Finding Number 2025-215: The Department did not meet the Mental Health Block Grant (MHBG) earmarking requirement for evidence-based programs addressing early serious mental illness. Federal Program: 93.958 - Block Grants for Community Mental Health Services Related to Prior Finding: N/A Agency’s vie...
Finding Number 2025-215: The Department did not meet the Mental Health Block Grant (MHBG) earmarking requirement for evidence-based programs addressing early serious mental illness. Federal Program: 93.958 - Block Grants for Community Mental Health Services Related to Prior Finding: N/A Agency’s view: The Idaho Department of Health and Welfare (DHW) agrees with the finding. DHW consulted with the Substance Abuse and Mental Health Services Administration (SAMHSA) Grants Project Officer (GPO) regarding the Early Serious Mental Illness (ESMI) earmarking requirement, including how the requirement is calculated, the flexibility available for meeting the requirement, and the potential impact on future Mental Health Block Grant (MHBG) funding. The GPO confirmed that the standard requirement is to expend not less than 10% of the MHBG award on evidence-based programs addressing ESMI. The GPO also confirmed that a State may elect the two-year option to expend not less than 20% of the ESMI set-aside by the end of the succeeding fiscal year. For Idaho's current grant period, this provides additional time to meet the expenditure requirement through qualifying ESMI activities. SAMHSA GPO Guidance The GPO further stated that if Idaho appropriately elects and documents the 20% two-year option, SAMHSA would not expect a penalty or negative impact on future MHBG funding. If the expenditure requirement is not met, unexpended ESMI set-aside funds cannot be drawn down and would revert to the Treasury. If ESMI set-aside funds are spent on non-ESMI activities, the amount used for those expenditures would need to be returned. This repayment requirement would not apply to other MHBG funds that were properly spent on allowable activities outside of the ESMI set-aside. The GPO also clarified that there is no separate waiver or exception process for the ESMI expenditure requirement beyond the 20% two-year flexibility. SAMHSA's MHBG closeout team will provide additional guidance regarding documentation expected at closeout to support use of the two-year flexibility. The GPO also clarified that no-cost extensions are not currently an option for the MHBG grant. The 10% ESMI earmark is calculated based on the total MHBG award amount for the grant period, not the amount drawn down or spent to date. Prior Monitoring Process DHW has historically used grant budget papers, LUMA financial system expenditure information, and spreadsheets to track ESMI expenditures; however, prior processes did not provide sufficient controls to ensure the required earmark was met. LUMA expenditure reporting and data processes have since been improved and are now used as part of the monitoring process. Improvements Already Implemented DHW has already taken steps to strengthen the monitoring of MHBG and ESMI expenditures. The MHBG team is developing an MHBG expenditure tracking tool to monitor expenditures at the program level and the amount needed to meet the ESMI earmark. The MHBG team also reviews LUMA expenditure data to monitor spending, identify issues or discrepancies, and determine whether additional follow-up is needed. The Finance and Budget Unit (FABU) updates the LUMA Data tab in the Realignment Project spreadsheet, and Grant Reporting posts the MHBG workpapers for review. The MHBG team reviews the expenditure information and MHBG workpapers and compares ESMI expenditures to the required earmark. The MHBG team also meets quarterly with internal partners to review MHBG grant activities, expenditures, reporting, progress made, and any challenges or concerns. These meetings provide an opportunity to discuss how the grant is progressing, identify potential issues, and determine whether additional follow-up is needed. For MHBG funding, the MHBG Team has implemented an annual Internal Funding Request process to provide a consistent process for requesting, reviewing, approving, and tracking MHBG funding. These improvements will be incorporated into the formal monitoring process outlined below and will continue throughout the grant period. Corrective Action: Idaho Department of Health and Welfare (DHW) will implement a formal process to monitor compliance with the Mental Health Block Grant (MHBG) 10% Early Serious Mental Illness (ESMI) earmarking requirement throughout each grant period. The Adult Mental Health (AMH) Program Manager will oversee implementation of the monitoring process, with review and oversight by the System Design and Implementation Bureau–Adult Behavioral Health (SDI-ABH) Chief and System Design and Implementation Programs Bureau Chief. The MHBG team, ESMI team, Grant Reporting, and Finance and Budget Unit (FABU) will each have defined responsibilities within the monitoring process. The corrective action will include the following steps: 1. Establish an ESMI expenditure tracking process. The MHBG team will develop and maintain an MHBG expenditure tracking tool to identify and track qualifying ESMI expenditures at the program level and compare the expenditure information to the required 10% earmark for the MHBG grant. FABU will maintain the expenditure information in the Realignment Project spreadsheet, and Grant Reporting will provide the MHBG workpapers through its established process. 2. Calculate the required earmark amount. At the beginning of each grant period, the MHBG team will calculate and document the amount required to meet the 10% ESMI earmark and the timeframe for meeting the requirement before the end of the grant period. 3. Monitor ESMI expenditures quarterly. FABU will provide the ESMI personnel costs monthly and continue to update the LUMA Data tab in the Realignment Project with the expenditure information. Grant Reporting will post the MHBG workpapers. The ESMI team will manage the ESMI contracts, provide support to ESMI providers, and review and process ESMI invoices to ensure providers are submitting invoices in accordance with their contracts. The MHBG team will review the workpapers and expenditure information for accuracy, compare the program-level expenditure tracking to the information provided in the grant workpapers, and compare actual ESMI expenditures to the required 10% earmark. The MHBG team will follow the established workpaper review and approval process. 4. Review expenditure status and address potential shortfalls. The MHBG team will review the quarterly expenditure information to identify potential shortfalls and determine whether additional qualifying ESMI expenditures may be needed to meet the 10% ESMI earmark. If a potential shortfall is identified, the MHBG team will work with internal partners and look for additional qualifying ESMI activities, including opportunities with other providers or programs, to address the shortfall and meet the set-aside requirement before the end of the grant period. FABU and Grant Reporting will complete their respective reviews as part of their established processes. The MHBG team will reach out to FABU or Grant Reporting as needed when questions, discrepancies, or clarification are identified. The AMH Program Manager will oversee this process and provide updates to the SDI-ABH Behavioral Health Chief and System Design and Implementation Programs Bureau Chief as needed. 5. Maintain supporting documentation. The MHBG team will maintain documentation supporting the ESMI expenditure monitoring process, including the expenditure tracking, quarterly reviews, required 10% earmark calculations, MHBG grant workpapers reviewed, the timeframe for meeting the requirement, and any identified discrepancies or corrective actions. Documentation will be maintained in the appropriate grant files in accordance with DHW record retention requirements. 6. Complete the grant closure review. FABU will initiate the established grant closure process approximately two months prior to the closure of each grant phase. During Stage 1, the grant will be reviewed to identify the areas and parties that need to be involved in the closure process. During Stage 2, Grant Reporting, Cash Management, and other identified parties will participate in the closure review. The MHBG team will participate in the closure process and review the ESMI expenditures and documentation to verify that the required 10% earmark has been met. Any questions or discrepancies identified during the closure process will be addressed with the appropriate parties. The results of the review will be documented and maintained with the grant records. Anticipated Corrective Action Date: September 30, 2027 Responsible for Corrective Action: Scott Rasmussen, SDI Programs Bureau Chief Scott.Rasmussen@dhw.idaho.gov (208) 334-5500