From: hi v? To: SSW Cc: Browne. Shirley; Peavey, Sheryl; Wiley, Jeffrey Subject: RE: Priority Approval for Journal Entries Date: Wednesday, November 04, 2015 11:16:09 AM Hi Darryl, I appreciate your thoughtful feed back and your audit perspective on this matter. I am including Sheryl Peavey and Jeff Wiley from the Commissioner?s Office on this so they can consider you ACF comments. Sounds like sound advice to me. Thanks again. //Jeff, Sheryl, I believe the highlighted section below is worth a discussion. Let me know if you?d like to meet. Warmest Regards, David Whitt Department of Administrative and Financial Services Deputy Director? Financial Services Center 221 State Street Augusta, ME 04333 Cell: 207-248-7150 From: Stewart, Darryl Sent: Wednesday, November 04, 2015 11:01 AM To: Whitt, David Cc: Browne, Shirley Subject: RE: Priority Approval for Journal Entries Hi David, I can tell that you (and the program managers) have put a significant amount of thought and work into this. In my opinion, including this narrative (and the financial back-up) in support of the transfer journal will help OSC and BOB during the review process. It explains why DH HS (the entity ultimately responsible for administering TANF SSBG) believes that this is an allowable activity of the transfer funds and provides insight into the Department?s thought process. That being said, I do not think we?re in a position to provide you with an opinion as to whether the federal government would consider these allowable costs of the TANF transfer to SSBG. Do you know whether ACF has been involved with the State?s interpretation and definition of "target group eligibility? and whether ACF has indicated that the State?s definition complies with the requirement that the TANF transfer be used "only for programs and services to children or their families?? Per the Uniform Guidance, the State has the option to request prior written approval for costs the State has difficultly in determining allowable Considering the financial implications, it may be prudent for the Department to reach out to ACF for approval. ?200.407 Prior written approval (prior approval). Under any given Federal award, the reasonableness and allocability of certain items of costs may be dif?cult to determine. in order to avoid subsequent disallowance or dispute based on unreasonableness or nonallocability, the non-Federal entity may seek the prior written approval of the cognizant agency for indirect costs or the Federal awarding agency in advance of the incurrence of special or unusual costs. Prior written approval should include the timeframe or scope of the agreement. The absence of prior written approval on any element of cost will not, in itself, affect the reasonableness or allocability of that element, unless prior approval is speci?cally required for allowability as described under certain circumstances in the following sections of this part: ?200.201 Use of grant agreements (including ?xed amount awards), cooperative agreements, and contracts, paragraph ?200.306 Cost sharing or matching; ?200.307 Program income; ?200.308 Revision of budget and program plans; ?200.31?l Real property; ?200.313 Equipment; (9) ?200.332 Fixed amount subawards; ?200.413 Direct costs, paragraph ?200.430 Compensation?personal services, paragraph ?200.431 Compensation?fringe bene?ts; ?200.438 Entertainment costs; (1) ?200.439 Equipment and other capital expenditures; ?200.440 Exchange rates; ?200.441 Fines, penalties, damages and other settlements; ?200.442 Fund raising and investment management costs; ?200.445 Goods or services for personal use; ?200.447 Insurance and indemni?cation; ?200.454 Memberships, subscriptions, and professional activity costs, paragraph ?200.455 Organization costs; ?200.456 Participant support costs; ?200.458 Pre-award costs; ?200.462 Rearrangement and reconversion costs; ?200.467 Selling and marketing costs; ?200.470 Taxes (including Value Added Tax); and ?200.474 Travel costs. [78 FR 78608, Dec. 26, 2013, as amended at 79 FR 75885, Dec. 19, 2014] From: Whitt, David Sent: Monday, November 02, 2015 7:48 AM To: Stewart, Darryl Cc: Browne, Shirley Subject: RE: Priority Approval for Journal Entries Not quite I wish it was completely straightforward! 1. Individuals do not live in an Right.. 2. TANF transfer funding, as a percentage of the whole in each contract, is well below the 82% proportion of the population that meets the 200% FLP according to OADS studies from that time period. 3. For the "children or their families? portion HHS is using "target group eligibility? similar to what other States are The idea is you deem a group eligible by defining a "family." In this case, they are using the ?family? definition in the 8586 application that is very broad. a. have some familiarity with the State?s ability to define terms. Ifyou remember, in the case of using TANF transfer for child welfare, room and board is a restriction except in cases of emergency. According to the Feds, an emergency is usually a day or However, the States can often define what terms mean. in our case, definition of emergency is anything less than a year ?they defined that back in 1991 (I?d have to dig it back out to remember what that When we contacted Marsha Warner at SSBG to inquire about using our own definition and how much authority the State had she immediately confirmed that this was up to the State in how it defined emergency and the State could define it however they wished. Warmest Regards, David Whitt Department of Administrative and Financial Services Deputy Director? Financial Services Center 221 State Street Augusta, ME 04333 Cell: 207-248-7150 From: Stewart, Darryl Sent: Friday, October 30, 2015 3:59 PM To: Whitt, David Cc: Browne, Shirley Subject: RE: Priority Approval for Journal Entries Good Afternoon David, This email is in relation to the TANF transfer Earmarking requirements and Bullet 2.a. from your narrative, which states, "In this case, DHHS is using TANF transfer dollars to 8586 for Elderly and Adults Home Based Care (vendor is Seniors Plus) and Independent Support (Homemaker) Services (vendor is Catholic To make this as simple as possible, is this the situation?: The individuals receiving these services (above): (1) do not live in an institution, (2) do have children living with them, and (3) their income is less than 200% of the FPL. lam trying to make sure I understand how these individuals meet the earmarking requirements (you referenced in Bullet 3) stipulated in the 2015 5586 Compliance Supplement: G. Matching, Level of E?ort, Earmarking 3. Earmarking. The State shall use all of the amount transferred in from TANF (CFDA 93.558) only for programs and services to children or their families whose income is less than 200 percent of the official poverty guidelines as revised annually by HHS {42 USC 604(d)(3) (A) and 9902(2)). Additional information on this transfer in is provided in IV, "Other information. Thanks, Darryl From: Labbe, Christie Sent: Friday, September 18, 2015 10:50 AM To: Dickinson, Angela L. OSC Accounting Staff Cc: Gove, Sarah; Whitt, David; Bailey, Samantha Subject: RE: Priority Approval for Journal Entries Good Morning, The followingjournals have been submitted and need second level approval: ABSJ 10A 8116CLO9141504 ABSJ 10A 8116CLO9141505 10A 8116CL09141506 ABSJ 10A 8116CLO9141507 ABSJ 10A 8116CL09141508 ABSJ 10A 8116CLO914151O Please note, ABSJ 10A 8116CL09141509 will not be submitted until next Tuesday, when the funds will be available. Thank you for all your help. Best Regards, Christie Labbe Senior Staff Accountant Service Center 221 State Street State House Station tt 11 Augusta, ME 04330 phone: 287-5962 email: christielabbe@maine.gov Please consider the environment before printing this email Con?dentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain con?dential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy/delete all copies of the original message. From: Dickinson, Angela L. Sent: Friday, September 18, 2015 8:26 AM To: Labbe, Christie; OSC Accounting Staff Cc: Gove, Sarah; Whitt, David; Bailey, Samantha Subject: RE: Priority Approval for Journal Entries The first three journals are now approved. Please continue with the other submissions. Thank you, Angela Dickinson This message (including any attached ?les) contains confidential information intended for a speci?c individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this message and notify us immediately. Any disclosure, copying, or distribution of this message, or the taking of any action based on it, is strictly prohibited. You can notify us by return email or phone at 207-626-8420. From: Labbe, Christie Sent: Wednesday, September 16, 2015 4:10 PM To: Dickinson, Angela L. OSC Accounting Staff Cc: Gove, Sarah; Whitt, David; Bailey, Samantha Subject: RE: Priority Approval for Journal Entries Hi Angela, The journals should be approved in the following order: ABSJ 10A 8116CL09141502 ABSJ 10A 8116CL09141503 JVC 10A 10A 10A ABSJ 10A ABSJ 10A 8116CL09141507 ABSJ 10A 8116CLO9141508 . ABSJ 10A 10. ABSJ 10A When journals 1-3 are approved, please let me know and I can get the rest over to you for approval. Thank you for all your help. Best Regards, Christie Labbe Senior Staff Accountant HS Service Center 221 State Street State House Station it 11 Augusta, ME 04330 phone: 287-5962 email: Please consider the environment before printing this email Con?dentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy/delete all copies of the original message. From: Dickinson, Angela L. Sent: Wednesday, September 16, 2015 3:44 PM To: Labbe, Christie; OSC Accounting Staff Cc: Gove, Sarah; Whitt, David; Bailey, Samantha Subject: RE: Priority Approval for Journal Entries The below documents marked in red cannot be approved for override due to insufficient funds. The remaining items are approved for next day priority. Please let me know if certain journals need to be approved first in order to process others. Thank you, Angela Dickinson This message (including any attached files) contains con?dential information intended for a speci?c individual and purpose, and is protected by law. If you are not the intended recipient, you should delete this message and notify us immediately. Any disclosure, copying, or distribution of this message, or the taking of any action based on it, is strictly prohibited. You can notify us by return email or phone at 207-526-8420. From: Labbe, Christie Sent: Wednesday, September 16, 2015 3:37 PM To: OSC Accounting Staff Cc: Gove, Sarah; Whitt, David; Bailey, Samantha Subject: Priority Approval for Journal Entries Importance: High Good Afternoon, May have priority approval on the documents listed below: ABSJ 10A 8116CL09141502 10A 8116CL09141503 JVC 10A 10A ABSJ 10A 10A 10A 8116CL09141507 ABSJ 10A 8116CL09141508 10A ABSJ 10A These documents need priority approval because of the potential loss of federal funds if they are not approved by 9/30/15. We are also requesting priority approval so that we stay in compliance with CMIA, which limits us to seven days cash on hand. Thejournals need to be approved in the order have them listed in. The journals with next to them are currently in rejected status and need special override approval. Thank you, Christie Labbe Senior Staff Accountant HS Service Center 221 State Street State House Station 11 Augusta, ME 04330 phone: 287?5962 email: christielabbe@mainegov Please consider the environment before printing this email Con?dentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure, or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy/delete all copies of the original message.