures to ensure that the requirements in the Supplement are current. The
grantor agency may elect to review audit working papers to determine that audit tests are


      The purpose of the Healthy Start Baby Love Plus Initiative is to reduce infant mortality and
      morbidity in the 14 specific counties. This is to be achieved by a) enhancing the effectiveness of
      existing maternal and child health activities and b) introducing new interventions that complement
      existing strategies in order to create a comprehensive package of strategies suitable for replication
      on a statewide basis. The comprehensive package of strategies will give each pregnant woman the
      opportunity to have a maternity care coordinator to assist with coordination of her care while
      pregnant. A community health advocate will provide outreach to educate the community about
      maternal and child health issues. This same individual will assist with locating women and bringing
      them in for early and continual care. Additional information is located in the Project Abstract found
      at program sites and the State program office.

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      The Healthy Start Baby Love Plus Initiative focuses on three regions of the State. The Eastern Baby
      Love Plus Program, established in 1998, covers seven (7) eastern counties: Bertie, Edgecombe,
      Greene, Pitt, Martin, Tyrrell, and Washington. The Northeastern Baby Love Plus Program,
      established in 1999 as a planning grant, continues to serve five (5) northeastern counties: Gates,
      Halifax, Hertford, Nash, and Northampton. The Triad Baby Love Plus Program, a disparity grant
      established in 1999, serves Forsyth and Guilford Counties. These project areas have recorded some
      of the highest infant mortality rates in the state. While each of the programs is tailored to serve a
      specific region, they collectively serve pregnant and parenting families through: Outreach primarily
      to women of childbearing age to increase their access to and knowledge of available services by
      providing transportation services (and at times, childcare and interpreter services) in 2 of the
      regions. Enhanced Clinical Services to increase community satisfaction with services and agency
      capacity to deliver care. Case Management to enhance efforts to better match a pregnant family’s
      needs with the services provided. Enhanced Case Management to focus on women’s health
      promotion. Local and regional consortium development, to increase community and agency
      coordination and collaboration to build programs that reflect the needs and values of the
      community. Community Planning Process in the belief that communities themselves can best
      develop the strategies necessary to attack the causes of infant mortality. The Northeastern Project
      also has a focus on the prevention of family violence during and around the time of pregnancy.
      Additional information is contained in the Project Abstract found at the program sites and the state
      program office. The Healthy Start Baby Love Plus Initiative is administered by the Maternal Health
      Unit, Women’s and Children’s Health Section, Division of Public Health, North Carolina
      Department of Health and Human Services.


      A. Activities Allowed or Unallowed

          Healthy Start Baby Love Plus funds may be used solely for the purposes detailed in the
          approved contract addendum/scope of work and budget. A scope of work/contract addendum
          is found at the local program site and the state program office.

      C. Cash Management

          Through a Consolidated Agreement, local health departments receive Maternal and Child
          Health Block Grant allocations and are reimbursed 1/12 of their allocation in the first effective
          month of the contract. All subsequent monthly payments are based on monthly expenditures
          reported. Local health departments must meet program outcome objectives, as specified in
          contract addenda, in exchange for the funding. The program objectives need to be met by the
          end of the period.

          The Contractor shall submit to the Division a monthly reimbursement request and, upon
          approval by the Division, receive payment within 30 days. The original expenditure report,
          DHHS 2481, shall be submitted to the Division Contract Administrator. The Contractor shall
          have up to sixty (60) days for close out, completion and submission of the final monthly
          expenditure report related to this contract period. If this contract is terminated, the Contractor
          is required to complete a final accounting report and to return any unearned funds to the
          Division within 60 days of the contract termination date. All payments are contingent upon
          fund availability.

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      E.   Eligibility

           Per the federal Healthy Start grant application, Eastern Baby Love Plus funds shall serve
           families in the seven county project area: Bertie, Greene, Edgecombe, Martin, Pitt, Tyrrell, and
           Washington Counties. Triad Baby Love Plus funds shall serve families in Forsyth and Guilford
           Counties. The Northeastern Baby Love Plus funds can only be used to serve families in Gates,
           Halifax, Hertford, Nash, and Northampton Counties. This includes women of childbearing age
           (mainly 14-44 years), children under age 2, and their families.

           Healthy Start Baby Love Plus agencies shall impose no charges on clients for services.

      F.   Equipment and Real Property Management

           Equipment must be accounted for in accordance with the North Carolina Department of State
           Treasurer Policies Manual, Chapter 20, Fixed Assets Policy.

           Title to equipment costing in excess of $500.00 acquired by the Contractor with funds from
           this contract shall vest in the contractor, subject to the following conditions.

           1. The Contractor shall use the equipment in the project or program for which it was acquired
              as long as needed. When equipment is no longer needed for the original project or program
              or if operations are discontinued, the Contractor shall contact the Department of Health
              and Human Services, Division of Public Health, for written instructions regarding
              disposition of equipment.

           2. When acquiring replacement equipment, the Contractor may use the equipment to be
              replaced as trade-in against replacement equipment or may sell said equipment and use the
              proceeds to offset the costs of replacement equipment subject to written approval of the
              Division of Public Health.

           3. For equipment costing in excess of $500.00, equipment controls and procedures shall
              include at a minimum the following:

                    a)    Detailed equipment records shall be maintained which accurately include the:

                          i. Description and location of the equipment, serial number, acquisition
                             date/cost, useful life and depreciation rate;

                         ii. Source/percentage of funding for purchase and restrictions as to use or

                         iii. Disposition data, which includes date of disposal and sales price or method
                              used to determine fair market value.

                    b)    Equipment shall be assigned a control number in the accounting records and
                          shall be tagged individually with a permanent identification number.

                    c)    Biennially, a physical inventory of equipment shall be taken and results
                          compared to accounting and fixed asset records. Any discrepancy shall
                          immediately be brought to the attention of management and the governing board.

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                    d)   A control system shall be in place to ensure adequate safeguards to prevent loss,
                         damage, or theft of equipment and shall provide for full documentation and
                         investigation of any loss or theft.

                    e)   Adequate maintenance procedures shall be implemented to ensure that
                         equipment is maintained in good condition.

                    f)   Procedures shall be implemented which ensure that adequate insurance coverage
                         is maintained on all equipment. A review of coverage amounts shall be
                         conducted on a periodic basis, preferably at least annually.

           4. The Contractor shall ensure all subcontractors are notified of their responsibility to comply
              with the equipment conditions specified in this section.

      G. Matching, Level of Effort, Earmarking

           Level of Effort – The contractors must maintain expenditures of contracted funds for reporting
           of healthy start activities equal to that reported in the contract.

           Matching and earmarking are not applicable at the local level.

           Suggested Audit Procedures - Identify the required level of effort and perform tests to verify
           that the level of effort requirement was met.

      H. Period of Availability of Federal Funds

           Local health departments will abide by rules governed under the consolidated agreement.

           For other entities, funding is available only for the duration of the contract period found in the
           contract agreement. Final expenditure reports must be received by DHHS within 60 days after
           the end of the contract period. The Office of the Controller must receive amended or corrected
           expenditure reports within six months after the end of the contract period.

      I.   Procurement and Suspension and Debarment

           Procurement – Prior written approval from Department must be obtained before purchasing
           equipment valued over $500. Institutions of higher education, hospitals, and other non-profit
           organizations shall use procurement procedures that conform to applicable federal law and
           regulations and standards identified in OMB Circular A-110. All non-federal entities shall
           follow federal laws and implementing regulations applicable to procurements, as noted in
           federal agency implementation of the A-102 Common Rule and OMB Circular A-110.

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           Suspension and Debarment

           Compliance Requirement – Non-federal entities are prohibited from contracting with or
           making subawards under covered transactions to parties that are suspended or debarred or
           whose principals are suspended or debarred.

           Suggested Audit Procedures:

           a.   Test a sample of contracts and ascertain if the required suspension and debarment
                certifications were received for subawards and covered contracts.

           b.    Test a sample of contracts to the List of Parties Excluded from Federal Procurement or
                 Nonprocurement Programs, issued by the General Services Administration and ascertain if
                 contracts were awarded to suspended or debarred parties.

      J. Program Income

           All revenues collected as conference fees, third party fees or patient fees and which are
           generated through the activities supported by funds will be reported to the Department in
           conjunction with monthly expenditure reports. Revenue generated thusly must be budgeted
           and expended within the fiscal year earned or within the subsequent fiscal year and will be
           used either to expand program services or to reduce the amount of state appropriation.

      L.   Reporting

           Local health departments are required to submit quarterly reports to the Program detailing how
           funds have been utilized. Local projects are also required to report specific data for evaluation
           studies. Other contractors are required to submit monthly expenditures. At the end of the
           contract period, each contractor will submit data reflecting whether the activity occurred, the
           actual population served, the number of participants, the actual outcomes, and the method of
           evaluation. The end of project reports will also include a narrative that highlights successful
           activities that occurred during the fiscal year. All reports will be submitted to the Women's
           Health Branch within 30 days following the termination date of contract.

      N. Special Tests and Provisions

           1. Compliance Requirements

                Conflict of Interest for nonprofit organization

                The 1993 General Assembly enacted legislation (Chapter 321, Section 16, 1993 Session
                Laws) requiring each private, not-for-profit entity, as a prerequisite to the receipt of
                funding from the State, to formally adopt a policy, which addresses conflicts of interest that
                might arise involving the entity’s management, employees, and/or board members. The
                policy statement is expected to address situations in which any of the above referenced
                individuals may directly or indirectly benefit from the entity’s disbursement of funds
                received from the State. In addition, the policy should specify actions to be taken by the
                entity or individuals, or both, to avoid either actual conflicts of interest or the appearance
                of an impropriety. Before a private, not-for-profit entity receives and disburses State funds
                the entity should have adopted and have filed a copy of the policy statement.

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          Audit Objective - Determine whether the grantee has adopted and has on file, a conflict of
          interest policy, before receiving and disbursing State funds.

          Suggested Audit Procedures

          1. Ascertain that the grantee has a conflict of interest policy.

          2. Check the policy and verify through board minutes that the policy was adopted before
             the grantee received and disbursed State funds.

       2. Compliance Requirement

          Consolidated Agreement System

          The DHHS Division of Public Health is made up of six major sections, Health Promotion
          and Disease Prevention, Epidemiology, Women’s and Children’s Health Services, Oral
          Health, Local Health Services, and Financial Management and Support Services Section.
          The Division utilizes a single written agreement to manage all funds, that is, State, federal,
          or private grant funds, that the Division allocates to local health departments across the
          State. This document, as amended, is called the Consolidated Agreement.
          The Agreements sets forth the more general requirements of the funding relationship
          between the state and local public health agencies. The respective requirements are
          detailed under the headings: Responsibilities of the Department (Local Public Health
          Unit); Funding Stipulations; Fiscal Control; Responsibilities of the State; and Compliance.
          More specific information related to program activity is set out in a document called the
          Agreement Addenda which details outcome objectives (which may or may not be
          negotiable at the beginning of each fiscal year) that each health department must achieve in
          exchange for the funding. A third part of the system is the Budgetary Authorization which
          is sent annually from each of the Sections or Branches of the Division to all health
          departments being allocated funds from specific sources, e.g., State appropriations or other
          federal grant funds for specific activities. This estimate indicates the amount of the
          allocated funds and their respective sources. Each health department should be able to
          provide an auditor with a copy of the Consolidated Agreement for the particular year being
          audited, as well as copies of the Budgetary Authorization and any revisions, Agreement
          Addenda, expenditure reports and any activity reports for each source of money received.
          If the health department cannot provide these documents, they may contact the State
          Division of Public Health Budget Office for assistance.
          Suggested Audit Procedures – It is suggested that Section B. FUNDING STIPULATIONS
          of the Consolidated Agreement be reviewed by the auditor before beginning an audit. The
          fourteen items of this Section describe much of the detailed information the auditor may be
          seeking during a review of these programs.

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