4/1/20 - Message for Division of Rehabilitation Services Providers - Grant Agreement Guidance Letter

Dear Community Grantee Provider:

In communications shared with you on March 16, 19, and 23, Secretary Hou shared with you that IDHS is making every effort to sustain funding for organizations that are unable to provide services or able only to provide limited services because of the COVID-19 public health emergency. This communication is intended to serve as guidance for the grant agreements you have with the Division of Rehabilitation Services to provide services through the Independent Living Program, Older Blind Program, and programs funded through the Donated Funds Initiative.

Specifically, for community providers who have a grant agreement to provide services through the Older Blind Program, please be advised that the Division is deferring, until FY22, the Notification of Funding Opportunity that would have otherwise been posted for FY21 due to the three-year grant agreement term limitation. Current grantees will receive the same amount of funding in FY21 as they did in FY20. Grantees should make the necessary adjustments to all Uniform Grant Budgets currently in process for FY21 to ensure the appropriate allocation of costs.

In addition, the Department is issuing the following FY20 guidance for current grant programs:

Given that the State adopted Federal Uniform Regulation 2 CFR 200 to be applied to State grant awards, the Illinois Governor's Office of Management and Budget (GOMB) and the Grant Accountability and Transparency Unit (GATU) concur with IDHS' request to apply the language communicated to the State by the Executive Office of the President, Deputy Director of Management, Memorandums M-20-11 dated March 9, 2020 and M-20-17 dated March 19, 2020 to relieve the administrative burden for State funded grant program awardees

Expenditure Budget Based Programs
i) Grantees that are not permitted to provide any or limited services to individuals due to COVID-19 Social Distancing mandated by Governor Pritzker are:

(1) Waived from performance of direct client related services; however, we encourage our grantee partners to seek opportunities to use alternative methods of service delivery, such as telehealth. IDHS grant program managers should collaborate with their respective grantee partners in this endeavor.

(2) Permitted to continue to charge salaries and benefits to currently active awards consistent with the recipient organization's policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources.

(3) Permitted to continue to charge Facility and Administrative (F&A) costs such as occupancy, insurance, taxes, utilities.

(4) Permitted to delay the submission of financial and performance reports for three months beyond the normal due date.

(5) That have not yet filed their single audits with the Federal Audit Clearinghouse as of the date of the issuance of this memorandum that have fiscal year-ends through June 30, 2020, are permitted to delay the completion and submission of the Single Audit reporting package, as required under Subpart F of 2 CFR § 200.501 -Audit Requirements, to six (6) months beyond the normal due date. No further action by awarding agencies is required to enact this extension. This extension does not require individual recipients and subrecipients to seek approval for the extension by the cognizant or oversight agency for audit; however, recipients and subrecipients should maintain documentation of the reason for the delayed filing. Recipients and subrecipients taking advantage of this extension would still qualify as a "low-risk auditee" under the criteria of 2 CFR § 200.520 (a)-Criteria for a low-risk auditee.

(6) Permitted to charge other costs to awards, including those necessary to resume activities. Costs must be considered necessary, reasonable, allocable, and otherwise not unallowable. Costs that are determined by the Department to not be considered necessary, reasonable, allocable, or allowable will be disallowed and subject to recovery. Program Managers should advise their grantees to seek program advice or approval should they have questions about incurring such costs.

ii) Grantees are required to:

(1) Payroll: Pay all current employees their full pay and benefits in accordance with their approved grant budget.

(2) Tax and Fringe: Remit all employer employee contributions such as payroll taxes, employment security, FICA, insurance, retirement plans. This is not an all-inclusive list.

(3) Grantees that are paid post performance will continue to submit invoices to the program and payments will be remitted as they are currently. For DHS-DRS, an invoice is equivalent to the Monthly Expenditure Report (MER).

(4) Submit their quarterly IDES Form UI-3/40 to corroborate their personnel costs as reported on incurred personnel costs reported on the periodic invoices. Submission will coincide with the quarterly performance and fiscal reporting due date. Note: This is a new requirement.

iii) Grantees are not permitted to:

(1) Create new bonus programs or increase salaries or hourly rates of pay for employees without written permission of the IDHS Program Manager.

(2) Pay employee bonuses without written permission of the IDHS Program Manager.

It is our intent to engage you further and answer any questions you may have during a special teleconference on April 2, 2020 at 4:00 p.m. The following call-in information should be used 1-888-494-4032, access code 338-068-3783#. You may also email questions in advance to your DRS project officer.

With Warm Regards,

Cassie Laird, DRS Fiscal Unit Administrator