Social Services Block Grant (SSBG) State Plan

Social Services Block Grant (SSBG) State Plan Source: Miss Code Annotated 43-47-35 Office of Social Services Block Grant (SSBG) State Plan Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 2 - MISSISSIPPI DEPARTMENT OF HUMAN SERVICES 750 NORTH STATE STREET JACKSON, MS 39202 (601) 359-4658 SOCIAL SERVICES BLOCK GRANT 2016 STATE PLAN/PRE-EXPENDITURE REPORT NARRATIVE Presented by: Mississippi Department of Human Services Richard A. Berry Executive Director Office of Social Services Block Grant Leigh Washington, Director Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 3 - TABLE OF CONTENTS Page ELIGIBILITY CRITERIA AND INCOME GUIDELINES ............................................... 8 & 9 MDHS AGING AND ADULT SERVICES PROGRAM OVERVIEW............................... 10-15 MDHS FAMILY AND CHILDREN’S SERVICES PROGRAM OVERVIEW ................. 16-20 MDHS YOUTH SERVICES PROGRAM OVERVIEW ...................................................... 21-22 FISCAL OPERATION ............................................................................................................. 23-25 STANDARD ASSURANCES & CERTIFICATIONS .......................................................... 29-32 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 4 - CONTACT INFORMATION The Mississippi Department of Human Services (MDHS) has been designated by Governor Phil Bryant to administer the Social Services Block Grant (SSBG) in Mississippi. The Social Services Block Grant is administered through the Mississippi Department of Human Services Executive Director’s Office. Richard A. Berry, Executive Director Mississippi Department of Human Services Post Office Box 352 Jackson, Mississippi 39205-0352 Telephone: (601) 359-4457 Fax: (601) 359-4477 Program Contact: Leigh Washington, Director Office of Social Services Block Grant Post Office Box 352 Jackson, Mississippi 39205-0352 Telephone: (601) 359-4416 Fax: (601) 359-4477 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 5 - PUBLIC INSPECTION OF PRE-EXPENDITURE REPORT Federal regulations covering Social Services Block Grant do not require a public hearing, only public participation solicited through a method set by the state. Public notice will be provided in a ccordance with Miss. Code Annotated 25-43 -3.103 which states, “At least twenty-five (25) days before the adoption of a rule an agency shall cause notice of its contemplated action to be properly filed with the Secretary of State for publication in the administrative bulletin.” Mississippians wishing to offer input on issues and concerns regarding social services provided by the Mississippi Department of Human Services, Divisions of Aging and Adult Services, Family and Children’s Services, and Youth Services, may send written comments to the Office of Social Services Block Grant, Mississippi Department of Human Services, P.O. Box 352/750 State Street, Jackson, Mississippi 39202, or e-mail Leigh Washington at leigh.washington@mdhs.ms.gov. All public comments and suggestions will be included in the Pre-Expenditure Report which will be forwarded to the Governor. To obtain a draft copy of the FFY 2016 Pre-Expenditure Report, please visit our website at www.mdhs.ms.gov or email Joy Dart at joy.dart@mdhs.ms.gov . Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 6 - LEGISLATIVE AUTHORITY On January 4, 1975, a new Title XX was added to the Social Security Act, which authorized an entitlement to States, for the provision of social services. Prior to the Title XX, States received matching Federal funds for specified categories of services, with eligibility for the services limited to receipt of public assistance under several titles of the Social Security Act. Under Title XX, States were given increased flexibility to offer a wider range of services to a broader population of adults and children. The statute also included requirements regarding planning, public participation, income eligibility, and administration. ADMINISTRATIVE OPERATIONS In 1981, Congress created a block grant to states for social services under the Omnibus Budget Reconciliation Act (Public Law 97-35) authorizing a wide range of community social services for individuals and families. These services are designed to prevent or reduce dependency, prevent neglect or abuse of children and adults, prevent or reduce inappropriate institutional care, and provide a limited range of services to individuals in institutions. It is the general belief of the State of Mississippi that persons should be self-sufficient and not dependent on the government for support. It is better for the individual and the community if people are able to solve problems on their own and contribute positively to society within the limit of their capabilities. In turn, the state has a responsibility to provide a positive atmosphere to allow and encourage persons to achieve self-sufficiency. Government will continue to have the responsibility for assisting citizens who are vulnerable and unable to care for themselves. Thus, the two-fold mission of the Social Services Block Grant in Mississippi is to protect vulnerable individuals and to assist individuals in achieving or maintaining self- sufficiency. Eligible persons for services are persons whose income is at or below poverty level, or who are unable to responsibly care for themselves. In order to enable recipients to become self-sufficient, programs must recognize the underlying importance of increasing client’s self-esteem and determination to overcome the significant problems of poverty. Resolving the complex problems associated with strengthening poor families and individuals in Mississippi will require significant efforts by clients themselves, by the state working in partnership with other levels of government, and with the private, voluntary, philanthropic, and independent sectors. With the support of these services, individuals will move toward adequately providing for themselves. This upward mobility of clients will encourage a shorter period of dependency. Policy and service priorities should reflect this perspective. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 7 - SSBG NATIONAL GOALS • Achieving or maintaining economic self-support to prevent, reduce or eliminate dependency • Achieving or maintaining self-sufficiency, including reduction or prevention of dependency • Preventing or remedying neglect, abuse, or exploitation of children and adults unable to protect their own interest or preserving, rehabilitating, or reuniting families • Preventing or reducing inappropriate institutional care by providing for community-based care, home-based care, or other forms of less intensive care • Securing referral or admission for institutional care when other forms of care are not appropriate or providing services to individuals in institutions. GOALS AND OBJECTIVES These goals and objectives will serve as a framework for the administration of the Social Services Block Grant for Fiscal Year 2016. Services • Social Services Block Grant funds shall be used to support those services as agreed to by the State Of Mississippi in accordance with federal and state laws. • The emphasis of the Social Services Block Grant will be on prioritizing services of protection, services that have long-term impact to reduce dependency and enhance self-sufficiency, and services that support vulnerable populations enabling them to remain in their home and community, thereby avoiding or reducing institutionalization. • Federally earmarked funds, under the Social Services Block Grant, will be used for services as stated in the federal regulations and will not be subject to the full allocation process. • Service coordination and joint working goals and objectives among various agencies will be emphasized and encouraged. The following broad service categories shall govern all service activities supported by the Social Services Block Grant allocations for Fiscal Year 2015. • Self-Sufficiency: Social support services which directly relate to decreased government or non-government assistance in daily living. • Protection: Social support services which are essential to the protection or well- being of an individual or family. • Maintenance: Social support services which are necessary to allow an eligible individual to maintain an existing standard of living. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 8 - STATE ENTITIES Mississippi Department of Human Services • Division of Aging and Adult Services • Division of Family and Children’s Services • Division of Youth Services FUNDED SERVICES The social services funded are based on agency requests, service priorities and divided into the following broad services categories: SELF-SUFFICIENCY PROTECTION Adoption Protective Services, Child Residential Treatment Prevention of Abuse/Neglect Homemaker Emergency Shelter, Child Family Development Protective Services, Adult Interstate Services for Children Ombudsman Foster Care Residential Treatment Intensive Crisis Intervention Placement for Children Protective Services-Child Investigation Interstate Services Centralized Statewide Intake MAINTENANCE Homemaker/Home Health Aide Home Delivered Meals Day Care, Adult Respite Care Case Management - Aging & FCS Transportation Information and Referral Aging & Disability Resource Center Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 9 - ELIGIBILITY CRITERIA AND INCOME GUIDELINES (Page 1 of 2) The eligibility criteria for specific services to be provided with Social Services Block Grant (SSBG) funds are referenced in the service definitions. More detailed information is provided below. Eligibility is determined by agencies throughout the state. The Mississippi Department of Human Services is represented in all counties. The Division of Aging and Adult Services has ten Area Agencies on Aging representing all counties within the state. MDHS – DIVISION OF AGING AND ADULT SERVICES (DAAS) Services target Mississippians age 60 and older whose socio-economic, functional, and/or geographic isolation places him or her in a frail, vulnerable target level on the DAAS Client Screening Form. Adult Protective Services (APS) protects the rights of vulnerable adults who may be victims of abuse, neglect or exploitation as defined in Mississippi’s Vulnerable Adults Act. APS services are targeted to Mississippians age 18 and older who are reported as alleged victims of vulnerability. MDHS - DIVISION OF FAMILY AND CHILDREN’S SERVICES All services of the Division of Family and Children’s Services are provided without regard to income, and are based upon the individual’s “need” for the service, and on the individual’s inclusion as an eligible individual as defined by the Definition of Service. “Need” for a particular service implies that the provision of that service will assist the individual or members of his family to advance toward the achievement of one of the program goals. The worker assessment includes the determination of whether or not the individual requesting service is unable to provide the service for him/her and has no friends or relatives who are able and willing to provide this service for him/her. Without Regard to Income Some services may be provided on the basis of need alone. These services are Adoption, Case Management, Placement Services, and Prevention of Neglect/Abuse. Income Maintenance Status Individuals eligible under Income Maintenance Status include: 1. Recipients of TANF and persons whose needs are considered in determining the needs of TANF recipients. Children, on whose behalf adoption assistance Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 10 - ELIGIBILITY CRITERIA – (continued Page 2 of 2) under Title IV-E is paid, are considered to be eligible as if they were a TANF recipient. 2. Recipients of Supplemental Security Income Benefits or State Supplementary Payments. 3. Individuals other than those described above, whose income is at or below 200 percent of the poverty level income based on family size will be eligible for all services without a fee. MDHS - DIVISION OF YOUTH SERVICES Children, ages 7 through 17 and 11 months, whose behavior problems have brought them into Youth Court jurisdiction are eligible for services. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 11 - ADMINISTRATIVE AND PROGRAM OVERVIEW MDHS DIVISION OF AGING AND ADULT SERVICES PROPOSED SERVICES TO BE FUNDED • Adult Protective Services • Adult Day Care • Case Management • Home Delivered Meals • Homemaker/Home Health Aide • Information & Assistance (Prescription Assistance Program) • Ombudsman • Respite Care • Transportation The Older Americans Act of 1965, as amended (OAA), administered by the U. S. Department of Health and Human Services, Administration on Aging, under the direction of the Assistant Secretary for Aging, requires the Governor of the State of Mississippi to designate a single state agency to develop and administer a Pre-Expenditure Report on Aging. The Division of Aging and Adult Services under the umbrella of the Mississippi Department of Human Services has been designated by the Governor as that agency and is hereinafter referred to as the DAAS. GENERAL DESCRIPTION OVERVIEW OF THE AGING NETWORK The DAAS is the state entity designated by the Governor to receive and administer federal funds received through the Older Americans Act and other resources developed by the DAAS. Working with a network of local Area Agencies on Aging (AAAs) and local service organizations, DAAS plans and administers programs and services to improve the quality of life for all of Mississippi’s older citizens. As the official state office on aging, the DAAS works closely with a network of designated agencies within a planning and service area to ensure comprehensive activities, programs and services for older Mississippians are offered statewide. Additionally, the DAAS works with many other state agencies as well as with the private sector, to create recognition of the needs and interests of older adults and to develop new resources. The DAAS proactively carries out a wide range of functions related to advocacy, planning, coordination, interagency linkages, information sharing, brokering, monitoring, and evaluation. The DAAS pays special attention to those older adults who have the greatest social, economic, and health needs and to low income minority elders. The DAAS plans, coordinates and administers Aging programs, and provides leadership and guidance to the various agencies and organizations serving the elderly and allocates Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 12 - MDHS – DIVISION OF AGING AND ADULT SERVICES – (continued Page 2 of 6) federal and State funds designated to meet the needs of elderly Mississippians. The ten AAA’s are separate units of the private, nonprofit Planning and Development District organizations. METHOD OF ADMINISTRATION PROGRAM OPERATIONS RECIPIENTS, METHOD OF DELIVERY AND COUNTIES SERVED Adult Protective Services (APS) The APS protects the rights of vulnerable Adults age 18 and older who may be victims of abuse, neglect or exploitation as defined in Mississippi Vulnerable Adults Act. Reports are made from the general public or professionals mandated to report, and are investigated by the dedicated staff to resolve the alleged malfeasance and assist to correct the underlying problem. The APS program staff consists of family protection specialists in the field, social work supervisors, and state office administrators who are responsible for investigators statewide. APS services are targeted to Mississippians age 18 and older who are reported as alleged victims of vulnerability. Total Recipients: Method of Delivery: _X Direct ____ Purchase Counties Served: Statewide Unit of Service: One unit of service equates to one client’s case including: report intake, review, case staffing, investigation, travel, case documentation, collateral contact, resource development, tech assist, legal assistance: at approximately 11 hours per case. PROPOSED AWARD $1,000,000 Adult Day Care Provide safe, monitored care during the day for persons with serious health problems or impairments. Adult Day Care provides personal care supervision, congregate meals, limited health care, and the opportunity to interact socially with other people. Adult Day Care is essential in maintaining older adults with impairments in their own family setting. Adult Day Care program services are targeted to Mississippians age 60 and older whose socio-economic, functional, and/or geographic isolation places him/her at Level II or above on the screening instrument and who are in need of a sheltered community setting during some portion of the day. Total Recipients: Method of Delivery: ___ Direct _X__ Purchase Counties Served: Unit of Service: Participant’s attendance at the center for at least 4 hours but less than 24 hours PROPOSED AWARD $175,861 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 13 - MDHS – DIVISION OF AGING AND ADULT SERVICES – (continued Page 3 of 6) Case Management/Adults Case Management is the method by which services are coordinated and monitored for the frail elderly in an effort to provide continuity of care and avoid costly duplication of services. It is the key service in a complete system of community-based care. Such a system provides an alternative to costly nursing home placement by developing and effectively using support services in the community, both formal and informal, to enhance the independence of the individual. Case management services target Mississippians age 60 and older whose socio-economic, functional, and/or geographic isolation places him/her in a frail, vulnerable target level on the DAAS Client Screening Form. A case manager=s client load is limited to 60 clients. Total Recipients: Method of Delivery: __ Direct _X_ Purchase Counties Served: Statewide Unit of Service: 1 hour of service PROPOSED AWARD $257,101 Home Delivered Meals Five meals are delivered to the residence of a homebound older person each week. This program is the only statewide service of its kind. A well balanced diet is essential in maintaining overall health; the home delivered meals program is a vital component for seniors to receive the nutritional intake needed to maintain or improve their health status. Meals are planned and prepared to the older person=s dietary needs and meet the USDA dietary guidelines. The service is cost-effective due to the use of volunteers to deliver meals, commodity credit meal reimbursement, and the utilization of a statewide contractor. The additional benefits the homebound person receives from a meal delivery are: visitation, informal counseling, and a Agate-keeping@ activity (a friendly check to see that the meal recipient is well). Home Delivered Meal services are targeted to Mississippians age 60 and older whose socio-economic, functional, and/or geographic isolation places him/her in frail, vulnerable target level on the DAAS Client Screening Form. Priority is given to persons at risk of institutionalization. Total Recipients: 4,700 Method of Delivery: _ Direct _X_ Purchase Counties Served: Statewide Unit of Service: 1 home delivered meal PROPOSED AWARD $1,269,924 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 14 - MDHS – DIVISION OF AGING AND ADULT SERVICES – (continued Page 4 of 6) Homemaker/Health Services: Homemaker services are supportive services provided in the home of a frail older person by a trained homemaker. Homemakers assist the older person with tasks which facilitate independence and meet the older person=s goal of remaining at home as long as possible. Homemakers perform routine household tasks such as cooking, feeding, and monitoring nutritional intake, cleaning, mending, grocery shopping, laundry, and they assist with bathing, dressing; help with bathroom and general hygiene activities, oral hygiene assistance, and safety education. Ongoing Homemaker certification training is provided to enhance the capacity of homemakers to provide the highest quality service to frail elderly individuals. Homemaker program services are targeted to Mississippians age 60 and older whose socio-economic, functional, and/or geographic isolation places him/her in a Adependent/needing assistance with maintenance@ target level on the DAAS Client Screening Form. Total Recipients: 4,600 Method of Delivery: __ Direct _X_Purchase Counties Served: Statewide Unit of Service: 1 hour of service to, for, or on behalf of the client PROPOSED AWARD $2,143,304 Information & Assistance (Prescription Assistance Program) Information, Assistance and Referral is the service that provides valid and necessary current data and facts to senior individuals or those who inquire on their behalf, through a telephone call or personal visit, of available programs, resources, and/or services. Information services identify a senior individual=s needs and type of help and assistance required. Information services also include education and training events for workers who provide services for senior individuals and/or workers who provide assistance and referral to senior individuals. Assistance is the service that provides senior individuals or those acting on their behalf, with help obtaining the service or aid that is identified. Assistance is provided to help the senior or those acting on their behalf to realize the service determined to be in the senior’s best interest or desired by the senior. Assistance may include filling out forms, explaining instructions, conducting research on behalf of the senior, or other activities to assist the senior obtain the service needed. Referral is the service that provides contact for senior individuals or those who inquire on their behalf, with an agency and/or community resource to obtain help and assistance. After an assessment to ascertain a senior’s individual need, communication with the appropriate source of aid is made for the senior individual as needed and follow-up is practiced with the senior or those acting on their behalf, and/or the resource agency/service provider to determine whether the services were received. Information, Assistance, and Referral services are targeted to Mississippians age 60 and older. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 15 - MDHS – DIVISION OF AGING AND ADULT SERVICES – (continued page 5 of 6) Total Recipients: 6,727 Method of Delivery: __ Direct _X_ Purchase Counties Served: Statewide Unit of Service: 1 contact with a senior or on behalf of a senior PROPOSED AWARD $197,354 Ombudsman: Ombudsman provides a voice for residents. The Ombudsman serves as an advocate who supports resident’s highest possible quality of life and care, and is responsible for investigating and attempting to resolve concerns and complaints made by or on behalf of residents of long term facilities. Additionally, components of the Ombudsman service involve interpretation of resident’s rights, laws, policies and regulations, as well as monitoring and responding to local, state and federal legislation impacting LTC. Ombudsman program services are targeted to Mississippians age 60 and older who reside in or are potential residents of a LTC facility. Total Recipients: Method of Delivery: __ Direct _X_ Purchase Counties Served: Statewide Unit of Service: 1 hour of contact for activities related to client services, training, and program management. PROPOSED AWARD $109,559 Respite Care: This service provides temporary relief time for the regular or primary caregiver (spouse, child, relative) of an ill, frail, functionally-impaired older individual requiring constant in-home care. Respite care is provided by placing personnel in a client=s home. Institutional respite is provided by bringing the client to a day care facility or by short term admission to a licensed board and care home, foster care, nursing home or hospital. Respite care may provide one or more primary activities – dressing, bathing, eating or general supervision. Respite program services are targeted to caregivers of Mississippians age 60 and older who are homebound and have functional impairments. Priority is given to the frail older individual whose caregivers have a need for the service. Total Recipients: Method of Delivery: ____ Direct _X_ Purchase Counties Served: Statewide Unit of Service: 1 hour of service to relieve the caretaker PROPOSED AWARD $60,712 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 16 - MDHS – DIVISION OF AGING AND ADULT SERVICES (continued page 6 of 6) Transportation: This service provides transportation of eligible individuals 60 years of age and older to and from various community resources for the purpose of obtaining needed services. Transportation is provided to eligible older persons for medical and/or dental treatment, social service and other related agencies/functions, personal care needs, adult foster care, adult day care, and other applicable services based on need. Currently, the transportation system is operated at the local level through contracts with public and private service providers, with funds from local sources, Title III, SSBG, and the Department of Transportation, Division of Public Transit. Transportation program services are targeted to Mississippians age 60 and older whose socio-economic, functional, and/or geographic isolation places him/her in at Level 1 or above on the DAAS Client Screening Form. Total Recipients: 1,248 Method of Delivery: Direct _X_ Purchase Counties Served: Statewide Unit of Service: 1 one-way trip PROPOSED AWARD $758,547 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 17 - MDHS- DIVISION OF FAMILY & CHILDREN’S SERVICES PROPOSED SERVICES TO BE FUNDED THROUGH SSBG/TANF • Adoption • Case Management • Interstate Compact Placement • Placement Services • Prevention • Protection Services • Investigations • Special Investigations • Mississippi Central Intake • Program Support • Support Services GENERAL DESCRIPTION OVERVIEW OF FAMILY & CHILDREN’S SERVICES NETWORK The Mississippi Department of Human Services (MDHS), Division of Family and Children’s Services (DFCS) is a state-administered child welfare system. This system is administered at the local level by 84 county offices through thirteen Regional Directors. This agency is authorized by state statute to promulgate regulations, policies and procedures necessary to implement the state’s child welfare system and to ensure the safety, permanency, and well-being for Mississippi’s families and children. PROGRAM OPERATIONS RECIPIENTS, METHOD OF DELIVERY AND COUNTIES SERVED SOCIAL WORKER PROVIDER SERVICES ADOPTION – A direct service provided to enable children and youth who cannot remain with their families to be adopted by individuals or families through a formal legal process. Total Recipients: 1,116 Method of Delivery: _X Direct __ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG - $ 435,829 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 18 - MDHS – DIVISION OF FAMILY AND CHILDREN’S SERVICES (continued page 2 of 5) CASE MANAGEMENT – Supportive casework provided directly by the agency to assist individuals and families in assessing the needs and identifying strengths and weaknesses; to develop a specific plan to address needs, goals, and objectives; to provide and assure connection with needed services, to monitor and evaluate progress toward meeting goals and objectives; and to intercede as necessary to assure quality of life and provision of needed services to individuals and families. Total Recipients: 3,336 Method of Delivery: _X Direct ___ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: TANF - $844,036 INTERSTATE COMPACT PLACEMENT – A direct service by social services staff which encompasses both the Interstate Compact on the Placement of children (ICPC) and the Interstate Compact on juveniles; this includes runaways. The services are mandated by the State of Mississippi. It provides out-of-state placement and supervision of dependent children. Its major purpose is to protect children from being placed in dangerous or inadequate situations across state lines. Total Recipients: Method of Delivery: _X Direct __ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG - $205,096 PLACEMENT – The neglected, abused or exploited children placed by court order or by voluntary consent of the parents necessitate direct service activities on the part of the agency staff to provide placement services. The Mississippi Legislature and United States Congress have mandated this service be provided. No foster child is placed in a foster care setting that has not been licensed or approved as meeting DFCS licensure standards, unless the child is placed pursuant to the relative licensing process which can be either an emergency process that enables a child to be placed with relatives as soon as the child enters placement, following an initial screen of the relative’s home or a full licensing process, completed no later than 90 calendar days after the child has entered placement. Total Recipients: 2,280 Method of Delivery: _X Direct __ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG – $897,295 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 19 - MDHS – DIVISION OF FAMILY AND CHILDREN’S SERVICES (continued page 3 of 5) PREVENTION/INTERVENTION – Provided as a direct service by social services staff within DFCS. Prevention and intervention services are those services or activities designed to provide early identification and/or timely intervention to support families and prevent and improve the consequences of abuse, neglect, or family violence, or to assist in making arrangement for alternate placements or living arrangements where necessary. Such services may also be provided to prevent the removal of a child from the home. Component services and activities may include investigation; assessment and/or evaluation of the extent of the problem; counseling, including mental health counseling or therapy as needed; developmental and parenting skills training; respite care; and other services including supervision, case management and transportation. Total Recipients: Method of Delivery: _X Direct __ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG – $282,007 PROTECTION – A direct service provided by DFCS social services staff designed to prevent or remedy abuse, neglect, or exploitation of children who may be harmed through physical or mental injury, sexual abuse or exploitation, and negligent treatment or maltreatment, including failure to be provided with adequate food, clothing, shelter, or medical care. Component services or activities may include immediate investigation and intervention; emergency medical services; emergency shelter; developing case plans; initiation of legal action; counseling for the child and the family; assessment/evaluation of family circumstances; arranging alternative living arrangement; preparing for foster placement, if needed; and case management and referral to service providers. Total Recipients: 1,848 Method of Delivery: _X Direct ___ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG – $743,473 PROTECTIVE SERVICES/INVESTIGATIONS – A direct service provided by DFCS staff. When the intake supervisor receives an intake and screening from Mississippi Central Intake Program (MCIP) that indicates a child is in imminent danger, the Intake Supervisor will assign a worker for immediate response. Prior to initiating the investigation, the worker should conduct an additional thorough review of any prior DFCS involvement with the family. An investigation is considered Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 20 - MDHS – DIVISION OF FAMILY AND CHILDREN’s SERVICES (continued page 4 of 5) initiated when face-to-face or attempted contact is made with the alleged victim(s) and should occur within the timeframes required by the level of the report. Total Recipients: 24,660 Method of Delivery: _X Direct __ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: TANF – $6,189,496 SPECIAL INVESTIGATION-The standard investigative/assessment protocol applies to all DFCS investigations with additional requirements that apply to special handling DFCS investigations/assessments. Special handlings are reports on resource homes, licensed facilities and DFCS employees. Total Recipients: Method of Delivery: _X Direct __ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: TANF – $946,026 MISSISSIPPI CENTRAL INTAKE PROGRAM – DFCS has contracted with Social Work p.r.n., independent contractor, to provide consistent measurable services for the MDHS Centralized Intake, 24-Hour, seven days per week Hotline and Disaster Preparedness Plan Services by operating a local call center in Jackson, Mississippi. The call center is adequately staffed 24 hours/day, 7 days/week, to include weekends, holidays and any other official office closing. This program is required by the terms of the Olivia Y. Settlement Agreement and Reform Plan. Social Work p.r.n. is required to have social workers answering the calls that are received in the call center. Calls Received: 29,676 Method of Delivery: _ Direct X_ Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG - $2,000,000 PROGRAM SUPPORT – Program support staff is responsible for providing administrative support and coordinating the fiscal, contractual, and regulatory activities of programs. Additionally, Program Support staff assists with long and short Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 21 - MDHS–DIVISION OF FAMILY AND CHILDREN’s SERVICES (continued page 5 of 5) range planning, and with fiscal projections and analysis. Also, develop timelines to monitor workflow, maintain accurate records of follow-up procedures and activities for all on-going administrative functions. Program Support staff keeps abreast of all pertinent Federal and State regulations, laws, and policies as they exist, change or are modified. Method of Delivery: _ X Indirect __ Purchase Counties Served: Statewide PROPOSED AWARD: TANF - $47,200 SUPPORT SERVICES- Support Services are those services needed, in addition to the worker direct service, which will aid the client in removing barriers to attaining their goals, such as support services needed to aid in the prevention of neglect/abuse. Total Recipients: 10,835 Method of Delivery: _ Direct X Purchase Counties Served: Statewide Unit of Service: 1 provided per client PROPOSED AWARD: SSBG- $235,726 TANF-$650,000 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 22 - MDHS- DIVISION OF YOUTH SERVICES PROPOSED SERVICE TO BE FUNDED Special Services for Youth Involved In At Risk Behavior or At Risk of Involvement with Criminal Activity. GENERAL DESCRIPTION OVERVIEW OF THE YOUTH SERVICES NETWORK The mission of the Department of Human Services is to provide services for people in need by optimizing all available resources to sustain the family unit and to encourage traditional family values thereby promoting self-sufficiency and personal responsibility for all Mississippians. Area – The Division of Youth Services’ Community Services Program has Youth Services Counselors assigned to each youth court in the state, which provide counseling and case management services for troubled children and their families. Additional duties include probation and parole supervision, collection of case information and related casework duties, and data collection. The Social Services Block Grant funds are used in the Youth Services Community Services component of the Division of Youth Services. METHOD OF ADMINISTRATION The Division of Youth Services provides supervision and evaluation through the implementation of policy and procedures ensuring that federal and state regulations are followed and funds are spent appropriately and effectively. PROGRAM OPERATIONS RECIPIENTS, METHOD OF DELIVERY AND COUNTIES SERVED The Division of Youth Services (DYS) currently provides special services such as counseling, day treatment, etc. for youth involved in or at risk of involvement with criminal activity. Components services or activities are designed to enhance family functioning and/or modify the youth’s behavior with the goal of developing socially appropriate behavior. Counseling, intervention therapy, and residential services are an integral but subordinate part of the service. Total Recipients: 12,000 Method of Delivery: __X__Direct ____ Purchase Counties: Hinds, Rankin, Desoto, Harrison, Lauderdale Units of Services: Supervision by Division of Youth Services Counselor per recipient PROPOSED AWARD $624,199 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 23 - MDHS- DIVISION OF YOUTH SERVICES (continued page 2 of 2) Electronic Monitoring and Supervision Program The overarching goal of the DYS, Electronic Monitoring and Supervision Services is to offer electronic monitoring and community based supervision to assist in the supervision and rehabilitation of juveniles released back into the community. The Division shall utilize a system that offers different levels of monitoring. The electronic monitoring and community based supervision initiative will assist both the supervision and the rehabilitative process of youthful offenders who are high risk and low risk between the ages of thirteen (13) to seventeen (17) on juvenile probation that require electronic monitoring services. The anticipated number of offenders to be monitored/tracked may range from one (1) to eighteen (18) clients on a continuous basis. Total Recipients: Method of Delivery: ______Direct __X__ Purchase Counties: Hinds, Pearl River, DeSoto, Harrison, Jackson, Lafayette, Jasper, Grenada, Coahoma, and Washington Units of Service: 1 bracelet per recipient for 45 days PROPOSED AWARD $500,000.00 Individualized Assessment and Comprehensive Community Intervention Initiative (IACCII), Tony Gobar The IACCII is to provide comprehensive strength-based needs assessments, individualized service plans and community-based services for eligible (low-risk, low- need/high need) youth who would otherwise be committed to training school. The specific target population for this initiative is: youthful offenders ten (10) through seventeen (17) years of age who possess high risk of returning or becoming further involved in the juvenile justice system. The IACCII ensures that youth and their families can access necessary services available in their home community. Total Recipients: Method of Delivery: ______Direct __X__ Purchase Counties: Quitman Units of Service: 2.5 hours a day 5 days a week for 52 weeks for 25 youths PROPOSED AWARD $100,000.00 Evening Reporting Center The Adolescent Evening Reporting Center(AERC) shall offer group activities during high risk time periods for adjudicated delinquent and pre-adjudicated youth ages fourteen (14) to eighteen (18) years of age, who are at a high risk of becoming further involved in the Juvenile Justice System by offering rehabilitative theories and practices while ensuring the safety of the community and juvenile. In addition, AERC shall manage and facilitate both the supervision and the rehabilitative process of youthful offenders. Total Recipients: Method of Delivery: ______Direct __X__ Purchase Counties: Coahoma, Hinds, Madison Units of Service: 4 hours a day 5 days a week for 52 weeks for 135 youths PROPOSED AWARD $750,000.00 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 24 - FISCAL OPERATIONS • Social Services eligible for funding are divided into three categories. • All state agency contractors will be required to comply with administrative and fiscal procedures as established by the Mississippi Department of Human Services. • The Mississippi Department of Human Services will maintain a uniform, coordinated management system, including uniform reporting procedures, fiscal management procedures, evaluation process, and an administrative cap for all contractors. • A 25 percent (25%) match will be required of all Social Services Block Grant state agency contractors, unless waived by the Executive Director. INCOME LIMIT FOR USE OF TRANSFERRED FUNDS Section 404(d) (3) (B) of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 requires that all TANF amounts that are used to carry out state programs pursuant to Title XX shall be used only for programs and services to children or their families whose income is less than 200 percent of the income official poverty line, applicable to a family of the size involved. EXPENDITURE PERIOD Funds transferred into SSBG from TANF pursuant to Section 404 (d) (3) (A) of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA) shall not be subject to the requirements of TANF [except as required under 404(d) (3) (B)], but are subject to the rules and regulations pertaining to the SSBG program corresponding to the fiscal year when the funds are transferred. The transferred funds and regular SSBG funds granted the state during a fiscal year are subject to the two-year timely filling provisions contained in 45 CFR Part 95.1. SUBMISSION OF PROPOSALS AND DETERMINATION OF ALLOCATIONS • Proposals for FFY 2016 were accepted for revisions until July 31, 2015. Proposed Awards will be set no later than August 31, 2015. • Proposals will adhere to the uniform format as revised by Social Services Block Grant. • All proposals will be evaluated based on merit and past expenditures. • Carryover dollars will be used to maintain services currently funded through MDHS. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 25 - • The amount of administrative costs charged to the Social Services Block Grant will not exceed 10 percent (10%) of a state agency’s program costs. Administrative expenditures will be reported by source. The definition of actual administrative costs will be: All costs necessary for general administration of and associated with program activity. Only those administrative and planning expenditures expected to be incurred for overall program management, coordination, monitoring, and evaluation may be included. Administrative and planning costs associated with the personnel devoting effort to a specific work activity may not be included. Such costs will be budgeted within that specific program activity. Administrative and planning costs are limited to ten percent (10%) of the award, without flexibility. Grantor approval is required for any increase in administrative costs. The more prevalent administrative and planning costs include, but are not limited to, those described below: a. Salary and fringe benefits of personnel involved in overall program management, coordination, monitoring, and evaluation. It does not include the salary and fringe benefits of personnel devoting efforts to a specific activity. b. Consumable supplies necessary to support general administrative activities such as paper, file folders, accounting work papers, etc. c. Travel of staff conducted for the benefit of the program, including local mileage to be reimbursed at the rate not to exceed the amount set at the federal level. All other travel costs will be eligible in accordance with existing regulations of the grantor. d. Rentals, such as office space and office furniture. Equipment rental is not included in this cost category. e. Equipment purchase, lease, and/or rental. An allocation plan should be developed for equipment shared with other activities. Equipment service agreements are to be listed in the ‘contractual services’ cost category. f. Contractual services such as postage, telephone, printing, consultants, and equipment service contracts, etc. g. Allocation of cost is charged in accordance with contracting agency’s approved cost allocation plan or indirect cost rate, as applicable. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 26 - • State agency contractors will employ such reporting and evaluation tools as necessary to assure accountability of subcontractors. • Performance criteria and indicators will be established by the state agency contractors for the selection and evaluation of subcontractors. • At the final closeout of the grant, unexpended funds will be returned to MDHS for reallocation. However, a state agency contractor may petition to retain these funds if it can be shown to be cost effective. • The MDHS requires an audit for all of its subcontractors, in accordance with the Single Audit Act of 1996. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 27 - PROPOSED BUDGET INFORMATION The State of Mississippi anticipates receiving a final award of $14,827,833.00 in Social Services Block Grant (SSBG) funds for Fiscal Year 2016. Funds were divided among the following agencies: AGENCY MDHS-Division of Aging and Adult Services ...................................................................$5,972,362 MDHS-Division of Family and Children’s Services ..........................................................$4,799,426 MDHS-Division of Youth Services ....................................................................................$1,974,199 TOTAL SERVICE DOLLARS .....................................................................................$12,745,987 Administration Fees: Department of Human Services Administration ...................................................................$497,350 MDHS-Division of Aging and Adult Services ..................................................................$848,051 MDHS-Division of Youth Services .......................................………………………………$6,000 TOTAL ADMINISTRATION DOLLARS .................................................................................. $1,351,401 *UNOBLIGATED FUNDS…………………………………..…………………………………….………$730,445 TOTAL SSBG FUNDS ................................................................................................................ $14,827,833 TOTAL TANF TRANSFER .................................................................................................. … $8,676,758 Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 28 - DOCUMENTATION OF PRE-EXPENDITURE REPORT REVIEW Single Audit Information Service dated November 1990, under Section D. Special Reporting Requirements, page 310, tab 1100, provides an opportunity for public comments to be offered before the Pre-Expenditure Report, or a DESCRIPTION of the intended uses of the Social Services Block Grant funds, would be considered complete. The regulations also provide that the manner in which a state obtains public comments are at the state’s discretion as long as statutory requirements are met. The State of Mississippi allows public comment in accordance with Miss. Code Annotated 25-43- 3.103. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 29 - AUDITS & REPORTING The Mississippi Department of Human Services (MDHS), Division of Budgets and Accounting (DBA), has the responsibility for ensuring audit coverage of all funds administered by the Social Services Block Grant (SSBG). The SSBG will be audited in accordance with the Single Audit Act of 1996. Under this Act the recipients of SSBG funds will be audited by the State Auditor or by a CPA firm selected by the State Auditor. MDHS will ensure the audit is in compliance with the federal regulations and will be based on the State Fiscal Year ending June 30, conforming to the following guidelines: 1. Generally Accepted Auditing Standards as set forth by the American Institute of Certified Public Accountants (AICPA). 2. The General Accounting Office (GAO) ‘Government Auditing Standards’, 1988 (the Yellow Book). 3. Specific grant compliance requirements contained in the OMB Circular A-133 Compliance Supplement issued by the Office of Management and Budget. 4. The provision of the Single Audit Act of 1996 and the provision of U.S. Office of Management and Budget (OMB) Circular A-122, Audits of State and Local Government. REPORTING As directed by the U. S. Department of Health and Human Services, the annual post expenditure report on activities conducted under the Social Services Block Grant during FFY 2015 will be submitted in March of 2016. All financial information is maintained by the Division of Budgets and Accounting within the Mississippi Department of Human Services. Final costs for the Annual Report of Services beginning October 1 through September 30 of each year will be submitted in a timely manner in a format acceptable to the U.S. Department of Health and Human Services. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 30 - STANDARD ASSURANCES AND CERTIFICATIONS OVERVIEW Each sub grantee and any lower-tier sub recipient must assure that it will comply with the regulations, policies, guidelines, and requirements imposed by the federal grantor agency and MDHS. The MDHS sub grantee must also ensure that any lower-tier sub grants it issues through funds received from MDHS will require the lower-tier sub recipient to comply with these same regulations. The assurances listed in this section may not be applicable to a particular project or program, and there may be additional assurances required by certain federal awarding agencies. In addition, each sub grantee must certify in writing that it will comply with the following regulations: • Lobbying • Suspension and Debarment • Drug-Free Workplace • Unresolved Monitoring and Audit Findings • Fidelity Bond Coverage STANDARD ASSURANCES The sub grantee assures that it: 1. Has the legal authority to apply for and receive the sub grant; that a resolution, motion, or similar action has been duly adopted or passed as an official act of the sub grantee’s governing body, authorizing the sub grant, including all understandings and assurances contained therein, and directing and authorizing the person identified as the official representative of the sub grantee to act in connection with the sub grant and to provide such additional information as may be required. 2. Will give MDHS, the State Auditor's Office, the federal grantor agency, and the Comptroller General, or any of their authorized representatives, access to and the right to examine all records, books, papers, documents, or items related to the sub grant. 3. Will establish and maintain both fiscal and program controls and accounting procedures in accordance with generally accepted accounting principles and federal grantor agency and MDHS directives; and will keep and maintain such books and records for audit by MDHS, by the federal grantor agency, by the State Auditor, or by their authorized representatives; and will maintain all such records, books, papers, documents, or items for a period of at least three (3) years from the date of submission of the final reporting worksheet, or, if any litigation, claim, audit, or action has begun before the expiration of the three-year period, will retain all such items until the completion of the action and resolution of all Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 31 - STANDARD ASSURANCES AND CERTIFICATIONS – (continued page 2 of 4) issues involved or until the end of the regular three-year period, whichever is later. 4. Will comply with the Single Audit Act Amendments of 1996. 5. Will establish safeguards to prohibit employees from using their positions for a purpose that constitutes, or presents the appearance of, personal or organizational conflict of interest, or personal gain. 6. Will comply with all federal & state statutes relating to discrimination, including, but not limited to: • Title VI of the Civil Rights Act of 1964, prohibiting discrimination on the basis of race, color, or national origin; • Title VII of the Civil Rights Act of 1964, relating to non-discrimination in matters of recruitment, hiring, promotion, and other employment practices; • Title VIII of the Civil Rights Act of 1968, as amended, relating to non- discrimination in the sale, rental, or financing of housing; • Title IX of the Education Amendments of 1972, as amended, prohibiting discrimination on the basis of sex in federally assisted education programs and activities; • The Age Discrimination Act of 1975, prohibiting discrimination on the basis of age; • Section 504 of the Rehabilitation Act of 1973, prohibiting discrimination on the basis of handicaps; • Subtitle A, Title II of the Americans with Disabilities Act (ADA) (1990); • The Omnibus Reconciliation Act of 1981, prohibiting discrimination on the basis of race, color, religion, sex, national origin, age, and handicap; • The Drug Abuse Office and Treatment Act of 1972, as amended, relating to non-discrimination on the basis of drug abuse; • The Comprehensive Alcohol Abuse and Alcoholism Prevention, Treatment, and Rehabilitation Act of 1970, as amended, relating to non-discrimination on the basis of alcohol abuse or alcoholism; and, Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 32 - STANDARD ASSURANCES AND CERTIFICATIONS – (continued page 3 of 4) • Sections 523 and 527 of the Public Health Service Act of 1912, as amended, relating to confidentiality of alcohol and drug abuse patient records; and any other non-discrimination provisions in the specific statute(s) under which these monies will be granted or awarded and the requirements of any other non-discrimination statute(s) which may apply to this sub grant or award. 7. Will ensure that buildings and facilities owned, occupied, or financed by the US Government are accessible to and usable by physically handicapped persons in accordance with the Architectural Barriers Act of 1968. 8. Will comply with the requirements of the provisions of the Uniform Relocation Assistance and Real Property Acquisition Act of 1970, which provide for fair and equitable treatment of persons displaced or whose property is acquired as a result of federal and federally assisted programs. These provisions apply to all interests in real property acquired or project purposes regardless of federal participation in purchases. 9. Will comply with the provisions of the Hatch Act as amended, which limit the political activities of employees whose principal employment activities are funded in whole or in part with federal funds. 10. Will comply, as applicable, with the provisions of the Davis-Bacon Act, the Copeland Act, and the Contract Work Hours and Safety Standards Act, regarding labor standards for federally assisted construction sub agreements. 11. Will conform with Executive Order (EO) 11246, entitled "Equal Employment Opportunity," as amended by EO 11375, and as supplemented in Department of Labor regulations (41 CFR Part 60) and will incorporate an equal opportunity clause in federally assisted construction contracts and subcontracts. 12. Will comply with the minimum wage and maximum hour provision of the Federal Fair Labor Standards Act. 13. Will comply with the Intergovernmental Personnel Act of 1970 relating to prescribed standards for merit systems for programs funded under one of the 19 statutes or regulations specified in Appendix A of OPM's Standards for a Merit System of Personnel Administration. 14. Will comply, if applicable, with Section 102(a) of the Flood Disaster Protection Act of 1973, which requires recipients in a special flood hazard area to participate in the program and to purchase flood insurance if the total cost of insurable construction and acquisition is $10,000 or more. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 33 - STANDARD ASSURANCES AND CERTIFICATIONS – (continued page 4 of 4) 15. Will comply with the Lead-Based Paint Poisoning Prevention Act, which prohibits the use of lead-based paint in construction or rehabilitation of residence structures. 16. Will assist the federal grantor agency in assuring compliance with Section 106 of the National Historic Preservation Act of 1966, as amended; EO 11593; and the Archaeological and Historic Preservation Act of 1974. 17. Will comply with environmental standards which may be prescribed pursuant to the following: (a) institution of environmental quality control measures under the National Environmental Policy Act of 1969 and EO 11514; (b) notification of violating facilities pursuant to EO 11738; (c) protection of wetlands pursuant to EO 11990; (d) evaluation of flood hazards in flood plains in accordance with EO 11988; (e) assurance of project consistency with the approved State management program developed under the Coastal Zone Management Act of 1972; (f) conformity of federal actions to State (Clean Air) Implementation Plans under Section 176 of the Clean Air Act of 1955, as amended; (g) protection of underground sources of drinking water under the Safe Drinking Water Act of 1974, as amended; (h) protection of endangered species under the Endangered Species Act of 1973, as amended; (I) Section 6002 of the Resource Conservation and Recovery Act; and (j) the Coastal Barriers Resources Act. 18. Will assure all funds received shall be used only to supplement services and activities that promote the purpose for which the grant is awarded, and not supplant, unless specifically authorized by the program regulations and the appropriate MDHS Division. 19. Will provide certification regarding lobbying to comply with Section 319, PL 101- 121 (31 USC 1352). 20. Will provide the required certification regarding their exclusion status and that of their principals prior to the award in accordance with EOs 12549 and 12689 Debarment and Suspension. 21. Will provide certification to comply with the Drug-Free Workplace Act of 1988. Form enclosed on page 32. 22. Will comply with all applicable requirements of all other Federal and State Laws, Executive Orders, regulations, and policies governing the program(s) for which these monies are provided and with the terms and conditions of the Sub grant Agreement. Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 34 - CERTIFICATIONS FORM FOR DRUG-FREE WORKPLACE The sub grantee may insert in the space provided below the site(s) for the performance of work done in connection with the specific sub grant. Check __X___ if there are workplaces on file that are not identified here: Place of Performance (street address, city, county, state, zip code) 750 North State Street____________________ Jackson, MS 39202_____Hinds County_______ DRUG-FREE WORKPLACE (SUBGRANTEES WHO ARE INDIVIDUALS) As required by the Drug-Free Workplace Act of 1988 - A. As a condition of the sub grant. I certify that I will not engage in the unlawful manufacture, distribution, dispensing, possession, or use of a controlled substance in conducting any activity with the sub grant; and, B. If convicted of a criminal drug offense resulting from a violation occurring during the conduct of any sub grant activity, I will report the conviction, in writing, within 10 calendar days of the conviction, to MDHS. As duly authorized representative of the sub grantee, I hereby certify that the sub grantee will comply with the above certifications. SUBGRANTEE NAME AND ADDRESS: Mississippi Department of Human Services 750 North State Street, Jackson, MS 39202 TYPED NAME AND TITLE OF AUTHORIZED REPRESENTATIVE: Leigh Washington, Director, Office of Social Services Block Grant SIGNATURE AND DATE: ____________________________________________ Social Services Block Grant August, 2015 FY 2016 Pre-Expenditure Report - 35 - COMMENTS See attached 1. Attachment 1 - Public Notice for FFY 2015 2. Attachment 2 3. Attachment 3 - Comments