The TRG Finance Department is committed to ensuring good stewardship of public resources by helping subrecipients comply with their contracts and compliance with State and Federal requirements for fiscal monitoring. As the Administrative Agency, it is our expectation that all awarded subrecipients have effective internal controls to manage funding and prevent fraud, waste, and abuse.
Do you have the fiscal foundation to meet financial reporting requirements?
Financial Management Standards
Subrecipients are required to follow 2/5/2018 Texas Health and Human Services Grant Technical Assistance Guide (GTAG) and 45 CFR 75 - Title 45 Public Welfare Part 75 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (Uniform Guidance) for the administration of grant funds. Where applicable, federal law will supersede the GTAG. Technical assistance in the use of these procedures is available from TRG’s Finance Department.
Uniform Guidance: https://www.govinfo.gov/content/pkg/CFR-2016-title45-vol1/pdf/CFR-2016-title45-vol1-part75.pdf
Minimal financial management and controls include:
Financial planning includes the development and monitoring of budgets that adequately reflect all functions and resources necessary to carry out authorized activities and the adequate determination of costs;
Financial management system and corresponding policies including accurate, correct, and complete payroll, accounting, and financial reporting records; cost source documentation, effective internal and budgetary controls; determination of reasonableness, allowability, and allocability of costs; and timely and appropriate audits and resolution of any findings; and,
Billing and collection policies include a charge schedule, a system for discounting or adjusting charges based on a person's income and family size, and a mechanism capable of billing and making reasonable efforts to collect from patients and third parties.
TITLE: Payer of Last Resort (PoLR)/Medicaid
The costs of delivering services should be reasonably shared by the state and federal governments, private health insurers, and, to the extent possible, by the person with an HIV-related condition. To maximize the limited program funds, Ryan White funds should be considered the payer of last resort. Subrecipient must agree to bill third-party payers for applicable (where the cost of the service is reimbursable from any third-party source) services provided, at no cost to the client, except for co-payments required by third-party payers. These potential payers include private insurance carriers, Medicaid, other available federal, state, local, and private funds, etc.
Subrecipient shall maximize efforts to obtain payment from Medicaid and all other available sources. Subrecipient who provide Medicaid reimbursable services are required to become Medicaid providers for applicable program activities. Where applicable, Subrecipient must establish the ability to bill private insurance including private health insurance, employer insurance plans, marketplace (ACA) plans and prepaid health plans.
Link: DSHS Funds as Payment of Last Resort, www.dshs.texas.gov/hivstd/policy/policies/590-001.shtm;
Link: TRG Payer of Last Resort (SR-0202-20)
Consumer Charges for Billable Services
In compliance with PoLR requirements, it is expected that all subrecipients have a sliding-fee schedule in place that uses as its premise the latest Federal Poverty Guidelines. Persons with an annual gross family income at or below 100% of the Federal Poverty Guidelines shall not be charged for any services covered by this funding. In accordance with Title 25 Texas Administrative Code §1.91, no one shall be denied services due to their inability to pay.
Please refer to the following chart for the annual cap on allowable charges:
MODIFIED ADJUSTED GROSS INCOME (MAGI)
ANNUAL CHARGES TO PLWH
Equal to or below the official poverty line
No charges permitted
101 to 200 percent of the official poverty line
5 percent or less of FPL
201 to 300 percent of the official poverty line
7 percent or less of FPL
301 to 500 percent of the official poverty line
10 percent or less of FPL
The most current HHS poverty guidelines can be found: https://aspe.hhs.gov/topics/poverty-economic-mobility/poverty-guidelines
Additional resources on MAGI can be located at DSHS’s Website https://dshs.texas.gov/hivstd/magi/
All revenues received for services provided by these funds are considered program income. Any revenues generated from third-party reimbursements/private insurance, Medicaid, Medicare or 340b pharmacy constitute program income. Subrecipient must report how such program income is used by the sub-recipients to advance the objectives of the HIV/AIDS program.
All program income generated as a result of program funding must be used for allowable current costs, and the income shall be budgeted and expended during the budget period in which it is realized. The receipt and expenditure of all program income shall be reported on the monthly expense report and the quarterly financial report.
Please refer to the 2/5/2018 Texas Health and Human Services GTAG (at https://dshs.texas.gov/contracts/gtag.aspx) and the 2017 HHSC Uniform Terms and Conditions, Version 2.15 (at https://apps.hhs.texas.gov/PCS/HHS0000310/Exhibit-B-UTC-Grantee.pdf) for detailed requirements for program income.
DISCLAIMER: The information provided is not all-inclusive of all financial management requirements. All requirements will be explicitly detailed in the Request for Proposal, with applicable links to Federal and State guidance.