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In order to comply with Office of Grants Management Policies 08‐08 and 08‐10, MDH grant payments for the Local Public Health Act to community health boards will be administered on a reimbursement basis. MDH will reimburse community health boards for expenses based on invoices submitted to MDH on either a monthly or quarterly basis. All invoices should be sent electronically to firstname.lastname@example.org for processing.
MDH recognizes that grantees incur certain costs of doing business that are not easily identified with a particular grant or activity. These costs are often referred to as indirect and administrative costs. In order to comply with Minn. Stat. § 16B.98, subd.1, MDH is responsible for negotiating appropriate limits to these costs so that the state derives the optimum benefit for grant funding. MDH requires that grantees formally agree to minimize indirect costs.
In addition, 2 CFR 200.331 requires that non-federal entities must recognize federally approved indirect cost rates. Grantees without a federally approved indirect cost rate must provide an indirect cost rate of no more than 10 percent of the total grant award. Administrative costs directly attributable to the grant program must be included as part of the appropriate budget line item and not included as part of an organization's indirect costs.
MDH will ask grantees to submit a requested rate for indirect costs and a list of the types of costs included in the grantees indirect costs.
More information on the indirect costs can be found here:
MDH Policy on Indirect and Administrative Costs (PDF)
In early 2013, the MDH submitted an alternate plan to the Minnesota Office of Grants Management (OGM) on how MDH would conduct financial reconciliation for grants to CHBs. During 2013, MDH piloted that original exception request with five CHBs. The purpose of the pilot was to:
- Better understand the financial reconciliation process
- Assess the capacity of MDH and CHBs to carry out the new procedures
- Engage CHBs in identifying alternate solutions to help MDH meet the intent of the policy
While MDH found no major concerns during the pilot process, CHBs had concerns about the amount of time it took to gather documentation and produce paper reports from the supporting systems. The following alternate reconciliation plan was submitted and approved by OGM in April 2014.
Approved Alternate Reconciliation Plan
Continue existing monitoring activities:
- WIC: No changes. Site visits and financial reconciliations once every two years as required byfederal regulations
- Continue programmatic site visits and monitoring (e.g., annual reporting)
- Continue grant reimbursement as the standard
Local Public Health Act funding removed from reconciliation requirement. No general ledger review required for Local Public Health Act funds.
All Other MDH Grants to Local Public Health
- MDH staff will gather and annually review findings from county or Single Audits already completed for the county and/or fiscal host for the Community Health Boards.
- MDH will create a questionnaire about changes to systems, personnel, procedures and programs for Community Health Boards without an annual audit to capture similar information for the annual review
- Any concerns identified in audit or questionnaire may lead to more thorough financial reconciliation or request for source documentation.
- All MDH grant programs over $50,000 will require a copy of the general ledger with at least one invoice submission during the grant period and review prior to payment. MDH may request additional info as/if needed.
- MDH will survey grants management staff at MDH every few years to identify concerns with grantees or procedures.
- MDH will create additional guidance for CHBs through toolkits/technical assistance to address concerns around common grant expenses.
- MDH will seek feedback about the alternate reconciliation process from local public health at least every three years to continue improving this process and provide updates to the Office of Grants Management as needed.