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IMPLEMENTATION OF THE STATE

LEGALIZATION IMPACT ASSISTANCE

UNDER THE IMMIGRATION 
GRANTS 
REFORM AND CONTROL ACT OF 1986 
STA TE OF CALIFORNIA 
OFFICE OF INSPECTOR GENERAL 
OFFICE OF ANALYSIS AND INSPECTIONS 
DECEMBER 1989  :_- . .,_. ""--",.. ..__._---- -. '--- -------'-------._ _.. - ---- --------.--.- ---- - - .. 
OFFICE OF INSPECTOR GENERAL

The mission of the Offce of Inspetor Gener (OIG) is to promote the effciency, effective
progr 
ness, and integrty of  in the United States Deparent of Health and Human Ser
vices (HS). It does ths by developing method to detet and prevent fraud, waste, and 
abuse. Crate by statute in 1976, the Inspeto Genera keeps both the Seceta and the Con
progr 
curently inormed about  or maagement problems and recommends 
grss fuy and 
corctive action. The OIG perform its  y conducting audits, investigations, and in
mission 
sta 
sptions with approxiately 1,300  strategicaly located arund the countr. 
AND INSPECTIONS

OFFICE OF ANALYSIS 

Ths report is prouced by the Offce of Analysis and Inspections (OAI), one of the thee 
major offces with the OIG. The other two ar the Ofce of Audit and the Offce of Inves
stada 
tigations. Inspections ar conducted in accordace with professional  developed by 
OAI. These inspections ar tyicaly short-term studies designed to determe program effec
tiveness, effciency, and vuerabilty to frud or abuse. 
Th study was conducted to determe the effectiveness of Caorna s implementation of 
State Legalzation Impact Assistace Grts fuds awar under the Imgrtion Reform 
and Control Act of 1986.

The report was prepar under the dition of Don McLaughlin, the Regional Inspector 
Genera of Region vn, Offce of Analysis and Inspetions. Parcipatig in ths project were 
the followig people: 
Kansas City  San Francisco 
Project Leader  Apryl Wilams 
Hugh Owens, 
Raymond Balandrn 
James Wolf 
Alicia Smith 
Headquarters  New York 
Albert J. Nace  Lucile M. Cop 
Debra Robinson  IMPLEMENTATION OF THE STATE

LEGALIZATION IMPACT ASSISTANCE

GRANTS UNDER THE IMMIGRATION

REFORM AND CONTROL ACT OF 1986

CALIFORNIA 
STATE  OF 
Richard P. Kusrow 
INSPECTOR GENERAL 
07-8002 
OAI- DECEMBER 1989  .---_":- ;..;.:,- :.:.,.....:,,.. ..:'. ,. J. ': :..;:";..h' ':'':'!t'-:'.:.(':':, ..  '- .--.:"~: ~~~.&, "'_ ;:,, :..:J.  .-,..:: ..i,':,,_ ':.-.-""_.; ,. .... ,-- ,,,. '"..._:..:.::.... ..--..:.. ..t,....  :'...
EXECUTIVE SUMMARY 
PURPOSE 
The purose of ths inspection was to determe how effectively Calfornia implemented the 
State Legalzation Impact Assistace Grants (SLIAG) program, to identify potential problems 
early in the process, and to identiy goo practices which all States could share. 
BACKGROUND 
progr 
The SLIAG  was established under the Immgration Refonn and Contrl Act (IRCA) 
of 1986 to reduce the fmancial burden of providig public assistance, public health assistace, 
and educational services to eligible legalzed aliens. In Fiscal Year (F) 1988, $928.5 milion 
in progr funds were allocated to States, and funds wil contiue to be alocated through 
FY 1991. These funds also cover admnistrative costs for implementing SLIAG at the State 
and local levels. Payments ar made for public assistance activities generaly available to all 
needy individuals and public health assistace services offered under the States' public health 
progrs. The payments also cover educational services designed to assist eligible legalized 
alens to attain a satisfactory level of performce in school and to achieve English language 
proficiency and citizenship skils necessar to become permanent residents. The Famly 
Support Admnistrtion (FSA) is responsible for admisterig the program. 
Because SLIAG was a new progr, FSA realzed that problems would surace early in its 
implementation. In addition to the norm dificulties encountered in creatig new processes 
and proedures, FSA recognzed that SLIAG would have unique problems. Some of these 
issues include the diversity of programs which SLIAG encompasses, cultur and language 
barers associated with the servce population, maintaning confidentialty of information, and 
the extremely short tie fraes for the grt award process. 
METHODOLOGY 
In response to the anticipated dificulties with implementing SLIAG, FSA requested that the 
Offce of Inspector General (OIG) conduct reviews in 10 States to determne the progress of 
States ' implementing this progr. The FSA selected nine States and the Distrct of Columbia 
of program they offered, the number of eligible legalized aliens in the 
because of the varety 
population, or the amount of the grant award. The nine States ar Arzona, California, 
Colorado, Florida, llinois, Massachusetts, New York, Texas, and Washington. 
Interviews based on strcturd discussion guides for each major program ara, as well as 
documentation fuished by FSA and State and local offcials, built the base of information for 
review conducted in the State of California and reports 
ths report. This report represents the 
on its implementation of the SLIAG program as of August 1988.  -----
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Both FSA and Calorna were commtted to identiyig problems and developing inovative 
and effective solutions for them. Imedately followig our on-site visits, FSA was given an 
outle of the State concerns identied in ths report 
IUnai 
1987 FSA ha held  conferences and issued informaton to 
FINDING: Since 

Stats on implementing the SUAG program 
begig 
The FSA held several national conferences  in 1987 to share 
inormation with States on SLIAG legislation, the implications for States, the 
application process, and the documentation of costs. 
The FSA also provide States with "Question and Answer" issuances and 
demographic data from the Imgration and Natuzation Servce (IS). 
FINDING: Calfornia established a strture to identfy organizanal and program needs. 
The Deparnt of Social Servces, the grte agency, assigned public 
assistace coordation to its Refugee and Imgrtion Progrs Brach. Both 
the Deparent of Health Servces and the State Deparent of Education 
established IRCA units to handle SLIG-relate functions. 
The State has used advocacy grups, along with State and local governmenta 
progr 
work grups, to help implement the SLIAG  in Calorna. These 
argements have helped cross- thugh report of plang and 
pollate ideas 
argements have aide diferent method for estiatig 
progress. Also, these 
progr 
costs. 
The Health and Welfar Agency, designate by the Governor as the single point 
of contat and lead agency to implement the SLIAG program, served as par of 
the State s IRCA Workig Advisory Grup. The Group was established to 
resolve policy and regulatory issues and ensur that the varous State 
deparents comply with IRCNSLIAG policies. 
FINDING: Calfornia also took steps to document expenditures and control disbursements. 
The State Deparent of Education conducted workshops for school officials to 
acquait them with the varous INS car. The purse of the workshops was to 
show the officials how these cards can be used to identiy eligible legalzed 
alens for the SLIAG-funded education programs.  , :. ..,..  .;.."'-: --'7_  J.""" - -' . ""- ',"-':'''" ;':'' ':'' '''-''-''' , . . -:.. .._ ...  -, ., .... "".I_-'-J''_'''' -'' .'' _.  .-",'-, -' .,--
The State told the counties that in order to be reimbured for servces rendered 
retractive to October 1987 there must be supportng documentation for these 
servces. 
The county agencies visited durg the inspection were, in many cases, captung 
infonnation on eligible legalized aliens retroactive to 1987. 
Neverteless, there are some funds control vulnerabilties. 
FINDING: Public health assistance programs need definitive guidelines from the State on 
how to identify eligible legalized aliens. 
FINDING: The FSA's policy of denying payment for services rendered by community-
based organizations and qualifed designated entities prior to the State s application 
approval date caused difficulties 
for the State. 
FINDING: Conflicting interpretations of the term "public charge" has caused 
uncertainties for aliens as to what services they are entitled to receive without fear of 
deportation. 
FINDING: State guidelines are needed to determine allowable costs in public health 
assistance and education programs. 
As mentioned earlier, FSA and Calornia have aleady initiated action on some of the 
recommendations made in this report. Steps have been taen by FSA to provide States with 
more specific, fonnal guidelies for identifying and documentig actual program and 
admnistrative costs. However, additional actions ar necessar in other areas on the par of 
FSA and California. 
RECOMMENDATION: The Stat should issue directives to the counties to ensure greater 
consistency in documenting the status of eligible legalized aliens 
for public health services. 
RECOMMENDATION: The FSA should analyze the effect of its policy to deny retroactive 
payment to community-based organizations and qualifed designated entities for services 
rendered in good faith, and consider whether a modifICation to its position would be 
warranted. 
RECOMMENDATION: The FSA and the INS should further clarify what is meant by 
public charge" and widely disseminate this information to the aliens who have raised 
concerns about their resident status.  ~~~~
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-i:::"  o:,  'k. 
RECOMMENDATION: The State should develop a methodology to identify allowable 
public health assistance program costs. 
RECOMMENDATION: The Stat should develop guidelines for all providers of 
educatinal servces identifying allowable costs for SLIAG purposes. 
COMMENTS 
drt 
The FSA and the State of Calfornia both commente on the  report. They generally 
agreed with our fmdigs and recommendations. Both indicate that steps have been taen to 
improve implementation of SLIAG. Their comments are included verbatim as Appendices B 
andC.  ",...-, .:..: .:.:":'. '--. ,-,-",-,.., .,,- ,=-- ",," '",.'...' -,.- .,-. ............ .. ......... ..........:..-. . ..c..........' .i..'... ...._..... .......- . ..._-. '  ...... ............... .........o... ...-....-. .-.....".....-....._."....."..  ..'..... -. ... . ............. ." ..;...."...."....'... '  '..' .'..-. .'..'....... ... ...... ... .... ...... .... .......... ...... . . d......;..../.... ../..'...:...... .-....."...... "....,...., ............- ...-.. ......  ...-.   .....".....  . ..(......-... . ...-...... ..".... .". . ' ...' .P ............... ........ .. c.....-   .. ........ .............  . . ....:. . ... . ..'......-....,   . ...-..'. ..;..'...;..''...- -   .... .... . .,.. ".".. '.-,..'....... ' ..... 
TABLE OF CONTENTS 
EXECUTIVE SUMMARY

NTRO DUCTIO N . .... .......  ............ .... ....... 1

PU R POSE. ...... ................ ................ ...... ....  ........ .... ..... ... 1

BACKG ROU N D....  ............... ..... ... 1

ETHODOLOG Y ............... .......... ................ 
.......... ......... II 

CALIFORNIA' S ORGANIZATIONAL STRUCTU RE........................................... 3

FINDINGS AND RECOMMENDATIONS .................................................................. 5

PU B LIC ASSISTANCE ..... ........... ......... ....  ................ 6

PUBLIC HEALTH ASSISTANCE................................................................ 8

EDUCA TIO N . ..11....  ..11.... ...................... 1 

CROSSCUTTING ISSUES ......................11................................................ 12

OIG RESPONSE TO COMMENTS ......................................................................... 15

APP EN DIX A.... ..... .... .......... .......... ..........  ............ ............... A . 1

APP EN DIX B................. ...  ....... .... B . 1

APP EN DIX C. .... ....... ..... .... .... ...  ........... C - 1
 . ..:. .._".-. .:_... --=-..,_... -,... --.. -";- -I_  "-_...;..."_."" .:._.:o_. ...-- ..='""),,,,,,,,:.--""  --..........:.-."".. ....'- ,.---
INTRODUCTION 
PURPOSE 
The Famy Support Admstrtion (FSA) reuested that the Ofce of Insptor General 
(010) conduct an inspetion in nie States and the Distrct of Columbia to determe how

Grts 
effectively the States implemente the State Legalzation Impact Assistace  (SLIAG)

Imgrtion 
progr awarde under the  Reform and Control Act (lCA) of 1986. The

insption included reviewig mehansms in place to identi these funds and determg

prours 
whether present or projecte policies and  adere to FSA  FSA also

gudelies. The 
was intereste in identig potential problems early in the process and goo pratices which

pertg 
al States could shar. Ths report presents the results of the inspetion  to the State

of Caorna.

BACKGROUND 
Under IRCA, eligible legalze alens may apply for perment residency within a I-year

peod afer they ar fit eligible (Le., by the 31st month afr they receive temporar resident

status).

Ths new population wil incrase the demad for State public assistace and public health

assistace servces signcantly. It wi also incras the demad for State educational servces

nee 
as these new residents obta Englsh laguage and civic skis  to beome U.S. citizens.

, To help States defray may of the costs of providig public assistace, public health 
assistace, and educational servces to eligible legalze alens, IRCA authorize $1 bilon 
each year from Fiscal Year  thugh 1991 for SLIG grts, less an amount 
(F) 1988 
identied as the "Fedra offset." With few exceptions, eligible legalze alens are ineligible 
progr 
for federaly funded public assistace  such as Aid to Fames with Dependent 
Chidrn (AFC), foo staps, and Medcaid. The "Fedra offset" is the estiated cost 
the Federal Governent of providig these servces or benefits to those few legaliz aliens 
mion 
who ar eligible for them. In FY 1988, the law alocated $928.  to States. 
To reeive SLIAG fuds, States must apply to the FSA Division of State Legaltion

adisterig 
Assistace, which is responsible for approvig applications and  the program.

The application must be approved in tota for a State to reeive any SLIAG funds. The FSA

also provides States with tehnical assistace on policy issues and on the method used to

determne costs and verify actual costs.
 ~~~~
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-i. - L::,  1;:i.  '-"',;1: 
The basic reuiment for States to clai reimburement is that costs must be alowable, 
reasonable, and alocable. State public assistace and public health assistace program must 
progr 
be the same ones avaiable to the genera public. States canot create new  in these 
aras speifcaly for eligible legalze alens. However, States may create new or adtional 
progr  clai 
education  for the eligible legalze alen popultion. States may also 
adstrtive 
reimbursement for progr adstrtive and SLIAG  costs. 
lite 
Reimburement for public assistace and public health assistace is  to the amount of 
maum 
State and local funds expnde for SLIAG-relate costs. The  SLIAG 
reimbursement for educational servces is an average of $500 per year per eligible legalze 
progr adtrtive 
alen. Determnation of  costs is mad in accordce with the fial 
regulation at 45 CF 402.22. 
adsterig 
The FSA is responsible for  the program Because SLIG was a new program, 
real 
FSA  that problems would surace early in its implementation. In addtion to the 
nor  reogn 
diculties encountered in cratig new processes and proedurs, FSA 
that SLIAG would have unque problems. Some of these issues include the diversity of 
progr 
which SLIAG encompasses, cultu and language baners associated with the 
maitang 
servce population,  confdentialty of inormation, and the extrmely short
fres 
for the grant award process. 
METHODOLOGY 
The FSA selected nie States and the Ditrct of Columbia for the inspection beause of the 
progr 
varety of  offered the number of eligible legalze alens in the population, or the 
amount of the grt. The nine States ar Arna, Caorna, Colorado, Florida ilinois, 
Massachusetts, New York, Texas, and Washigton. Ths report reviews implementation of the 
SLIG progr in the State of Calorna as of August 1988. 
strctu 
Pror to conductig the inspetion, the OIG develope  discussion gudes for each 
major program activity at the State and local levels. In the State of Calorna, we held 
Sacento 
intervews in  with appropriate sta. Ths include the single point of contat and 
representatives frm public assistacteh, p ublic health assistace, and education. In adtion 
we interviewed appropriate sta in  counties: Los Angeles, Orge, and Santa Clar 
Accordig to 1987 data from the Calornia Deparnt of Finance, the four most populous 
counties with eligible legalze alens were Los Angeles (64%), Orange (8%), San Diego 
(5%), and Santa Clara (2.5%). For purses of reviewig dierent geographical aras in the 
State, two counties in the south were selecte (Ls Angeles and Orange) and one county in the 
nort (Santa Clara). Prviders of health and education servces also were intervewed The 
purse of the local contats was to obta informtion frm local governg boes as to their 
progr 
planed implementation of the SLIAG  In Caiforna, SLIAG-funded program 
adstere  progr. 
be county- as is the case with their other  ~~~
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CALIFORNIA' S ORGANIZATIONAL STRUCTURE 
The governor has designate the Health and Welfar Agency as the single point of contat and 
progr 
lead agency to implement the SLIAG  The agency is responsible for a number of 
taks includig preparg the anual application for SLIAG fuds; reommendig SLIAG 
fudig 
alocations for spifc progr; coodiatig budget policy with approprite State 
agencies, the Legislatu, and pertent Fedra agencies; and servg as par of the IRCA 
Workig Advisory Grup to resolve policy and reguato issues and ensur that varous State 
deparents ar in compliance with IRCAISLIG policies. 
In Caora, the th prgr components  administerig the SLIAG program ar the 
Deparent of Social Servces, respnsible for public assistace; the Deparent of Health 
Servces, responsible for public health assistace; and the State Deparent of Education 
respnsible for education activities. Each agency wi reuest funds from the grante agency, 
which is the Deparent of Social Servces. 
The Deparent of Socia Serves 
adstrtive 
The Deparent of Social Servces is respnsible for State  functions associated , 
progr 
with effectively implementig public assistace  to be funde by SLIAG. The 
Deparent of Social Servces, head by  ditor, has eight divisions. The SLIAG 
functions wi reside in the Welfar Progr Division. With ths division, the Refugee and 
priy 
Imgrtion Progrs Brach wi be  responsible for coordiating and
adsterig  progr 
the SLIAG  at the State level. Addtional sta wi be responsible for 
the grte agency s activities associate with coordatig and adsterig SLIAG fuds. 
Deparnt of Healh Serves 
The Deparent of Health Servces is respnsible at the State level for coordiatig and
adterig 
health progrs to be funde by SLIG. Deparent functions assocate with 
SLIG wi be data proessing, budgets, accountig, legal servces, and contrt management. 
An IRCA Coordnation Unit has ben established with the Deparnt of Health Servces to 
overse the functions assoiate with the SLIG progr. 
SIl Deparent of Educaton 
adsterig  progrs 
Responsibilty for  youth and adult SLIAG-relate educational  resides 
in the State Deparnt of Education s IRCA Unit The IRCA Unit is locate in the 
Deparent 
s Youth, Adult and Alternative Educational Servces Division. The Chancellor 
Ofce of the Caorna Community Colleges wi shar respnsibilty with the State 
Deparent of Education in management and tehncal assistace as they relate to community 
colleges.  ~~~~~
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The IRCA Unit provides grts to local educational agencies, community colleges, 
communty-based organzations, qualed designate entities, and other public and private 
non-profit organzations to deliver educational servces to be fude by SLIAG.  FINDINGS AND RECOMMENDATIONS

Both FSA and Calora were commtt to identiyig prblems and developing inovative 
and effective solutions for them. Imedately followig our on-site visits, FSA was given an 
outle of the State concerns identied in ths report 
IUna 
FSA Iu held  conferences and issued informaton to 
FINDING: Since  1987, 
Stls on implementing the SUAG program 
begig 
The FSA held severa national conferences  in 1987 to shar 
inormtion with States on SLIAG legislation, the implications for States, the 
prss, 
application  and the doumntation of costs. 
The FSA also provide States with "Question and Answer" issuances and 
demogrphic data from the Imgration and Natuzation Servce (IS). 
FINDING: Calfornia estalihed a strture to Idntfy organizanal and program needs. 
grte 
The Dep  nt of Social Servces, the  agency, assigned public 
assistace coordation to its Refugee and Imgrtion Progr Brach. Both 
the Deparent of Health Servces and the State Deparent of Education 
established IRCA  SLIG-relate fuctions. 
unts to handle 
The State has used advocacy grups, along with State and local governenta 
progr 
work grups, to help implement the SLIAG  in Calorna. These 
argements have helped crss-pollate ideas thugh report of plang and 
progrss. Also, these argements have aide diferent method for estiatig 
prgr 
costs. 
The Health and Welfar Agency, designate by the governor as the single point 
of contat and lead agency to implement the SLIAG program, served as par of 
the State s IRCA Workig Advisory Grup. The Grup was established to 
resolve policy and reguatory issues and ensur that the varous State 
deparents comply with IRCNSLIAG statutory and regulatory reuiments. 
FINDING: Calfornia also took steps to document expenditures and control disbursements. 
The State Deparent of Education conducte workshops for educational servce 
providers to acquait them with the varous INS car. The purose of the  . . .I"  ,- - ' '. :... . , ' :"_",-, -';. ..,,-,_ o__  ..- ::"..:, "': ---.-.;...-..- ;"""- -,,"". --.LL;i.....""'':'';''  '''-''
workshops was to show the officials how these cards can be used to identiy 
eligible legalze alens for the SLIAG-funde education programs. 
The State told the counties that in ordr to be reimbured for servces rendered 
retractive to October 1987 there must be supportg documentation for these 
servces. 
The county agencies visite durg the insption were, in may cass, captug 
inormtion on eligible legalze alens retractive to 1987. 
Neverteless, there are some fuds contrl vuerabilties. Findigs and reommendations 
concerng these vuerabilties follow under major topic aras. 
PUBLIC ASSISTANCE 
Assistance or Serve Activitis 
fude 
State public assistace servces to be  include Genera Assistace, AFC
Progr, foo 
(unemployed parent), Supplementa Securty Income/State Supplementa 
staps, Med-Ca, and other programs as indicaated i n the State s approved application for 
SLIAG fundig. No new progrs have ben  due to the avaiabilty of SLIAG
fudig. Al other servces wi be furshed ditly by the counties. 
In Los Angeles County, about 5,00 new Med-Ca cass ar established each month, but only 
a sma number of these ar eligible legalze alens. The Orange County Med-Ca progr 
taes car of patients up thugh age 17. The Indigent Medcal Servces program handles 
patients age 21 thugh age 64. The Orge County Medcal Servces progr taes car of 
patients 18 to 21 for emergencies only. For genera relief, a delarative statement on 
residency is acceptable. The State has indicate to the counties that the costs attbutable to 
eligibilty workers can be claied as a SLIAG cost. In Santa Clara County, the county 
servces. 
dictly provides al 
Documentatn of Eligible Legalized Alien Status 
The norm intae proess will be used to document eligible legalze alen status. The 
question wi be asked, "Ar you a citizen?" A photoopy of the INS form 1-688 (Temporar 
ma. 
Resident Car) wi be  The counties can retractively clai SLIAG-related costs if 
rendere 
they can document the servces 
legal 
In Los Angeles County, eligible  alen inormation wi be on-lie using specifc 
cods. For Genera Assistace, the data is computeri A manual reportg system is used  ~~~~~
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for sending monthly reports to the Finance Deparent. The application process also asks for 
the place of bir. Follow-up is made if the responses ar questionable. For example, when 
applicant is shown to be born in a foreign countr but indicates U.S. citizenship, the case 
furer 
would requir  review. 
In Orange County, Social Securty numbers ar obtaied on all famy members. These 
numbers ar valdated with the Social Securty Admnistrtion in Baltiore twice a year. The 
county began identiyig IRCA eligibilty data in Januar 1988. County procedures requir 
identiying eligible legalze alen status by photocopying the 1-688 (Temporar Resident 
Card) and I-688A (Employment Authorization Card). 
In Santa Clara County, applicants ar asked if they ar a U.S. citizen. Verication, since 
October 1987, has been made using the 1-688 (Tempora Resident Card), which is 
maintaed in the applicant s record. 
Program Costs 
The State indicated that if the counties want to be reimbured retroactive to October 1987, they 
must have supportng documentation for services rendered to eligible legalizd alens. Claim 
clai 
forms have been provided to counties to  actual costs. A ledger wil be prepared for each 
progr 
at the State level (e.  foo staps or Genera Assistace). 
Counties can claim actual costs by identiying the time and related costs of providing 
AA (Amesty-Alien) is used to 
specified servces to the eligible population. A specific code 
identiy services rendered to this population group. 
Administrative Costs

tie 
At the State level  sheets are used to identify personnel costs. Other costs ar detel1ined 
by diect costing of supplies and equipment to SLIAG. Indict costs are determn d by the 
State Cost Allocation Plan. 
In Los Angeles County, the cost allocation method is used in the middle month of each quarer 
to allocate costs to progrs. Only the caseworkers complete time sheets. All other costs are 
put into support of the caseworkers. No dict charge is made for admnistration. Orange 
County has its own cost alocation method. Santa Clara County computes admistrative costs 
as 60 percent of the cost of services rendered. 
Drawdown of Funds and Cash Balances 
The Deparent of Social Services is responsible for drwdown of Federa funds. Briefly, the 
agency prepares funding requests for all th deparents-Deparent of Social Services,  , .,-o""- ;", :--"' -:"""" '''_.  "",.... .IO_  ..:"'_ ";';-~~~':" C::  ..,'';'':_ '; :''!' ...'' &.' :'' '''''''' '''':'1.'',;,  --,,
Deparent of Healtht Sher vces, and State Depanreente o f Education. Funding reuests 
ma  ar 
no sooner than  days before they  The reuest goes to the fiscal agent 
(Ban of America). Once reeived the fiscal agent sends fuds to the State trasurr s office 
for trsmission to the State controller s offce. If, for some reason, a large cash balce was 
discovere in the peodc report to the State, subseuent SUAG payments would be 
reuce 
PUBLIC HEALTH ASSISTANCE 
Assistance or Serve Activities 
With the Deparent of Health Servces, public health servces and tratment progrs 
trsmitt 
cover tuberculosislleprosy, sexualy  diseass, labotory support, imunizations, 
periata servces, famy plang, chil health and disabilty prevention, and IRCA 
subvention. IRCA subvention includes a varety of public health servces not specifc to other 
progr. 
avaiable  Public healPthurbglicr  assistace includes Calorna Chidren s Servces 
and the Adolescent Famy Lie  Public assistace includes the Medcaly Indigent 
Prgr, 
Servces Prgram the County Medcal Servces  and priar car clics. 
ad 
No new progrs have ben  for FYa 1d98 8 beause of SLIAG fundig. Envinmenta 
ditly 
health and foster car servces have ben  for FY 1989. Those servces provided 
by the Deparent of Health Servces include laborator servces, imunizations (the State 
purchass the seru but the counties adster it), Chidrn s Servces (although th is split 
with the counties), Famy Plang, and Chd Heaplth ranid  Disabilty Prvention. The State 
contrts with priar car clics to render some  health care. 
In Los Angeles County, thee servces ar contrcte out. These ar obstetrcal clics, truma 
car servces, and emergency room servces. Orange County health servces include Indigent 
Medcal Servces for persons age 21 thugh age 64, which the county took over frm the 
State several year ago. Santa Clar County offers simar servces. 
Documentaton of Eligible Legalized Alien Stats 
cert  ar 
For puroses of filg the SUAG application,  public health program  classified as 
identig  legal 
public assistace. Ths reuies  individual eligible  alens in order to 
document costs. The pertent INS car wi be reueste for verication puroses. The 
counties have ben reuestig ths inormation since October 1987. The policy is to ask for 
afr 
the applicant s status  the servce has ben rendere Varous method of identifyig 
eligible legalze alens have ben adopte by the State, which ar (1) actual head count 
(which is the most dicult to obta), (2) random sample of the universe, or (3) sample of 
servce ara or users.  . ~..:. :,,-, ,.; ""-- '---_'._------------ --------.--..----.--------.. ~- -."
Los Angeles County found that samplig eligible legalze alens would identiy more SLIAG 
costs than using their system to count individuals. Samples of inpatients were taen on two 
occasions. The sample data was obtaed frm bi-ligual sta going to the homes of the 
persons who had ben in the hospita. In ths settg these individual were more liely to 
indicate their alen status than in the hospita envinment. Ths County indicate ths gave a 
fude  Orge 
more accurte count of thosae dpe rsns using SLIAG  servces. In  County, 
legal 
adtional sta have ben  to identi the eligible  alen population. The 1-688, 
Tempora Resident Car or I-688A, Employment Authorzation Car issued by INS 
legal  begig 
identiy the eligible  alen patients by an alen registrtion number  with 
forze 
A9. In Santa Clar County,  procurs have not yet ben established 
FINDING: Publi healh assistance programs need definitive gudelines/rom the Stat on 
how to identify eligible legalud aliens. 
Both Los Angeles and Orange Counties believe the State s approach to veriyig eligible
legal  progrs 
alen status is fragmente To date, only two State  have indicated the 
documentation neeed to verify eligible legalze alen status. The Adolescent Famy Lie 
Prgram wi accept either a facsime of the 1-688, Temprar Resident Cad or I-688A, 
Ca 
Employment Authoritzhatio n  The Community-Bas Periata Services wi accept any 
one of the followig  pieces of identication: . (a) a facsime of the 1-688, Tempora 
Resident Car or I-688A, Employment Authorization Car (b) the amesty application form 
Ths proess 
or receipt for application fee, or (c) the number on the INS card or receipt. 
obtag 
causes more adstrtive workoad beause of the inconsistencies in  eligible
legal 
alen verication. 
greatr 
RECOMMENDATION: The Stat should issue directives to the counties to ensure 
consistency in documentng the stats of eligible legald aliens for public healh servces. 
Program Costs 
The State indicated that counties can use either the actual expenditus, sample method, 
identi 
population ratio method to  costs for public health assistace servces. For those 
public health servces that ar considered public assistace for SLIAG reimburement 
puroses, the counties must trck actual costs of servces rendered to eligible legalze alens. 
Los Angeles County sta indicate they had not reeived instrctions frm the State on how 
to determe alowable progr costs. The county wi captu whatever cost informtion the 
State  is also waiting for State instrctions. Once guidelines have 
reuests. Orange County 
ben issued the county intends to negotiate with the State on method of determng ratios 
and samples. Santa Clar County, not havig any State instrctions, does not know what costs 
to clai or how to document these costs.  Administratve Costs

tie  tie 
At the State level, sta uses  sheets day to reor SUAG-relate activities. These 
progr 
sheets ar use to apporton costs by  These costs ar report on the HCFA
adstrtive  frge 
quarrly expenditu report form. The  cost center includes salar, 
benefits, and a percentage of operatig and equipment costs. The indiect cost rate is 25 
determed under the Cost Alocation Pla pertent to public health. 
percent as 
prours ar  adstrtive 
In Los Angeles County, no  yet in plac to identi  cotsits . A 
possible samplig of employee servces is being conside Orge County uses  sheets 
to reord adstrtive tie alocate to prgr. Admstrtive costs ar computed as 
Orge 
ratio of SLIAG costs to tota costs. The  County Health Deparent s indiect cost rate 
is 18 percent. Santa Dar County captus adstrtive costs in relation to tie spent 
progrs. 
Drawdown of Funds and Cash Balances 
Al requests for SUAG fundig would be mae with the Depparernit  of Social Servces, the 
grte agency. Up to a 25 percent advance can be mad to a  care clic or smal 
county. The cash advance wai be reluceed as crlai tar  submitted for reimbursement. Clais 
for reimburment wi be applied agaist the cash advance. It is unely that large cash 
balances would occur. However, if large cash balances wer note the State s Audit and 
Investigations unt would be 
Interagency trsfer of funds is not done at the county level. In Los Angeles County, SLIAG 
trasurr-ta 
funds would go to the  collector and then to the auditor-contrller for eventual 
trsfer to the health servces fund Al SLIAG fuds wi go into one ledger account. The 
State has not yet issued any  th proedur. Lage cash balances would not 
gudelies on 
Orge  Deparent 
occur because al servces are paid for by reimbursement.  County Health 
sta ar not aware of any proedurs for the trsfer of SUAG funds frm the State to the 
sta 
county. Cah balances probably would not occur. In adtion, Santa Clar County 
indicate that cash balances probably would not occur. 
EDUCATION 
Assistance or Serve Activities 
gr 
kidergarn thugh 
Servces rendered are adult education and  12. Technical 
assistace wi be furshed to educational institutions by the State Deparent of Education 
and thae dCh ancellor s Offce of the Caorna Community Colleges. No new progrs have 
bas 
ben  due to the avaiabilty of SUAG fundig. The community- organizations 
and qualed designated entities wi provide some of the educational functions.  ....J  "'_':-- .._"""' ..w._-,,, ""' _.._....~~~..J  -'- -,,""" .._+a'-=-'-,- ----""-' '- -' ----- ""' ''--''--'
Educational servces ar rendered though grts with varous facilties arund the State. 
Services rendered are English as a Second Language classes and citizenship 
skils classes. 
Documentation of Eligible Legalized Alien Status 
Identiyig eligible legalzed alen status wil be incorporate into the norm enrollment 
process. The State has held workshops for educational servce providers on obtaning this 
information. The workshops for kidergarn thugh grde 12 acquaited educational 
servce providers with the varous INS car and how to use them for identification purposes. 
For adults, the interview process is used. The applicant is asked, "Have Y9u applied for the 
amesty program?" At the present tie, no statewide record-keeping system exists for 
determning who ar the eligible legalze alens who qualify for educational program under 
SLIAG. The inspection revealed that the educational facilties are asking for the 1-688, 
Tempora Resident Car or I-688A, Employment Authorization Card, or ar utizing the 
INS' s fee receipt which reflects the "A" number assigned to each eligible legalized alien. 
Severa community colleges and secondar schools were visite as par of this inspection. At 
servg Orge  00- 00 
one college  County, approximately 10, 11, persons are enrolled in 
English as a Second Language classes, and approximately 2,500 are eligible legalzed alens. 
progr 
One of the requirements of the SUAG  is that eligible legalized aliens be in U. 
schools for less than 3 complete years. At this college, information is obtaed on whether an 
eligible legalized alien was in that school for Iess than 3 complete year. However, 
information is not obtained as to whether they attended any other schools. 
Program Costs 
The State is developing guidelines for determnig actual program costs. Notices have gone 
out to al providers to document costs retroactively from October 1987 thugh June 1988. 
Providers must have had a grant in place by May 13, 1988, to be reimbursed from that date 
forward. The accounting system wil be moded to add another fund account to record 
progr 
costs. The amount reimbursable under SLIAG is capped at $500 per eligible 
legalized alien per year. Each provider or school entity must keep a separate accountig of 
these funds. 
A visit to a local community college in Orange County revealed that the State made its 
definition of alowable costs very restrctive. The college had received an award letter dated 
May 1, 1988, for the period October 1, 1987, thugh June 30, 1988. Costs considered 
allowable were (1) essential staf development for personnel providig instrction to eligible 
legalized alien students, (2) requird supplementa record-keeping/documentation costs, and 
(3) supplementar educational services necessar to enable eligible legalized alien adults to 
attai permanent residency status and naturalzation. However, a revised award letter dated 
July 14, 1988, was received that sharly reduced the allowable costs. This letter stated that 
only costs associated with assessment and evaluation would be curently alowable for 
FY 1987-88.  ,-----
--- -_. 
---..... """ "'---"-' '''.''--''--' ----'' ,..---  -". . '-'~ '------_", 
Administrative Costs 
lit 
adstrtive 
The SLIAG provisions  State educational agency  ti  5 percent of 
costs to 1.
tota SLIAG educational costs. Tune sheets wi be used to captue  spent on the SLIAG 
Th 
progr. 
SLIG-related education positions ar funde by the State Deparent of 
progr. 
Education and are not charged to the SLIAG 
The State Deparent of Education is using a provisional indiect cost rate of 34 percent of 
payroll costs, which goes back to 1979 and was updted in 1983. The communty colleges 
use a 10 percent rate, provisional since 1981. An Orange County communty college has no 
tie 
gudelies frm the State to determe adistrtive costs. No  sheets are used to 
wi 
determe sta tie devote to SLIAG activities. The college  develop its own 
methodology for determg adstrtive costs for SLIAG puroses. 
claig
In other aras reviewed in Caforna, schools were improvising methods for 
adstrative  tie 
costs. Most were using  sheets as the generay accepte manner of 
determg adstrtive costs. One seconda school is planning to use school proedures 
for determg adstrtive costs thugh identiyig instrctor hour and the number of 
eligible legalze aliens receivig instrction. An apportonment will be used to record
adstrative 
costs. 
For the school year 198t7i-1 988, an elementa school plans to have school personnel 
reonstrct how much  they spnt on SLIG progrs from calenda, notes, etc. This 
tie 
would include  spent on the application proess. 
Drawdown of Funds and Cash Balances 
The Deparent of Social Servces, as the grtee agency, would handle al drawdown 
activities. The State permts cash advances of up to 25 percent of estimated costs. The State 
requires the community-based organzations to be bonde for the amount of the SLIAG 
advance. When providers submit their quarrly reports on actual costs, any excess cash 
balances would be detected The State would request a refund or make an adjustment. 
CROSSCUTTNG ISSUES 
Accordig to fmal regulations published Marh 10, 1988, States had to submit the FY 1988 
application no later than May 16, 1988. Revisions to the application had to be submitted by 
July 1, 1988, and the FY 1989 application had to be submitt no later than July 15, 1988. 
progrs 
Applications were to conta brief descrptions of the State 
or servces, estimates 
of the State s SLIAG-relate costs for each program or activity for that parcular fiscal year 
(includig inormtion on the number of eligible legalze alens residing in the State), and a 
brief explanation of the methodology used to estimate these costs.  .:O:  -'."'--. :'. c-.  -,---,;" ""-'_-"..c""--,  '''-'-''''-''_ .J.  --'---- --.o. _., _._ -_._ _._ --- ---.--._--
FINDING: The FSA's policy of denying payments  community-
for servces rendered by 
based organizations and qualifed designated enties prior to the State s application 
approval date caused difficulties 
for the State. 
Some communty-based organizations and qualfied designated entities have provided health 
and educational services to eligible legalized aliens with the understanding they would be 
reimbursed for these services by the State. The FSA interpreted that servces rendered prior to 
the approved application date could not be reimbursed. This has placed a financial burden on 
these providers, who have rendered the servce but may not get paid for it. 
RECOMMENDATION: The FSA should analyze the effect of its policy to deny retroactive 
payment to community-based organizans and qualifed designated entities for servces 
, and determine whether a modificaton to its position would 
rendered in good faith
warranted. 
FINDING: Conficting interpretations of the term "public charge" has caused uncertain
ties for aliens as to what services they are entitled to receive without fear of deportation. 
Another situation causing concern to the State is the defmition of "public charge." Some 
afd 
people are  to identify themselves as aliens for fear of being considered a public charge. 
progrs 
Some qualifed designated entities are  SLIAG-related 
tellig alens not to apply for 
for the same reason. The situation has caused uncertnties for alens regardig benefits they 
may be entitled to and if acceptig these benefits would subject them to possible deporttion. 
RECOMMENDATION: The FSA and the INS should further clarify what is meant by 
public charge" and widely disseminate this information to the aliens who have raised 
concerns about their resident status. 
FINDING: State guidelines are needed to determine allowable costs in public health 
assistance and education programs. 
Los Angeles County Deparent of Health Services sta indicated they have not received 
progr 
instrctions from the Deparent of Health Servces on how to determne alowable 
captu 
costs. Th  county wil  whatever cost information the State requests. Orange County 
Health Care Agency staff are also waiting for State instrctions. Once guidelines have been 
Orge 
issued by the State,  County sta intend to negotiate with the State on methods of 
determning ratios and samples. Santa Clara County, without State instrctions, does not know 
what costs to claim or how to document these costs. 
RECOMMENDATION: The State should develop a methodology to identify allowable 
public health assistance program costs. 
Although the State Deparent of Education is developing guidelines for determning 
allowable educational program costs, a secondar school indicated that no instrctions have  been received from the State Deparent of Education on determning costs. An elementar 
school revealed that it did have information from the State as to alowable costs. They were 
referencing a State publication entitled "Californa State Education Plan for State Legalization 
Impact Assistace Grants." Other schools visited indicated that either they had no State 
were awaiting receipt of guidelines. In the case of one community college a 
guidelies or they 
stadad community college accounting maual was used 
RECOMMENDATION: The State should develop guidelines for all providers of 
educatinal servces indentifying allowable costs for SLIAG purposes.  ~~~
..;.. 
w._.  ;";"o.- . 
OIG RESPONSE TO COMMENTS 
The FSA and the State of Caorna both commente on the drt report. 
The FSA 
agr 
The FSA has generaly  with the OIG report findigs and recommendations. The FSA 
progr 
has taen a number of steps to improve implementation of the SLIAG  includig 
claryig program policies and proedures. We have moded cert aspets of the report 
based on the comments reeived frm FSA. 
The FSA questioned the statement that the new population would signficantly increase public 
assistace and public health assistace servces. Early estiates indicated that large numbers 
of alens would qualy to access the SLIAG program. The report recogniz that inormation 
obtaed durg the review determed that substatial incrases in workloads and 
expenditus could occur in these program areas as well as in education. However, we 
understad frm  ' offcials that demand for servces nationally is 
recent discussions with States
earlier projections. 
falg behid 
fig  cert 
The draf report states that "For purose of  the SLIAG application,  public health 
progrs ar 
classifed as public assistace. 
priary 
The FSA replied that they see ths  as an issue of cost identication and that they 
work with the States to develop method of documentig costs which ar consistent with 
FSA' s responsibilties as stewar of public fuds. We believe that FSA's actions to identiy 
progr 
alternative method is responsive to the nee of the 
We contiue to believe that a strct interpretation which permts public health costs to be 
claied only for specifc eligible legalze alens is burdensome to the States and, in many 
reui 
cases, would  considerable revisions to the States' system or statutory reuirments. 
agr 
However, we do  that FSA's use of alternative systems, such as the Cost Documentation 
System and a revised population ratio method system which reflects usage, would be a 
positive effort to enhance cost effectiveness without reuirg States to develop new systems 
or make considerable revisions to present systems. The population ratio method could be 
revised to consider not only eligible legalize aliens in the servce population but also use of 
those services by the eligible legaled alien population base on informtion aleady obtaned 
frm progr experience. Where appropriate, other alternatives might be used which would 
produce a more effcient system for the States and address congrssional intent that the States 
would not be required to establish new or elaborate systems. 
cert 
The FSA made numerous comments to identify  matters of fact, policy, or proedures. 
We have included these comments verbati in Appendix B.  The Sta of California 
agr 
The State has generay  with the OIG repo fidigs and reommendations. Their 
comments ar include verbati in Appendi C. The comments clared the State 
adster 
organzational strctu use to  the SLIG progr as well as the report 
dteisc rption of the State s drwdown of fuds and the handlg of cash balances. Since the
of the on-site review, the State has taen signcant steps to effectively implement the 
SLIG progr though procedur and 
system changes.  ~~~~
.... ~~~~
':_.!",  ,;-~~~ '::': ::.. :n:.  ' ' -:-'_ ,.:..(. '" .-. ' ;:",-.
:;;;..:'i: 
APPENDIX A 
GOOD PRACTICES  A number of pratices have ben identied that other States could shar. 
The State has use advocacy grups, along with State and local governnta work 
Caora. 
SLIG progr in  These argements have 
groups, to help implement the  plag 
helpe cross-pollate ide thugh report of  and progrss. Also, these 
estitig progr 
argements have aide dierent method for  costs. 
The State Deparent of Education conducte worhops with school offcial to 
acuait them with the varous INS car. The purse of the worhops was to show 
the offcials how these car can be use to identi eligible legalze alens for the 
progr. 
SLIG-funde education 
adter 
The State has taen steps to establish an organzation that wi help  the 
SLIAG progr. The Deparent of Socia Servces assigned coordatig public 
assistace to the Refugee and Imgrtion Progr Brach. The Deparent of Health 
Servces establihed a separte IRCA Coordation Unit. The State Deparent of 
Education has established an IRCA unt in the Youth, Adult and Alternative Educational 
Servces Division. 
cooatig 
Al of these IRCA  units have develope the expertse necssar to 
implement the prgram at the State level. Since  administers may of its 
progr  Caora 
at the county level, these coordiatig unts wi be the focal point at the State 
level for interation regardig SLIG implementation. The Deparent of Social 
grte 
Serces is the  agency for the SLIAG fuctions at the State level 
The Health and Welfar Agency, designate by the Governor as the single point of 
contat and lead agency to implement the SLIG progr, served as par of the State 
IRCA Workg Adviso Grup. The Group was established to resolve policy and 
regutory issues and ensur the varous State deparents comply with IRCNSLIAG 
policies.  ~~~
.-- .\,;:, ;;;,:"::~~~ .:.: ':. ;.:. :-_~~~ ..__ ~~~:;- .,... ,':~~~ .. - ;,,;:,,--,,~..;,.;' ;'''' ':';'' -'- ~'  , .
:;i  .0;:"::;"  G.::'':'  :::'l.  oL;  "r 
APPENDIX B

FAMILY SUPPORT ADMINISTRATION COMMENTS  .-. .--' .._-.  ", .. .(:,;:', _.. .-. ,,; :-, ,,::..,,,,,;; ..j.  ..;.:.  '-  -.:...- ,:.. "_.-_ - . " .':-';_ ~-_...J,,  ..., - _._-_. . ..:- ",. ';, ."" ";- ,,,,,- -...-' . '""- ,,-.-.- - ,.
DEPARTMENT OF HEALTH &. HUMAN SERVICES  F3mily Support Administration 
Memorandum 
"."..IU 
August 10. 1989 
Date: 
From:  Acting Assistant Secretary 
for Family Support 
Subject:  OIG Draft Report: Implementation of the State Legalization 
igration Reform and 
pact Assistance Grants Under the  (OAI-07-88-00442) 
Control Act of 1986 - California 
To: 
Richard 
P. Kusserow 
Inspector General 
Attached are the Family Support Administration comments on 
report. 
coments are technical 
the above draft  Many of our 
in nature due to the complexity of the legislation and the 
fact that the SLIAG program was very new at the time of the
review. 
We appreciate the assistance and cooperation we have 
received from you in response to our request to conduct this 
program. 
round of reviews of the SLIAG  The reports we 
received are very useful" to us in understanding how States 
are implementing the 
program. 
Attachment  -. . _ :":._ "::",.;.  :,,,_-,,,,,,'--:"._ _.- -_ ~~~ -..- ' - -'.- -". .. ,-
; 'n  :0",. 
l C.  '1.x \JIG DRA 
RE:.:BKr': 
Lealization X-pact Assistace
Implementation of the state 
Grants 
Under the Immigration Reform and Control Act of 1986 

state of California

The Family Support Administration' 
s comments are divided into
three sections: 
Comments on background information and other 
narrative material that does not relate directly to the draft
report' 
s findings, comments on the findings, and responses to the 
draft report's recommendations. 
Narrative : 
Page 1 (Background) -- The draft report says, .This new

population will increase the demand for State public assistance

and public health assistance services significantly. 
The draft 
report isn't clear whose conclusion this is or upon what data and

analysis the conclusion is based. The final report should

clarify these points.

In the course of implementing SLIAG, we have discovered that

neither state and local public health programs nor, with few

exceptions, public assistance programs, inquire about legal

status. This suggests that at least some aliens were using

these services before legalization and that newly legalized

aliens do not represent a "new population" for public assistance

and public health assistance services. Preliminary cost data

from states suggests that newly legalized aliens are accessing

public assistance services at rates far lower than the general

population. 
There are indications that a backlog of public 
heal th needs existed and was identified during the medical

legalizations. 
examinations required of all applicants for 
However, there is no data to suggest that, other than this

temporary bulge in demand for public health services, newly 
legalized aliens will generate a significant increase in demand 
services. 
for public health assistance or public assistance 
Page 2 (Background) -- The draft report says, .States must 
develop a method acceptable to FSA for determining
iil 
administrative costs. 
We note that several methods for 
determining the share of administrative costs in ongoing 
programs that are allocable to SLIAG and which are acceptable A
Driori 
are specified in the regulation at 45 CPR 402.22 (b). The 
process of determining SLIAG administrative costs (those costs 
incurred in administering the SLIAG grant itself), like all costs 
y 45 CFR

associated with administering HHS grants, is governed 

Parts 74 and 92 and relevant OMB circulars.

B-2
 '.' ''"'"'..,",",-, ..- .. , ':'''--- '-' .:",..,; , -;':: '- ;". '''' ,:"'. . ,-.....:\:' .':;': '; ....:' .':;',?,:':' .: . - -". . ,"".'.' .-....,':...-:: .:.. .;- -,,  .. - .. -,-,,..;.., "-''-,''.... .-.,~. :.._ :.:_:",  ':--.
'0_  i:;.  .""''-I'' 
c-. 
paqe 5 (Assistance or Service Acti vi ties) -- The draft report 
states, .State public assistance ,services to bep fuantde)d, by SLIG 
include General Assistance, APDC-U (unemployed 
Secuity 
Supplemental  Inco.e/State Supplemental Proqam, food 
proqaJ 
stamps, and Medi-cal. No nev  have been added due to the 
availability of SLIAG fundinq. The only proqua for which the
Departent of 
Social Services provides direct assistance is the
adoption progam. 
The State viII contract out for child abuse 
fuished 
studies. All otheri mserrvitcte s will be  directly by the 
counties. . It is  to note that all progam of public
thee criteria. 
assistance must .eet  Pirst they :8st be 
qenerally available to the population of the State. Secondly, 
they must be .eans-tested. Lastly, they aust provide for the 
subsistence or health of the individual. The requirement that
the proqam 
be qenerally available would preclude the State from
developinq any progam for 8
eliqible legalized aliens. 
Additionally, it is not clear what is aeant by child abuse 
studies. The statute and reqlation would preclude the State 
eliqible
from developinq or conductinq studies on bealf of 8
aae 
leqalized alien.  The final report should  these points
clear. 
Page 5 (Assistance or Service Activities) -- The draft report

the counties that the costs

states, "The state has indicated 
attributable to eligibility workers can be claimed as a SLIAG
cost. 
.. The final report should note that acceptable methods for 
determining SLIAG and program administrative costs are outl ined 
in Federal regulation. The regulation at 45 CFR 402. 22 discussed 
several methods for determining SLIAG and program administrative 
costs in ongoing programs. This section of the regulation also 
permi ts use of other methods for determining proqram 
administrative costs that will document that these costs are 
allowable, allocable to SLIAG, and reasonable.

Page 6 (Program Costs) -- The draft report says that "The state

below the proqram level to identify these costs for 
will not  qo 
SLIAG fundinq purposes.  We cannot determine from the 
description what is meant by this statement. We request that the 
ion. 
final report provide clarifica 
paqe 7 (Administrative Costs) -- The draft report identifies

several methods beinq used by the state and the counties to

determine administrative costs. The final report should note

that acceptable methods for determininq SLIAG administrative

costs are outlined in the regulation at 45 CFR 402.22, and the

process of determininq SLIAG administrative costs, like all costs

associated with administerinq HHS qrants, is governed by 45 CFR

Parts 74 and 92 and relevant OHB circulars.
 " ' ,,- --.' "" -..  .... ,-- : . ' .. '':-' , ,," .- :";'. :-'' ,"' ,-' ~~~ ::. '..';, .':"  ..,;,....:.. ""_ '-'''- ':'''':': '''':' ''---
J-:''J  :.f..  J..  ,:l  ..,,.I  ::S......  C:"  ''J 
ssi tanJ 
Public Health l:'
Page 7 (Assistance or Service Activities) -- The draft report

I s 
ists California Children  Services and Adolescent Family Life 
Pulic 
health/public assistance. 
Program as  The final report 
should note that since the OIG program review, the State has 
I s 
resubmitted the California Children  Services program under 
public assistance, and the Adolescent Family Life Program under
public health assistance. 
Page 8 (Documentation of Eligible Legalized Alien Status) -- The 
draft report states that "For purposes of filing the SLIAG 
application, certain public health programs are classified as
public assistance. 
By statute and regulation, all programs and 
activities which fit under the regulatory definition of public 
aSssistLance oIr pAublic heGalth as.si stance must be categorized 
accordingly. The definitions of public assistance and public 
health assistance are based directly on section 204 of the 
Immigration Reform and Control Act of 1986 (IRCA) which created
The public assistance/public health assistance categorization 
issue is primarily one of cost documentation requirements, not 
the allowability of costs associated with any particular health 
program. Under our regulation, States are allowed to use a 
'the service population to 
single ratio of the number of ELAs in 
the total service population to establish actual costs for public 
SLIAG. Implicit 
health assistance programs, as defined for 
this method is the assumption that eligible legalized aliens will 
access programs in the same frequency and at the same cost as the 
general population. We do not believe this assumption to be 
appropriate for medical assistance programs that provide 
treatment to needy individuals. To the contrary, the 
information that we have to date indicates that allowing use of 
the population ratio method for these programs generally would 
have indicated 
overstate costs, dramatically in some cases. We 
to States that we would allow use of the population ra io method 
empirical basis to indicate 
for any program for which there is an 
 costs. 
that doing so would not overstate 
Furthermore, we realize that many public assistance and public

heal th programs do not routinely collect information on

immigration status but we have found that many do collect social

numbers. That is 
securi ty  why we funded and devoted substantial 
staff resources to developing a system that matches the social

security numers of 
program participants with those of newly 
legalized aliens. This system gives States informatioa on the

number of newly legalized aliens participating in a program and

the cost of services to them. 
It is now available and allows 
States to establish costs for FY 1988 as well as current and

future years. 
Recently, we sent State SLIAG Single Points of 
Contact suggestions for other possible methods for establishing
 . '
. "'.- ,-:-"_"'...,".':, .:': ..~~~) .,.' -. :...- , :": . - "'"" - ';' :''''-'::' . . ::. :;':. -:.:. ~~~ ''' ':'::'- - --' '':';'' '--:''; ' . "''';'---_..,", ....-'--' . -.. 
"::-:' n  cj...;  :i,.  ;2.::.: .  ::':3--::.i:' 
costS. 
None of these  ;,er:.!:lti.  methods requires aatting up ni:' 
.. ii 
administrative mechanisms or checking status of all program

participants. 
status) -- The 
Page 8 (Documentation of Eligible Legalized Alien 
draft report further states that, "Los Angeles County found that 
sampling eligible legalized aliens would identify more SLIAG 
Samples of 
costs than using their system to count individuals. 
occasions. In the 
inpatients were taken on two  opinion of the 
county, this resulted in a more accurate method of determining
costs.  the state. 
This method is under review by - It is unclear 
to us how taking a sample of inpatients would yield better 
resul ts than counting actuals. The regulation allows costs for 
(1) establishing 
public assistance programs to be established by 
(2) 
costs associated with identified eligible legalized aliens, 
using a statistically valid sample of the program' s case load,
(3) "
any other reliable method of cost calculation, subject to
Federal review" (45 CFR 402.21). We have made available to 
states a Cost Documentation System, initiated by HHS, which will

enable them to establish costs based on a blind match of social

security numers of 
program participants. We have worked with 
states to develop other alternative methods that do not involve

inquiring into the immigration status of any individual. We have

distributed information on these alternative methods to states.

Page 9 . (Program Costs) -- The draft report states, "Los Angeles 
County staff indicated they had not received instructions from 
the state on how to determine allowable program costs. The 
county will capture whatever cost information the state requests. 
Orange County is also waiting for state instructions. Once 
quidelines have been issued, the county intends to negotiate with
the state on methods of determining ratios and samples. Santa 
Clara County, not having any state instructions, does not know 
docuent these costs. 
what costs to claim or how to  The final 
report should note that acceptable methods for determining SLIAG 
and program administrative costs are outlined in Federal 
regulation. The regulation at 45 CFR 402.22 permits use of other 
methods for determining program administrative costs that will 
document that these costs are "allowable, allocable to SLIAG, and 
reasonable. " 
Page 10 (Drawdown of Funds and Cash Balances) -- The draft

report states that "Up to a 25 percent advance can be made to a

county. 
primary care clinic or small  Since payment is made by 
reimbursement, it is unlikely that large cash balances would

occur. " These two statements appear to be contradictory. We

s limited

request that the final report clarify whether payment 

to reimbursement.

B-S
 ::::, ?,;:'. . ._ :';: ::;,:-..; ' , :;.':,-..,.:- ""';"- ::..:,,..-:.! ':, ,:';.,_:",:..,":':\. ":'..- '.'.: -.:.."-..:' ':.._::..":...-.~~~~:'-""_ -'- "''''
oJ"	 i.'h..,,J.,-, ..'t: 
Education: 
Page 11 and 12 (Administrative Costs) -- The draft report 
indicated that "An Orange County community college has no 
costs. 
guidelines from the State to determine administrative 
Another section under Education, the draft report cited, "In 
other areas reviewed in California, schools were improvising 
methods for claiming administrative costs.  The final report 
should note that acceptable methods for determining SLIAG and 
program administrative costs are outlined in Federal regulation 
at 45 CFR 402.22. 
Page 12 (Crosscutting Issues) -- The draft report states, 
"According to final regulations published March 10, 1988, States 
had to submit the FY 1988 application no later than May 16, 1988. 
Revisions to the application had to be submitted by July 1, 1988, 
and the FY 1989 application had to be submitted no later than
July 15, 1988. 
Applications were to contain brief descriptions 
of the State's programs or services, estimates of the State' 
that
SLIAG-related costs for each program or activity for 
particular fiscal year 
(including information on the numer of 
eligible legalized aliens residing in the State), and a brief 
explanation of the methodolog used to estimate these costs. 
request that the final report clarify what are the pertinent 
issues the draft report wants to address in this paragraph. 
Findinas  (Daae ..): 
Finding:	
Since 1987, FSA has held national conferences and 
issued information to States on implementing the SLIAG 
program. 
Comment:	 Since the OIG's onsite visits in August 1988, we have 
continued to provide assistance to States. We have 
conducted several more workshops and meetings to assist 
states in implementation. In October 1988, we issued a 
compendium incorporating the extensive formal guidance 
previously provided to States on methods of cost 
documentation. We also have provided assistance to 
individual States in the form of correspondencft,
telephone consultation, and onsite technical 
assistance. We are in the process of conducting

initial program reviews of the major States, including

California, which we visited in April 1989. We

request that the final report reflect this continuing

dialoge with States. 
Finding:	
California established a structure to identify 
organizational and program needs. 
Comment: It is not clear from the description of these steps

that the statute and regulation limit use of SLIAG funds for
 .:..
. .
- - '... L..  -:-: :'. ''-. '':  :':"-.- ':u	 . - .- :, - .." ". ' ' ."".. ,-  :--_,:',::.." ':.: :,....:,;..:'  ':;.;:':_",, ;_- "':"'-':::'':':'P::-'  "4. '"':' '::; : :" -:__.._.";..,.I  :. -, -- --_. -'._,, "'--'- .._
to' &Octivities that 
public assistance and public health asshfcance 
are "generally available. 
This means that states may not use 
SLIAG funds to set up public assistance or public health programs
specifically for "
eligible legalized aliens.  The final report 
should make clear how this requirement relates to the state 
report. 
actions featured in the draft 
RECOMMNDATIONS 
FINDING	 The FSA's policy of denying payments for 
services rendered by community-based 
organizations and qualified designated 
prior to the state I s application 
enti ties 
approval date caused difficulties for the
state. 
RECOMMNDATION	 The FSA should analyze the effect of its 
pol icy to deny retroactive payment to 
community-based organizations and qualified 
designated entities for services rendered in 
good fai th, and determine whether a 
modification to its position would be
warranted. 
RESPONSE	 since the OIG inspection, this issue has 
been resolved. State was informed that 
there is no federal prohibition against 
entering into a contract or other legal
instruent with  ty
providers of communi 
based primary care or educational services 
with the effective date of the contract, or 
amendment to an existing contract, predating
the date of execution of the agreement. Such 
an agreement would be acceptable provided 
that the execution of such an agreement were 
permissible under state or, if applicable,
local law. 
However, nothing in Federal law 
or regulation requires that a state or local
governent 
assume costs of private providers
who serve ELAs. We furter advised the state 
that costs incurred under such contracts 
would be allowable under SLIAG only if they 
met all applicable regulatory and statutory
cri teria. 
In particular, we cautioned that 
costs under such contracts will have to be
fully docuented and 
would have to be 
reasonable, allowable and allocable to SLIAG. 
state was further informed that documentation 
of all costs under contracts vOluntarily and 
belatedly entered into by State or local 
governments meet the standards outlined in 
the regulation at 45 CFR 402.21. 
B-7  . .
. .
.-.--._ ,. ', ;':.::- ).. ,..,:  ' .,-_. ";-:;':'. _ - - ' , ' - --._ , , :' :, ,, . --:, ' .._"";_..., :;-"-':, )': ;':. !.:::.. :..- ,;::;, ;.. ::.':---' :. .-,;-..-,..' . _.,
i::,	 :i.  'A.'  .:L':,  ';''i.\.;..:.L.',- .J;  .:-i,  ':/;:.J, 
Conflicting interpretations i,t  the" term-" 
FINDING 
public charge" has caused uncertainties for 
aliens as to what services they are entitled 
to receive without fear of deportation. 
RECOMMNDATION	 The FSA and the INS should further clarify 
what is meant by "public charge" and widely 
disseminate this information to the aliens 
who have raised concerns about their resident 
status. 
RESPONSE	 Under IRCA and the Immigration and 
Nationality Act, the INS alone is 
responsible for determining whether 
individuals are likely to become public 
charges. FSA cannot establish policy on 
this issue. Nor can FSA disseminate 
information directly to the alien
population. 
INS is precluded by IRCA from 
providing names and addresses of eligible 
legalized aliens to outside agencies. 
However, we agree that it is important that 
all concerned know INS policy on the public 
charge issue. INS representatives have made 
virtally all 
presentations at  of our 
At these 
workshops and conferences. 
meetings, States have been able to ask 
questions and receive direct information from
the INS. We have communicated to states all

information provided to us by INS on this and

other pertinent issues, and will continue our

policy of disseminating any relevant

information that we receive.

The Department also has indicated its

support for a legislative change to allow

States to use a small portion of their SLIAG

grants to inform temporary residents of the

requirements for adjustment to lawful

permanent resident status and of the rights

and responsibilities of lawful temporary

residents. Such use is not permitted under

current law.
 ~~~ ~~~
--  .:::-:..;:.: ~~~ J;...::;.: :._ ';  ,-.. c.,. .."...'''':' :''':-_ " ...:-,,, - :"- .,,,, :,,),,--,,,",.--,:.,;,.. ,"".'., . " :"-" ';--./  ...' ,:-:.._-.1';  -'':r- "".c,
APPENDIX C

CALIFORNIA'S COMMENTS
 " . ,.. .

.. ,.
STATE OF CALIFORNIA 
Governor 
. GEORGE DEUKMEJIAN. 
HEALTH and WELFARE AGENCY 
OFFICE OF THE SECR

1600 !'ili..TH STREET, R;:,  ,,; .;S 
Sacramento, California 95814

(916) 445-6951 
1989
SEP 
Instor 
Richa 
General 
P. Kl1sserCM, Instion 
Office of Anysis & 
HH Office of Inspector  neral 
Ro 
Cohen Bu lding,  5660 
330 Indepndence Avenue
Wahingon, DC 20201 
De 
Mr. 
Ku..c=:sercw: 
Put 
an 
to your reqest  subtsheq ent disclls.cc;ioon nwit tsh  Mr. Hugh (Mns of 
yo  sllbnittiDJ  enclosed 
staff, I am  which constitute 
Californa s resnse to yo drft instion report, "Imlementation of 
the State Lelization Asistance Grants tmder the Immigrtion Reform 

Control Act of 1986 - State of C.alifomia.

It was a pleas to work wi tthh yiarrJ :rre isetwaff  owfh oa w berroea dth oscrooupgeh olyf  
profesional an well orgnized in 
affecting Caiforna s imlemntatioyn oof  IRCA. If 
issues and procefduurtehsr  acsiostatnsc,e  to yo in the reiew of  drft or 
I may be of any 
the explication of ollr  pleae do not heitate to telephone me 
at 
(916) 445-0196, 
Sincerely, 
RICH A. EPIN
Spial Asistant 
Enclos 
cc: 
Ka 
Hugh R.
City, K) 
Normn L. 
DHHS  .:, :;.'. - :.;.. " '.:::.:: , ..  --:, ''..-  :. :: ' ::': "::;.- _:. .. -, ',... - ' .' -, :' .:.  ,,, . .. " .,,' -,,-" _: .;: - " \.  . - "' :"- - . , , .. '- -..... -.,, ''- ' ..: ,. ,-;",-'-, - -.':... ' '..
u -- '  .-:c'- ''':'i.,  ' _d  t.  J;_  0 .  '"'',--P'. 
Slate or Callrornla  Departmenl or Educallon 
Epstein 
Memorandum 
To: 
Richard  Date:  6/27/89 
From: Rlcharo L StIles. Manager\ 
Amnesty EOucatlon Offlce 
merly the IRCA Unlt)

Subject: 
Education Response to Ofrtce of Inspector General 
Draft Report 
The following is the Department' s response to the Oraft inspection report 
Implementatlon of the State Leaalization 
ImDact Asslstance Grants Unaer 
the !mmlgratlon Reform anO Control Act of 1986 - State of Callforma" The 
comments 
IncluOe correctIon of erroneous facts ana actlOns taKen oy tt,e 
Department subsequent to the August 1988 conclusion of the report study 
riod, 
1) The report should indIcate the report study period on the cover 
page and

as part of the executive summary, I t would be appropriate to insert the 
tlme perIod In the last sentence of D3ge 1. !t snouJa be mentIoned 39 
tne reDort unaer Memoaology 
page:2  ot 
2) The Department of EducatlOn has renamed the IRCA Unit the Amnesty 
Education Office and it is located in the Department's Curriculum and 
Instructional Leadership Branch. 
The Deputy Superintendent is James 
Smith, The speclflc division 
Migrant ana Amnesty EaucatlOn DivlS10n
IS  tt'e 
wIth John R. SChaeffer as DivISIon Director, i recommena msertma on pace 
, thIrd line - At the time of thIs study -
Defore tne secona semence 
beginnmg w1th "The IRCA Umt" 
3) The Amnesty Education Offjce provides grants to local educatlOnal 
agencies. Therefore, substItute the word "grant" for " first 
contract" 1n the 
line of the second paragraph on page 3 and all other places the word 
contract is used

4. The Department conducted workshoDs for all educational service 
provlOers. ine wora " scnool otTlclals" usea unaer me 
tlrst cuilet on page 5, 
tends to 1mply only pUblIc agenc1es. Smce Callforma s educat10nal system
consIsts of a coalition of private 
and pUblic providers, I recommend  ~~~
. _ :.. ,-, :/':':'-: - ").:::.. .--=: ,-:., ,;, , ; :_ ..");;'_:-:;:.\:::::. ': . .' ' !,,:::' .-,:,.:.:::..' " ;:"" ; -," ' --.." : .:... :'... ::'.:. .,-,. :",.-'';,::.. ';-",::;;,,,~~~~ ::,:;..
:i.- j'J :i:'  i.: :.i. r.:-
SUbStItuting the term "
educatIonal servIce providers" for "SChool offlc1als 
nere ana throughout the report. 
3) 
The report states on page 10 under the head1ng - Documentation of 
Eligible Legalized Allen Status - "At the present time, no statewide record
keepmg system exists for determlnlng who are eligIble legalized aliens who 
qualIfy for progrfams under SLiAG. Although it 1s correct that there was 
data management system utilized by the 
educattonal service providers 
dur1ng the study report period, the IRCA Pre-enrol1ment Instrument was 
being reviewed by various state agencies. The pre-enrol1ment appraisal 
developed by the Comprehensive Adult Student 
Assessment System (CASAS), 
was ready for distribution by late fa11. The CASAS project conducted 
workshops throughout tt'e state to provIde training In the use of the 
Instrument. 
AgencIes were  materIals and ongoing
provIded with  free 
technical assIstance. The pre-enrol1ment appraIsal process provIdes
information on students 
educat10nal history, salient demographic 
characteristics. and data supporting temporary residency status. 
addition, potential students are educat10nally appraised to determ1ne their 
ability to speak and understand Engltsh and knowledge of the history and 
government of the United States. The data col1ectton form clearly 
identifies the A number of the student and whether the student IS adjusting 
as a pre-82 or 
SAW. 
4) The section, Program Costs, on page 11, the second paragraph of the report
states that "
the State made 
its definition of al10wable costs very 
restr1ct1ve.  It needs to be clar1f1ed why these costs were narrowly 
defined. For FY 1987-88, there was no budget language governing al10wable 
costs. The Governor s State of the State Address for Budget Year 1988-89 
offered gUldel ines for al10wable costs tt'at only IdentIfied assessment as an 
allowable cost above the service hours provIded multIplIed by the statewIde 
average revenue limIt for k-12 adult educatIon programs computed on an 
hourly basts. Therefore, the original  this 
approvalletter was superceded by 
airective from the Administrat10n. Agencies were sent a second letter that 
adv1sed them of the allowable costs. ThiS paragraPh is also confusing 
because it only discusses al10wable costs in terms of ancillary costs. 
does not ment10n that a11 tnstructional costs incurred by el1g1ble newly
legalIzed persons are relmburseable oy muitlplying the servIce hours by the 
statew1de average revenue  adult 
I1m1t for k-12  education programs 
d on an hourly baS1S For 1987-88.. agenc1 s wer  ab1e to clalrn 
c: ('ompl.t 
'to) 
per instructional hour. 
5) The bottom paragraph of page 11 discusses adm1n1strattve costs. Th1s 
section 1s m1sleading because tt discusses state operations budget and local  0, '
~~~
; ,, ;' :;" ::. .-"- :(:;. : . . '.:.,.: :: . : - --, ,-, , . ... '.. .._- - : "':'... "". .':::::.:.,-,:,-,... , ,. '--' '-_.; :;;, '. :;:.;.:: ::. ":-",.."
':';":2  : 1:- i,  ..::.: ..1 
il  ~ 2 
provider administrative costs as If they were governed bv the same prov1so. 
In fact, only the state operations budget IS limited to 1.5% of the total 
educational costs. Local educational providers have no such limitation, The 
California State Department of Education School Accounting Manual clearly 
def1nes budget classifications and al10wable expenditures. AI1 public 
agencies should be familiar wtth this document. 
6) The second paragraph of page 13 correctly detailed the major problem 
faced by community-based organization and Qualif1ed designated entities 
that prov1ded health and educational serv1ces 1n "good faith" to eligible 
legalized aliens in 1987 prior to the approval of their application. The issue 
was final1y resolved in late fall , permitting the Department to correctly 
reimburse these agencies for costs incurred between October 1 and May 31. 
However, the delay m receipt of funds caused serIous cash flow problems to 
private non- who had limtted resources, 
proftt provIders 
7) The executive summary, page iii 
, indicated that state guidelines are 
needed to determ1ne allowable costs In publ1C health assistance and 
education programs. I support this finding, however, stronger emphasis 
should be placed on the fact that Cal1fornia was the only state to offer 
educational programs in 1987. There were no final regulations from 
INS, 
and SLiAG leglslatlOn was stil1 bemg defmed and Interpreted. By December 
agencIes were provIded wIth gUldelmes for clalmmg allowable costs. The 
Department conducted several regional workshops with providers 
to explain 
how to claim allowable costs. The Department focused particularly on 
pr1vate non-prof1t agencies, offering 10 reg10nal workShOPS w1th1n a two-
month period. The Department wil1 publish a Program Operations Manual on 
or before October 31 , 1989 to further assist providers. I have no Quarre I 
more clarification of the sltuation 
with the finding Out argue that  IS needed. 
Th1S fmdmg  page 13 of the report. In the last 
IS further d1scussed on 
paragraph, they ment10n that Orange County staff  waiting for state 
instructions. I t further states that "once guidel ines have been issued by the 
State, Orange County staff 1ntend to negot1ate w1th the State on methods of 
determining ratios and samples. The paragraph does not indicate if Orange 
County staff are from pubHc health assistance or education programs. 
EducatlOnal service providers already nave an accountaOil1ty data 
in 
management system  place, the IRCA Pre-Enrollment Appraisal. 
Therefore, they do not r'eed to negotlate wHh the State on methods of 
determining ratios and samples.
 , ,- ; . ,,,,- ':' ':,,:--..-.-., :,:; :::. - ;"':.. ':.': ,.. '",_ ::' ;..; ..-",-;; ..  '- . :, -.  ::" :' , - '." ,"~ :.  :- ,-,'-" ''',, ",;"" ,:;:,-::.::.-..":........ ..  ' .  ;-'
c. '  :'f!.,  .:c.:.:.;"'  ::,L.  ';2.-
Ste 
of Caifornia 
Healtb and Welfare 19eD

MEMORANDUM 
To:  Richard Epstein 
T';;t.  June 28, 1989 
Spec ial Assistant - IRCA 
Heal th and Welfare Agency  Subject: 
Office of Inspect 
1600 Ninth Street, Room 450 
General (OIG)
Sacramento, CA 95814 
Report on the 
Implementation of 
SLIAG 
From:  t of Social Selces 
Attached are the Department of Social Services' 
(DSS) comments/suggestions to
the OIG report. Our overall concern with the report is the OIG' 
understanding of the roles and responsibilities of DSS under the State 
Legalization Impact Assistance Grant 
(SLIAG). We hope that these suggestions
will clarify the roles and responsibilities of DSS in administering and 
managing the SLIAG program. 
If you have any questions, please do not hesitate to contact Ana Lissa Muniz 
of my staff at 4-1568. 
ch1e 
Immigration and Resettlement

Managemen t Bureau
 omments  Suggest 
lifornia  Organizational Structure 
We recommend the following language on the second
paragraph. 
In Cali forn ia, th e State Departm en t 0 f Soc ial Serv ic es 
(SDSS), the State Department of Mental Health (SDMH), and 
th e  State Departmen t 0 f Housing and Commun it Y Dev el opmen t
(SDHCD), are responsible for some public assistance
progr ams; th e 
State Departmen t 0 f Heal th Serv ic es (SDHS) is
responsible for all public health and other public
assistance programs; and the Stattieo nDe.p artment of Education 
(SDOE) is respon sib le for ed uca  Eac h agenc y will 
request funds from the Grantee Agency, which is the SDSS. 
Sta te De partmen t  Soc ial Se rv ic es
of 
We suggest the following language for the third paragraph.

The State Department of Social Services (SDSS) is
responsible for administering (Grantee Agency) and 
level. 
complying with SLIAG functions at the State 
The 
SDSS, headed by a director, has eight divisions. The State 
Legalization Impact Assistance Grant (SLIAG) functions will
reside in the Welfare Program Division. Within this 
division, the Immigration and Resettlement Management 
Bureau has been assigned the dual responsibility of
functioning as the Grantee Agency, which includes 
coordinating data collection, preparing reports to the 
Federal and State Government, disseminating information to 
other Immigration Reform and Control Act (IRCA)/SLIAG

Departments; and program administration/management of 
related public assistance services to eligible legalized
aliens. 
istance 
Public Ass 
The programs mentioned in the sixth paragraph do not
incl ud e  tiv it ies/serv ice 
assistanalcle t. hI ne  ae  s funded under public
addition, the adoption program and the
child abuse stud ie s are not funded or a pprov ed ac t i vi ties 
in the SLIAG Federal Application.

C-
 - : :. ; :-::::!,;. ~~~~~ :;p:. .  :.-,:- ::  ..\' :"'.. ... :;: . ::::. ':: ::. :",.'::  ,.. .'- .. .. _ -,-,,;' ,._ , -_-- ;,' . .:.._ :". -,-_ ", '..- . .:;:::--::;.:':::""- ,,' ';/~~~
i.  ..E  i::i.'  :J  2U.il:.,.. 
I.' 
Balances 
Drawdown of Funds 
f! 
The third paragraph on the drawdown process is not

accurately described. 
The attached flow chart clearly 
in California. 
illlustrates the drawdown process  The 
process: 
following is a brief statement on the drawdown 
The SDSS is responsible for the Grant Management activities

funds. 
which include the drawdown of Federal 
The SDSS developed and executed a Memorandum of

Understanding with each Department to ensure the timely

drawdown of IRCA/SLIAG Federal funds and to delineate each

others 
' roles and responsibilities. 
ctices 
Good Pra 
The statement on number three does not include the

SDSS' role and responsib lity  as a Grantee Agency. (For 
additional comments, refer to our second paragraph on
Page 1. 
C-7
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ATlc)J, 
"RECUE' .  . ..
Caia 
Sta ." 
Department of Health Seices 
Memorandum 
pstein . 
: Richarcf '  Dae : July 5, 
1989 
Special Assistant to the Secretary

Health and Welfare Agency  Comments on Dra 
Subject: 
1600 Ninth Street  DHHS Inspector

General Report on

the SLIAG Program

In California Dated

May 1989
m : Peter Abbott, 
County Health

8/523 
The following responses are provided on the Draft DHHtSh Ines pector
General (IG) report entitled "Implementation of  State
Legalization Assistance Grants under the Immigration Reform 
and 
Control Act of 1986 - State of California"

Finding (Pg. 8):

DHHS 
Pulic  ti ve 
health assistance programs need defini  quidelines

aliens. 
from the state on how to identify eligible legalized 
Response: 
In the 
and 
the 
year that has elapsed between the IG visit 
in  report, California has made significant
psutbrliidcaetsio n of their 
establishing financial reporting 
systems
local 
responsive to federal requirements. All  government
agencies 
claiming SLIAG reimbursement for public health and
public health  associated with 
assistance costs  providing
services to eligible ' legalized aliens  based 
(ELA' s) 
documentation or statistically valid sampling have been 
the 
provided with  Family Support Administration'  (FSA)
goufid ance on the documentation of ELAs contained in Module
the FSA publication entitled "State Legalization Impact
Assistance Grants - Establ ishing and Reporting Actual Costs" 
(DHHS SLIAG manual). Additional guidance was promulgated 
a program by program basis (for example, see attachetdo "M  ISP"
Counties LIMA Guidelines - Fiscal Year 1988-89"  meet 
;nique situations.

All agencies have been advised to maintain photocopies 
the cited information  When this is not possible, they have 
been advised to annotate their files that such documentation 
the 
was in 
alien  fact viewed in each instance and to record  INS
registration number from the documentation that was 
viewed. 
C..9  ~~~
We are 
in an 	aware that this documentation requirement may resul t 
associated with 
serving
ELA I S or Cier.s&tatecmenot urage ELA 	 ilizing available services
because of the uncertainties m u
 surrounding the
and confusion 
public charge" issue. However, we see no other option given
the 
DHH requirement. 
DHHS IG finding (Pg. 13):

state 
quideline. are needed to determine allowable costs
public health assistance and education programs.

Response: 
Guidance on allowable SLIAG costs contained in Modules 5 and 
of the DHHS SLIAG Manual has been made available to local
government public health assistance programs seeking 
SLIAG
reimbursement. As  , additional guidance 
indicated above  was 
promulgated on a program by program basis (see attachment). 
Woef a lso note that the report states on page 7 that the Department
Health  costs using 
sheets.  Services documents administrative  time
This  fiscal year 
was the case during State  1987-88.
Beginning  staff 
7/1/88 the Department began directly allocating 
resources to SLIAG administration functions, allowing associated
personnel services and operation expense costs to be directly
captured' by its automated accounting system. We expect to use 
this system throughout the remainder of the SLIAG grant. 
We appreciate the opportunity to comment on the draft report.
you have any questions, please call Mike Rodrian at 5-1161. 
Attachment 
cc:	
Darrell Doty 
Audits Coordinator 
Accounting Section
8/1160  .. ., '''' .,,,"' .".  ....  :. - :::. :;.:::. ''" ' .' "' ' ::j. -::. . . .. ; . ..-'._...:._:.,:..:,..-.:::_..;.': 
;io 
EXHIBIT C

MISP COUNTIES

LIM GUIDELIl!'rS 
Fiscal Year 1988-89

These guidelines are for the State Departent of Hea(lLthI S)e.r vices 
(DHS) Legalized Indigent Medical Assistance Proqram  LIMA 
is the State' s program for reimbursing counties for unreimursed 
care 
persons eligible
heal th  services paid for or provided to 
under Section 17000, Welfare and Institutions Code (WIC) and who
have 
become leqalized residents under porofv isions of the Federal
Immigration Reform and Control Act  1986 
guidelines cover only LIM  fo(rI RtChA)e .  These
expendi tures  iod
July 1, 1988 through June 30, 1989. For additional information,
please contact Gary Miller at (916) 445-0188. 
PURPOSE. ALLOWABLE USES OF LIMA FUDS 
LIMA funds, which are ; federal
provided to the State through the 
governent' arSet ate Legalization Impact Assistance Grant 
(SLIAG)
proqram, 
intended to reimburse counties for actual 
unreimbursed costs of  care services provided to
IRCA-legalized persons  heal th eligible for 
who are  services under 
restrictions:
SLIAG funds are subiect to these 
Section 1  WIC. 
i.OOO 
or 
o SLIAG funds may be used only for programs  activities 
which are generally available to the citizens of the State. 
services for 
Scope of  IRCA leqalized persons must be
identical to services provided to other program recipients. 
all 
Unreimbursed costs are actual  applicable
costs after 
revenue  subtracted. 
and reimbursements have been  Claims
may include direct  costs 
unreimbursed administrative  and
eligibility 
costs. 
coissts 
o Counstiees mrusvt acicocunte fors th e differences cbethweean r
 aes  for services if charge data  the 
Rbaespiso rfto. rand   computinq all or a portion of the LIMA Cost
In most instances provider charges exceed costs; 
LIMA can only pa::t'  costs.  Counties are required
for actual
 relation
ttoo  explain their method of ascertaining costs, in 
charges; 
generally, a ratio is applied to charges to
determine costs. For further details, please see reporting 
form instructions.

be 
o In order to  SLIAG reimbursable,  services must be
provided only to persons who meet all  existing  program 
cost. 
requirements, including share of 
to 
funds  be used 
o LIMA  may  reimburse eligibility
as 
determination and administrative costs, as well  for 
costs of providing health care services. (See next two  . '
' .
. .
~ ' ..  ...
EXHIBIT C

section  information). 
for more detailed eligibility 
o :  1.ru.::t1: .  costs must  determinecl .(4.  :t.  ordi:nce with
allowablei . ;f:ie v..deral regulation ' \... C1  Part
and Part 402. Indirect Cosestt sf moruths t ibn e4 5d eCtFeRr mined in 
accordance with A-87 guidelines as established by the 
of 
Affairs 
Division of Local Governent and Fiscal  the 
state Controller'  Office. 
o Administrative costs related directly to the medical care
of 
IRek legalized persons should be  into patient
buil t 
tchosatst.  LIMA administrative costs should include thoosfe  costs
are directly related to the administration 
SLIAG
Grant Fuds, i. e.,  record 
planning, consulting,  keeping, 
data collection and cost report preparation.

LI 
abortion 
funds cannot be used to reimburse costs of an 
s life. 
unless the abortion is required to save the mother'
pay 
o LIMA funds cannot be used to  IRCA-legalization
' or  the 
application fees fees for  medical examination 
legalization. 
required for IRCA 
are for 
o Costs reimbursed  heal th
under these quidelines 
services (including administrative costs, a1nd, e ligibility
determinations) provided between July  1988 and
June 30, 1989. The  used must 
method of accounting 
consistent from year to year of claiming. 

o Costs  federal reguIations
claimed shall meet applicable 
pertaining to  Pulic 
the implementation of section 204 of 
Law 99-603.

SLIAG ELIGIBILITY REOUIREMENTS:

are 
o Counties receiving  responsible for
SLIAG funds 
status 
identifying and documenting the IRCA-legalized 
persons 
whose health expenses are claimed for LIMA
reimbursement. The  person is
only certain proof that a 
card 
IRCA legalized is the Lawful Temporary status  1-688 
(green card.  If the I-b88 is unavailable, 
the Employment
Authorization card  provides indication
that  I-688A (red card) 
the person has applied for legalization and paid the
application fee.  of 
persons
However, a small percentage 
receiving the I-688A card do not receivcea trhdei.r  lawful 
temporary resident status and the 1-688  Another 
legalization is
indication that the person has applied for 
the . Immigration and Naturalization Service computer printed 
application 
document verifying payment of fees required for 
status. 
for temporary resident 
o Counties should retain copies of  documentation  used 
establish eligibility.  ;;r:.:::t:	 ::.' ,. :;c  ... :,; 2::-3, /S;/  :;.:.,:.: ,.. ..::..!::  :'  .-lJ2 : :.'. ;;: :i,  ;... "-,,J..-;;";:!.' '::';''':';-., i..:..  :;".:,.; ' ...!._".t, ;,;..;..;', :. . -' - " -' ''-:C.)' ' -..-.. ' ...,.~. :,, . 
EXHIBIT C

o The effer:t:ive r\at	 is 
f legal status ":1:: 
individu  fee. It  or her applitcl abe ttheion and - paid the
required  filed' is important for providers to check the
issue date and the expiration date of any docuentation 
provided to ensure that the person who received services
did 
status 
so on or after July 1, 1988 and had IRCA legal 
on or before that date of service. 
IRCA-LEGALIZED PERSONS AN CATEGORIES OF HEALTH SERVICES ELIGIBLE 
FOR LIM REIMBURSEMNT AR AS FOLLOWS: 
o Unreimursed 
county costs of health care services reqularly 
provided to IRCA-legalized persons eligible for serv.ces 
under Section 17000 (WIC) in the county, (including MISP) . 
o Unreimbursed county 
costs of providing non-pregnancy
roelantedl  y. 
health care to IRCA legalized pregnant women 
are  who
Medi-Cal beneficiaries for pregnancy related services
o Unreimbursed county costs of providing non-emergency health 
care to IRCA legalized AFDC linked persons, who are 
Medi-Cal beneficiaries for emergency services only. 
o County administrative and eligibility costs associated with

providing healtn 
IRCA-legalized persons
services 	
eligible under Section 17000 (WI C) . 
DOCUNTING HEALTH CARE COSTS 
of 
payments are  services to
based on unreimbursed costs 
IRCA-eligible recipients of  services under Section 17000 
(WI C). 
Counties will therefore want
 to document these costs by recording 
he following:	
o Patient identifier--
name, county numer, Socia  Security
numer (if any), etc. Please obtain patients'  Social
Security numer 
(SSN) whenever possible. These SSN'  may 
be useful in the future for claiming unreimbursed costs. 
o Date, location, unretmursed cost of the service provided. 
o Method of verifying the patient. s IRCA status. Preferred
methods: photographic or  sides of 
xeroxed copy of both 
Faolrime nI-)6 8o8r  (temporary resident) or Form I-551 (resident
other document verifying the individual'
immigrant status, and/or notation in case or program files 
showing the person'  Alien Registration Numer (I'A"
of 
numer), 
date, and expiration dates  the
the effective 
documents, and date(s) the individual received services.
Not recommended:  status. 
self-declaration of immigrant  . .
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.. J _  fJ'-7.  l ,.  - -:.-- n  r.,,  O. - 'J . 'n. 
EXHIBIT C

of 
Counties may document the 
(visits,  nUmQ 
IRCdA-reeimtbuersarblme uniinations) either
by  inpatient days, and eligibility 
sample. If
actual record or by use of a statistically valid 
tthoe  lfaetdteerr ails  usedl,i ntehse,  satnadti asntiyc arle vsiasmipolnisn go mre thod must conform
Departent qouif d eH  ealth and Hum  modiinfidciactaitoends  ibny 
Services as 
"MODUL 13" , SLrG Guidelines, attached. The Department should
be 9i ven an explanation of the sampling technique 
Audi t 
exce  tions resul tina from use of a sam  na method museud. st be borne 
bv the countv.

IRa-reimursable units 
The costs of  may be documented either
reporting actual  of services or by 
costs/uni ts  determining an
average cost per unit of services. 
Costs may be computed based
tohn eth e actual costs associated with specific LIMA patients or
costsav meruagset  pcrosotv iodfe  sear vriecaes oinn aab lper omger&asmu rore  aocft i avci totufya.  lA cvoersatgse. 
cost 
Averaged costs should. not exceed the total  services 
associated with LIMA patients.

In 
costs, the county 
arriving at county unreimbursed LIMA  must
reduce medicoalr c are costs by any revenues and re imbursements
received by  on behalf of an IRCA legalized person, e.g.,
party 
Medi-Cal -reimbursements, Medicare, third  reimbursements, 
share of costs payments, fees, or other payments. 
LIMA ON AB8/MISP SCHEDULES

the 1988-89 fiscal year must be
LIMA funds paid to the county 

reported both on MISP and AB 8 portions of the 1988/89 Estimated
Actual 
and Actual Financial Data Reports. 
For the 1988/89 Plan
and 
Budget, if estimated LIMA costs and revenues/reimbursements
are 
known, these should also be included. LIMA costs claimed 
are shown as expenditures: LIMA payments received from the state
and reimbursements from patients and third party payers are shown
as revenue. Details 
about MISP and AB 8 budget schedules can be
found in guidelines for the FY 1988-89 County Heal th Services 
Plan and Budget Update.

APPLICATION FOR LIMA FUDS AND STANDARD AGREEMNT 
In 
order to receive LIMA fUnds, a county must enter into a LIMA 
submit the
A9reement for 1988-89 LIM funds, and complete and 
appropriate cost report  Departent on  timely
forms to the 
bas is . 
The 
LIMA Agreement must be signed by the chairperson,  Board 
Supervisors, or designee.  ') 
, --..
:;,::: :", :.; /::-'-, :::. ::_ ;j,; .-  ;:, :.:..:.: y : :.:;: ::': ... -;'::...., ,":, ",:;;,-,:..; j ":';_":: .:, :::. / ' ' ..
j.L  ::J  jj;"e.:  /;;:i ";"j2.l&:..:  :'L ...  :0.'  L: '  l ::),  J,,  .'',;i,,  .:..-t';, 
KISP COt7IES 
TH 
GENERAL INSTRUCTIONS POR COMPLETING  LIMA COST REPORT PORMS 
YE 
FISCAL  1988/: 
LI 
unreimursed 
The MISP /LIMA Cost Report is desiqned to claim e 30, 
costs for btahes ipser.i od July  rcu;h J  1989 on 
quarterly  Please s1, u19b88 mi t separate reportsL fIor  each 
quarter. 
funds 
The quarterly reports are necessary to pay 
to the county and are due to the County Health Service Branch 
indicated below: 
Quarter Endinq September 30, 1988 - Due March 15, 1989 
Quarter Endinq December 31, 1988  - Due March 15, 1989 
Quarter Endinq March 31, 1989 - Due May 15, 1989 
Quarter  Endinq June 30, 1989  - Due August 15, 1989 
This  Actual Final 
report form is also designed for use as your  ort 
State Fiscal Year Cost Re  for the period July 1, 1988 through
June 30, 1989.  March 31i.n  1990
and is a cumulaThtiis vrepeort  irs eduep noo latrert  thoan f costs previously reported  the 
not 
quarterly reports and any addi tional costs  previously 
reported. This report will be used to make a final settlement 
LIMA funds. Please read the following instructions and the LIMA 
form. 
guidelines prior to completing the 
Section A -- Enter the name of the County. 
Section B -- Ptlheeas e indicate the quarter being reported or if it is

Actual  Year Cost Report. 
Final State Fiscal 
Check the appropriate reporting period (s) . 

This section  and utilization data. 
Section C -- provides cost 
on 
costs for services provided  dates
Please report 
within the reporting period. The following persons or
for 
categories of 
health services are eligible  LIMA 
reimbursements. 
o Unreimbursed costs of health care servicelsi griebgullea rly 
provided to IRCA-legalized  for
the 
services under Section 17000 pe(rsoWns IC) in  county, 
(including MISP) 

pregnancy
o Unreimbursed county costs of providing non-
related medical care to IRCA legalized pregnant 
preqnancy 
women, who are Medi-Cal beneficiaries for 
related services only. 
o Unreimbursed county costs of providing non-emergency
health care to IRCA legalized AFDC lfionkred  persons,
who are 
Medi-Cal beneficiaries  emergency
services only.  ) ,

. -. ::: ::,;..;:,:./:- : :;:  :\-::, .";-.j. :-:',,;).' ;-.,::: ;\.' ...:::" ,:' --:"::;::' .:,-:.:: . ::'::_: ,: .' '.:.::'':' ' ....;' : ':-- :.:, '""-"'"':!.' :. "'.';':-' :"),:,:'":.':,,; .,.=-.:.. :"","':'-. ':_::-,.';. . ,--" ",",:., "".
i..  i;;,	 :/J.:"jJ:i'.'.!i:,  :' 1 ,  'J,  --:o_.  .o:J.., 
Colum 1  numer of Patient 
-- Enter the total  Days, Visits,  and
Section 
17000/MISP Eligibility  tenuinj!Ji,=n!=  for 
the period covered by the report.

If 
Colum 	2 -- you are reporting costs ONLY (no  charges) skip
to colum 4, otherwise, enter the charges per day
and/or visit. Weighted average charges per unit
service are acceptable. 
If used, please explain how 
the weighted average charges were determned. 
Colum 	 colum 
If you completed  (charges are repotrote d) you
. must  ratio in order 
enter the necessary  reduce 
charges to costs. Please  explain how these ratio(s)
were determined. 
Colum 	4 -- Iefn tyeour  	tchomepl eted colums 2 and 3, multiply them and
If you are  this
resul ts.  starting in 
colum with costs, 
it should be noted that weighted 
acceptable. If
average costs per unit of service is 
weighte 
average costs are used, please explain how 
the amount was determined. 
Note:	 Administrative costs related to direct medical care 
should be built into the cost amount in this colum.
An 
example of administrative costs for this colum 
would be hospital or clinic administration.

-- If 
Colum  applicable, multiply colum  (units

services) by colum  service)
and enter 	the resu(lctoss.t sE pnetre ru ntihte o fc osts for 
administration of LIMA in this colum. 
Note:	 LIMA Administrative costs reported in this colum 
should include the costs of administering the LIMA 
program and must not duplicate administrative
costs reported in colum 
Colum 6 -- Report all RENUS and REIMUREMNTSo fre ceived 
(Medi -Cal ,f o	CMrP ,s tehrirvdi pcaersty,  Mor sIShaPre   costs,
etc.  eligibility
determination and LIMA administrative costs 
Colum s. 
claimed in 
the 
Colum 7 	 Subtract colum  results.

6 from 5 and enter 
This colum should 
unreimbursed

represent the 
county costs of providing medical care to persons

legalized 
pursuant to the Immigration Reform and

Control Act  1) indigents; 2) 
eligibility  CIRCA) for:  3) the  MISP

determinations;  unreimbursed

County cost of LIMA administration.

C-16
 ~~~~
'i=!;.  ''.;:':';. i.. :', ;,..--- ,,,,, ::':L.:"'  .J:,  ",-,;.-_. :., ...:.;.:r':  ,,"'_.,4"'-"'--' o:"- :_-,",,. ;...":L_  ....,-,...I"-' 
This section  disclosed
section D -- indicates how the data 
Colum 1 are docuented.  are 
Indicate if the data 
based on complete case specific records or  .:ed 
a valid statistical sample. 
for 
Section E -- Enter  each category, the numer of legalized
indigents served and indicate with a check mark 
it is an unduplicated or duplicated count. 
following: 
Section F -- This section provides for the 
the net costs 
Line 1:  The sumary of  previously
reported to the Departent, (enter a zero 
the State 
Fiscal 
for first quarter of 
Year) . 
Line 2:  The  current  costs being reported  the
Departent from colum 7. 
Line 3:  The  total costs reported to date  for  the 
state fiscal year. 
Section  submitting
G -- Tthhee p errespoon rrte smpounssti bslieg nfo ra npdre pdaariteng  thaen d report
indicated. 
bection  H -- mOnulys tth be eAc stuiagln Feinda al sntadte d Faistecadl  Ybeya tr hCeo st Report
. County
AUditor/Controller. This report is due not. later 
than March 31, 1990. 
and 
Complete the questions in this. section  explain
Section I -- the 
completing
thism ethodology and assumptions used in 
section is 
Cost Report. Completeness of this 
report 
required for the approval of the cost  and 
LIM funds. Therefore please be
disbursement of 
specific 
as possible in answering the questions 
this section.

-l 7  :..
)
 
.
-----------;;;;;
:;;:;; ................"" ......................... ..... ....................... ..... ;;;;: ;::;.j'.'.".'.".'. ..,. ;;;;;;;:.!......... !..... .... ....j". ..... "." ..... 'j' .......... "'. ..... ..... ..... !........ ..... ..... !........... ............... .......... ....,!. ..............;;;;. ;;;;,.... ....: ..... !... ..,.. ..... ..... . j'" ..... ..... ..... j' ;:. ;;~~~.. ...;;;. ;;	. ..... j. ;. ;..=..:;: .	~~~~;. ;. ' ;; ; :.;. ' ~~~~~~~~~.. . . . .. .. . .. ~~~~. . . . . . .. . . . .. . . . . . . .. ~~~~.. . . .~~~~~~~~~! . . . .. .. . . . . . . . . . . . . . . . . . . . - . . - . . . . . . . ! . . . .. . . . . . . . . ~~~~~~~~~~~~~~~~~~~~~~. ;.I MISP COONIIES .............................. .:-.: .......... ..... ..... .--.. ..... ..... ..... ..... ..... ...... .... ..... ..... ..... ..... ..... ..... ..... ;;j ..... ..	!. .... ..... ..... ...., .== =.... === =.. . . . ... . . ! .. . . . . . . ::. ::. I A. N/\E OF Co./Nn= e&: === == === == cc:ce. _:=ea ..as. 8cae:=esce c=== ...a: ..=:8 -== =: = = =s =e= =- .E : 2 === =S8 ..=:- .2 e:_:c =c=e: = e. eaaee =sa == ..:e: -=8=e .c2ee = .. ..... ..e:- D=aa:  REPOT 1988/89I FISCAL YEAR 
 01'26/09) (Rcv.I LEGALIZED INDIGENT MEDICAl ASSISTANCE (LIMA) COSTS 	a..== =e... = a... =..ae =e= ee e=: aa ...
..a............ ..... ..a.e =e=... .....82.. ..=.s ..... ...:. e.:e: a.:ee ;;;;: ;e=. =ee e.  cons rOR , 1988 . Due Hnrch 15TIlE QUARIER (NO I NG: SEP IEHnER 30ACTUAL UHRE IH8U1SED lIHA , 1989 
198 . Morch 15, 1969
COTS fOR TilE WARTER ENDING: ACTUAL UNREIMBUSED LIMA OECEHDER 31, HARCH 31, 1989 WARTER ENDING: ACTUAL UNREIHBUSED LIMA COSTS 'OR TilE . Due Hay 15, 1989 
, 1969 . Due August 15, 1989
THE WARTER ENDING: JUNE 30ACTUAL UNREIMBUSED liMA COSTS fOR JUy " 1990
Much 31, , 1989 . Due Y. REPOT fOR THE 1988 THROOGH JUNE 30fiNAL STATE f.PER 100: 8==-: ..s.=t.............. ...Dt ..... 
..=.....=................ .......... .......... as... COlUt 5 COU". 7 COlU4N 6 'OT
C. fiSCAL DATA COlll 4 I I COllJ 31 I D. BASIS Of I COUM :....s................."..."
lIttI COUMN 2 .... .a.828=s..........=a......................... 8=........ or 8..=...... ..C.. 8.8== ==Z=-
===. ..aaa ... a==.. I. COSTS I lItt ELIGIBLE REVENUES I UlREUIiURSm1U8ER Of 	TOTAL COONTY COSTS I RATIO I TOTAL TO I CHARGES PER I PER I (Check the COSTS I Of PROVIDING I or SERVICES PROVIDED REIMBURSEMENTS 	I PATlEIIT DAYS, I SERVICES TO IRCA DAYIVISIT I OR .ppoprl.te box), VIS ITS, I COSTS CLAIMED DAYS I RECEIVED BY co.nuy VISITS, TO (COC. 5. 6)REPOTED (NET COON" COSTS)I CHARGES I fOR COSTS I INDIGENTS LEGALIZED EliG. DETER. I IRCA I IN COLUM 5 
INDIGE..TS I .......a....s...... I PURSUANT TO I EliG. DETER. I lEGALIZED ........"...=Z .a=:= ==a:. ===:= ==-,
88:_:_==78..=8. =.... aa8.8 ..= ......................... ...e. ..:-. ...:- aD:== _:C8. ===2. '_:..8...= ..... Stottltlcal slIPle II ))1 	II 3)1	I (COL. Z IIReA M/C BENEflCIARIESI Case Specific
INO.EMERGENCY COSTS 	'.G'. ...1I"""". ..... 	..... ..... .G'.'. .... .'G.' .....
Statistical S8llel8ENEfiCIARIE	1-HIC I (COL. Z I'IIIICA  I . . . . .. .  I _ 17000,MISP IIICA I StatlsUc.1 s_plel(COL. 1 X 4) 	I (COL. 2 X 3)1 I ; 	I SECT . C.5e Spec! fie
I INPATIENT SERVICES  j ..... ..... i.. I;;	 ! ..... "..G St.tlstlcel 511,e (COL. 1 X 4)
I (COL. Z X 3) EMEIlGENCY SERVICES 	ISECT. 17000,"15P IRCA 	C.5e Specific..................0................ ..	.. ..... ..... ...1
I.... ..... ..... IXXXXXXXXXXIxxxxxxxxxI I (COL. 1 X 4) 
ISECT. 17000'"ISP IRCA I 	IXXXXXXIIXIIXIIXXXXIIKIIIIKXXI i;;;;;;;i;;;;:;:; -;;;;I
i;;;; i;;;;;;;; i;;;;;;;;;;;;;i..... ..... .......... . i.................. '	Of LIMA XXXXXXIIIIX I XIIIIIIICXXIIIIIIXX I 	IXXXXXXXXXXXXlIlIxxxxxxxl IXXXXlOlOXXXlOxlxxxxxxxxxx I G"" .......... .......... ,.'G. .......... ..'G' ...1
I'.."'.'. ..... .................... ..,'G ..... ..... ..... ...G. ..... ..... ..'G. ..... .'.'. ..... ..... ...G. ..... ..... TOT A l IxxlIlIlIXXIIXIIXXllllllllllllxxl IIIIIXXXIIXXII IXIIIIXXIIIIXIIKIIIIIII IIIXIOJOXXXJOIOXIXIIXXXXXIIII XICXXXXXIIX I XXXIIIIXIIIIII I XXXIIXXXXXIIIIXII I ........"."..."....2.. ..:.. IXXXXXIIXllllxxXXlIlCxlIlIxxl IIIIIJOJOIOJOXXXII I .....=. ..... ..... ..=....88...... c... .a.-:....= .... ......c........."....."............... CCDE: .. .==a..==_:  I E. 170,"ISP IReA IUBER Of 1=1 DUiCATED CON' ELIGIBLES SERVED: 1=1 UNtJlICATED COT  NUBER Of IRCA.AfDC BENEfiCIARIES RECEIVING
CONT CES	NO. EMERGENCY SERVI I DUL ICATED I UNOtJLlCATED COUNT  NUBER OF IRCA.MEOI.CAL BENEfactARIES, PREGNANW UDN RECEIVING NO.PREGNANCY SERVICES I DULICATED COJNT I UttJLBCATED COUN' ...:- ...ca 8C... ...== ===== -===: &=:== _=Z8 z... ........ ............... ..... aa... 2..:S ..-:- a.... ....- .e... ..... .E... ..... ..... ...ce K8e.. ..... ..... ..... . 828==  t :

 '
.
----'-. ................ .................... ..... ......'............................ ..... ..... ..=............... . .. . ..... ..... ............. ..... ..... ..... ..... ..... ..... ..... ,.... ..... .....;:' ; ..... .. . ;;; . ; . . .. . .... . .' .. . . . .. . .. . . . ; . .. .. . . .. . . . ~~~~~~; . ; . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . .. . . . . . . . . . .. ~~~! !~~~~........................................ ............... .==....... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ... . . . .. . .. .. ... .. . .. .. . : . ,. :. . ..aa . .......... ..... ..... ..... c...: r.c= ..
e...... .......... ..... ..... ......e.....eaa ..... .c.......... ...........c... ..... ...e. ..... .e ....s ..... ..... .....  .00" . 00 .00 .0000 . 00 00 . .00' .0000 .00 .. . . .. . .. 00 . .. 00 . . .... .00 .. .00 00 . . . 00 . . 00 .. 00 . . . . . 00 . .. . : oo. . .. . 00 00 . 00 .. .. .. . 00 .. .. oo. 00 00 ... :. . QURIER(S) 'I I. lorAl LIMA COSIS CLAIMED IN PREVIOOS 1900/09 
 .... . .... i ..  JU JUy I, COIS ClAl1U 30, 1989 10 DATE1988 IHROJGH FOR THE PERIOD I J. lOlAl LIMA .......... .................... ...ass..:. ........
......C:.8 :DS== :ZD== ...a. ..... ....-
..... ....: s.... _Ical ou cOlty In reprted care to Indlgenta
providing represent the actulII U1relnburled COlts Inc..red by I hereby cert Ify that the net C08tl It.pot I G.
.uch unel""raed cost.. . .
on file doUlentatlon to thllt the cOlty has legal hed pusuant to 1..lgratlon Reforl an Control Act(lRCA) end REPORI PREPARED IY PHONE NUMER DAlE PREPARED ................................... ..sa. 
..... .ess. ...s. ..... .................... ............... .E:.. Z..=. =. c.... ..... 8S... ..... ..... STAlE US ONL' ' (REQUIRED ON FINAL RErORI ONLY) COTROLER st.poted by IREVIEVED IT: knowledge. I H. CE.TIFICATION IY COUNT' AUDITOR 
Unelllrsed lIlI DAlE -
Cost ctal.ed above Is I hereby cert Ify that the Tota' bet of II DAlEOfflcla' Comty Records .nd IAPPROVED 8Y: 
t. ICcur.te to the  SIGNAIUtE OF AUDITOR COTROllER .'1 DAlE CERTIfiED IPAYMENT AUTHOIZED DAlE AUHOIZED AMOI AUTHORIZED: (or duly euthorhed rep.lentatlve 
with cop of offici a' authorization attached) ...8
......... ......""...".......=8S8CZ.. ..... ..... ..... ......ac.. .....c....  lAaa I. MATERIAL (ATTACH ADDITIONAL PAGES TO ANSUER THE FOllOlING QueSTIONS)  up the bo checked, plee.e ellplaln Depnding U1reillsed I. Oocunt In dete..lnlng In Section D. Cellplaln) the .thod used LIMA costa a. Indicated lamle. co.lete ca.e specific data or valid statistical the .ethod utlilled;  a. How wa. the laml e drawn?
estlonnlre.b. Plea.e IUblt the lamle 
Into accout the.e factorl:
S.-le take c. Does the freqnc
C I) (2) 'I.lng of lam'e(3) Tren over tIservice poplation (4) lamle II Ie In relation to d. Are the 8ethod u.ed 'oglca' en result In a statlltlcallv ve'ld .aMple? ..tiNted cost. In doing the lamle" e. "'at ..s the  In acltlon, t)p .. location of the 2. Docunt (ellplaln) the ..thodlogy Indicate the for when LIMA costl are cllilld. used to Idetify eligible. domentetlon which Is available for audit purposes.  an COstl wer, deterMine. 3. Please explain how chargel  docunt lIethod (Colum 3); recbed to costl by how each retlo was deterMined. using the ratio 4. If charges are ty, 8IUtt, en .ethod of 5. If couty adlniatrative cOlt. of pleale e.plaln the claill CColu. 5) which are not Included In patient COltl, LIMA are cants. aclnlltratlve cost deter.lnlng different  rehnbUsellts for please describe the Method used to speel flc patlenta, relllrletnts are 6. If revenus and not bosed on actual Individual reverues or 880ts of reimbusemets. determine the revenue or  ruer 7. Oocunt \!ect9oo U Nail deterlIOne. of users (Reported! Un cexpleln) how the 
 
n -----------------~~~;;; ::::::~~~.....-........................................................................................................................................................-.................... ............................. ............... .................... ..... ............... ..!................ .....~~~.................. ............... ..... ~~~............... ..... !.........~~~............. .!............ ..... ;;j'.".. . !............. ..... ..... ..... ;;;;. !...........:- ..... ..... ..=........... !................... !........ ...... ~~~~~~~~~~~~.................... ..... .......... .......... ......... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... I HISP COUNtiES j"" .... ...... .... j .......... ..... ......... ..... ...=.......,.......... .... !......... ......... !. ..... ...~~~~~.... :.......,..... .... ' .......... ..... ..... ..... ..... !.....=.. ..... ..... ..... .... ..... ..... !.. .... ..... ....~~~~~~;;;:; .! ..... .....!...=!... ~~~; .......j ..... ..... .... !~~~~;. ;. ; ;;'. ;;
. ;. !. ~~~; '~~~~. .~~~~~==.! .~~~~~~~~~~~.......... .................... !....... :...... =!.... -.... --. " ...;:. :. z= ===: = z =: %= === d: -==== = =z == .8 sea.: =e... e == .:ca 8 cce c e= E ..aZ2. :8C8 ...=8 . : == = 8=== s ==a ..... ..c.. a:... -== =2 ..... ..s.. 8C= == ae.=c e sc:e= S . .... sa. a: D.. a: =.8 = COUty I A. NAME OF  19BR/89I 'ISCAL YEAR 
(Rev. 01/26/09) I Nr HEDICAl ASSISrANCE (lIHA) COStS REronr I lEGALIZED INDlf ..... ..E.. ..... ... ea ..... ..... 
..... .22.. .e tho Ippoprloto 'Ines) I. RErotlNG rERIOD: (Check , 1990, 19M . Due March IS, 1989 COIS FOR ACtUAL UNRElH_SED LIMA THE GUARIER ENDING: SEPUMDER 30190 . Duo Hirth 15, 1989 COST;; 'OR TIle ClARnR ACrUAl UNREIHIUSED lIHA ENDING: DECEHIER 31, . Due "ay IS, 1989 FOR "IE GUAInER ENDING: "ARCH :U, 1989 ACtUAL UNRElM_SED LIMA COJS , 1989 JUE 30. Due August IS, 1989 ACtUAL UNREIH_SED LIMA cors fOR rIf GUAlnER ENDING: 198 Y. UPOT '01 TIl PERUD: JUy " , 1989 . Due March 31..se......... tHROUGH JUNE 30FINAL STATE f..... ....s...........k8........................s.. ................................... 8Z8:8 c. ..... 
REPOr or 1 D. 8AS IS OF UlREU8URS'E I LIMA COStS I REVENUES I RATIO I U8ER OF LIMA ElIGI8lE TOTAL COUNTY COSTS PER I TOTAL TO PER I I CHARGES (Check the OF PROVIDING coStS I SERVICES PROVIDED I or REIHBURSEMENtS I I PATlEN' DAYS, I COO"I SERVICES TO eppoprlet4. boA)IRCA OR COStS CLAIMED , VISITS, I VISnS DAYS I RECEIVED BY ro DAYIYISn CHARGES COSTS) REPOTED lUlU C(INTY IlIlGENfS LEGALIZED I 'OR COSTS EliG. DETER. (COl. S. 6)
IN COllRl 5 IRCA I INDIGENtS I llEGALIZED I EliG. DUER. I PURSUANT TO ........-......................... a-
I......... .......... ..... .......... ...a. ..... ............811. ..... ..... , S8I1.
.J. - Stetl,tlc,-(COL. Z X 3)
IRCA MlC 8ENEFICIARIESI - Cn. Spec:lI' EMERGENCY cosrs 
.... ..... ..... ..... .00.. ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... I.... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... Stetlstlcel SlIle I (COL. 2 X 3)1 lI IIICA MlC 8ENEFICIAIIESI
:Ie Cese Spec. 'PREG RELATED COSTS I ) .... ..... ..... ..... ...::I :8Il. ::CA I , I X 4) :;T 1 (COL.I =
I (COL. 2 X 3) ;.. i".i"""'" i . i" .... ..... ."' I;;;; :. Ces. Speel fieI (ITPATlEN' SERVICES I 
 I.... ..... ..... ..... ..... 
 .4) IXJOXXlOxxlJOXXXXXJOI I (COL. 1 ISECr. 170oo/"ISP IRCA I IICICXXXXXXXXXXXXXXXXIC XJOXIO lau" XIOIO (I IxxJOXJJOXIOX I XIOIO XIOXX IIOXXXIOIOIIOIOIlIOXXXXXX I I XXXXXXXXXAD" I N I S TIA TI Of II MA XXXXX XIOIII ICXXXX I IIOJOXXXXX XIOXX XIOJOXJO XXXXXXXXXIII XXXX XIOIO I XXXX Ix  i:::::
i::: ::i::::: i::::::::i::::::::j""""""." ................ i"'."'" ..... ...... i'" I"" .. ...e......................................... ..... 8eaa...... 
..... ..c.. ..ac: :..=8  C(INT 170,"ISP 1:1 UIUCATED muT 1:1 IIICATED NUBER OF IReA ELIGI8LES SERVED:  NUER OF IRCA'AFDC IENEFICIARIES RECEIVING
1:1 DULICATED COUNT
NO- EHERGENCY SERVI C:I UNtIliCATED CONT CES  NUBER OF IRCA'MEDI'CAlIEMEFICIARIES, PREGNAM'
COr UNLICATED COUNT
UDN 1:1 IIICATED RECEIVING NO.PREGNANCY SERVICES i== 
C --.:"* .........................................:- ..... ............................ ...... .......... .......... .......... ..... :;: ;;;:;; :;; .......... .,... ..... .....
.......................... ..... ..... ..... ..... ..... ........ ;;; ..... ..... .... ..... ..... .,... ...... ..... .... ..... ..... ;;:: ;;;;;-.......... ..... ... \;;;.; ...:. .... ... .. ... .. ; :;:-.. ..... . .... . ... ;:. ; ;::;:= ;;;:; ;:;=;;= ..... . .... ... .. . .... ... .. ... ; :. ; ;;; . ;; .. . .... . .. . . . .. .. . .. .. . .. .. .. . ... . . . . . .. .. .. . .. .. . .. . . . ; . .. .. . . . .. . . ; . . . .. . .. .. . . . .. . .. . . . . . . . . .. .. .. . . . . . . .. . . . .. .. . . . .. . . . . . . . . . . .. . . . .. . . .. . . . . . . . . . . . . . .. . . . . . . . . . . .. . . . . . . . . . . . . - . .. ;;;:; ;:;=::; ::;-::;;;; ;=':'.. .. ... . . . .. .. . . . . . . . . .. ..  c..e ::
as... . ..... 8SS.. 2.= t c: e e:ee 8 . ancw. es. .......... ee... ..... ..... ..... as=.. ..... ..... ..... ..... ..... ..... ..... ..... ...sa ..... a.a= ss 8S :.'.8 .....  SUHRY OF COSTS
1 ,. 
. ..... ...1 I.... ..... ...,. ..... ..... 
OURTER(S)
1988/89 , 1. TOTAL LIHA COSTS CLAIMED IN PREVIOUS  ..... i .. , 1989 TO DATE1-. .. . .. .. 
UM aJn Pfllm JUy " 1988 THROUH JUE 10CLAIMED fOR 'HE I J. TOTAL 
;:8 ;;8;:;;;:::;8 ;	; :S8.= 8.. :::;:8 ;;:8:;;8:: 8 : ;8;:S ;=  pot luch UWelnbrled costl. . cCKty has on fHe dounentatfon to I Icgel hed pusuant to Act(lRCA) end thet the 1..lsratlon aefonl en Control  REPORT PREPARED BY PHON NUHER DA TE PREPARED -=.....28:..... ..... ..... ..... 
................................... ..... 88..........:..28::2 ..8S ...82 FINAL REPORT ONLY)STATE US ONLY
COUNTY AUDITOR CONTROLER (REQUIRED ON Ported by I H. CERTI FICAT ION .Y 
ATECost Clallled ebove I s I knowl edge. UneldJrsed U.. I hereby certify thet the Total IREVIE"ED .Y: DAlEOff Ielal CCKty Recorc1 and II eccurate to the bes IAPPROVED .Y: t of rt  SIGNATURE OF AUDITOR COTROLLER	(or duly authorized repelentatlveDATE CERTIFIED 'PAYMENT AUTHOIZED .Y: authorllatlon atteched) DATE AUTHctlZED AMOT AUTHORIZED:  with cop of official c.=...... ............... .......... Z&8=a a:c.:: 2............ a=C.8 _.=as   I. R THE FOlLOIING QUESTIONS) BACKUP MTERIAL (ATJACI ADDITIONAl PAGES TO AHS  the bo checked, pleose explain Depnding 1. Docllt (explain) the _thod In Section D. used In dete..lnlng mreillursed LIMA coste al Indlceted Ie. lpeclflc dete or vllid Itetlstlcal I co.lete cese the Method uti I lied:  1..1. dra..?
a. How WIS the lt the 1..1. queltlonnlre.
b. Pleese s accout these fectors: c. Does the SUMI. tet. Into rl!nc (1) F (2) TI.lng of sMfI.(J) Tren over tllI (4) leml. II popletlon Ie In relation to service and result In e stetisticlily velld slRple?
Method used loglcel d. Are the Ie? esth.ted cost I In doing the s e. "'et wes the  typ en forwhOlUM coati ere clellned. locetlon of the 2. Docunt (expl.ln) the IIthodiogy In acUltlon, Indicate the used to Idetify eligibles  8Idlt purposes. dounentetlon which II aVlnebie for  3. Pleese expleln how chergel end costs were deter.lne.
 redued to costl by (Colum 3): doC:lIt how each retlo wes deter.l.-d. using the retlo Method 4. If cherges are  .ethod of 5. If couty 8IWlt, and pleale explain the typ, claill (Colu. 5) which are not Included In patient cOltl, edlllniitretive COltl of LIMA are compots. deter.lnlng different 8dlnlstratlve cost  ralllrs_ntl used to pleese describe the lIethod lpecl flc patlentl, rehllbulelltl for 6. If revenul end are not based on ectuII Indlvlduel reveruel or emotl of deter.lne the reimbusemets. revenue or  nuer 7. Documt (explain) we. deter.One. of userl (Reported 9n $ how the gon 
(
' y). 
. . ;;'	 :;. 
MISP CO

" _II  GBNER  INSTRUCTIONS FO  COMPLETING  d:: . LI'ioL SUPPLEMENTAL DATA FORM 
FISCAL YEAR 1988-89 
Fill in county name.

Check appropriate reporting period (s) . 
Section A. 
This portion of the LIMA Supplemental Data Form
provides addi tional information on those servicesL anId  costs 
LI 
Rineclpuoderdt  (oSn eScetciotinon  C, lines 5, 6, andI 7n poaf tthieen t  Costs
17000/MISP  Services,
OThutep aintiteennt ts	 oerfv itcheiss,  taanbdl eE miesr gtoen scey pSaerravteic oesu rte spectiv
those LIM 
services and unreimbursed costs provided by county facilities
and staff 
staff.  from those provided by non county facilities and
Note that  for "
the requested data is  unreimbursed 
(Colum 7 from the LIMA Costs Report). 
costs" 
Colum 1  Enter the numer of LIMA days or visi ts provided by
coonun tthy efa icnipliattiieesn ta,n od usttpaaffti etno t IaRnCAd  legalized residents
emergency services 
lines as appropriate.

Colum 	
Elninteer  the unreimbursed cost per unit of service on each
as appropriate. NOTE that this can be . calculated
by dividing	 Colum 3 by Colum 
1 for each line. 
Colum 	
Enter the total of unreimbursed costs incurred by county
facili ties 
service. 
and staff for each type of 
Colum' 
s 4, 5, and 6 
Enter 
comparable data for LIMA services and costs 
incurred by non county facilities and staff. Attach
narrative description of  costs 
how these  were 
identified and calculated.

Enter totals for all colums. Please ensure that the

total  unreimbursed costs incurred by county and 
non 
county  colum 7, lines 
providers sums to the total of 
7 of the LIM 
6, and  Costs Report.

Section B

is 
This. portion of the LIMA Supplemental Data Form  designed
to provide additional data on outpatient obstetrical services
provided to 
IRCA legalized residents. The structure of the
form 
recoqnizes that many IRCA residents will be covered
Medi-Cal for at least a portion of their prenatal and 
post
partum care. Please distinquish between those individuals
and costs 	
whose entire pregnancy was partially covered by  . ' : ' ' -' .. . ~~~ ;:; ;;  . . :"':'  ::' j;':._ ~~~~~
i :':::Zi, ,":  ;:;i'  3.  .-i'  :L.  2:.  l '  :.i  d:'  :L, ::i'  L:X 
(.c' '

Medi-Cal 
by  and the county, and those who were entirely funded
i:':"-:otrhmea tci o-u.n atys.  Nwoteel la lasso  r thaatn uwees  afrreo ma..  'd. ndig'- \f:oclrl  qcirnods so tchoesrt  
sources in this portion.

numer of 
Enter the  pregnant women falling into  each 
Colum 
category for the reporting period.

Colum 2
 Is the numer of services or encounters provided?

Colum 
Is the qross cost of the services provided during the

reporting period?

Colum 
Is this total gross cost of services provided?

Is this 
Colum 5
 fiqure the amount  Medi -Cal  payments

received (billed)?

Is 
the  of 
Colum  amount  other revenues (e. g.  patient

payments, other third parties ) received or  billed
indicated? 
Is 
Colum 7
 this figure the unreimbursed cost charge to  LIM 
for the reporting period?  l;:  . f' r. I:;   f 
-
1 '1; 'l f_ 
-"-------~~~~~~~~~~~~-- -- ;.'.".."""""' ...............-.............. .:;;; .................... ..... ................. ..... ............~~~",. ..... .""'....~~~~.......... .......... .....:..;;;;........................ ................. ........... ..... ......... .......... ... ........... ..... ..... ..... ........... .... ....... ... ......................... ..... .......... .................... ..... ;...... . ..... ..... ..... ...... .... .... ..... ,.... ..... ..... .... :::..... ..... ..... ..... ..... ..... ...!!....... ...... ..... ... ..... ..... ... ........... ..... ..... ..... ..... .......... ..... ...... .... ..... ..... . ........... ........ ...... ..... ..... ..... ..... -.... .:.. ..... . .... .... .;;;;;. . .. ...... .... ...... ... ..: ... .. ~~~~.... .;; .. ... ' . .. .'. ..; ; ~~~~~~~. . ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~...... .............. .......... ......... ..... ..... ..... ..... ..... ..... ..... ..... ........ ..... ..... ..... ...... .... ..... ..... ..... ..... ...... .... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... .... . .... ..... - -.....;. ;;;;; .. .. ... .. . ;:... - !,... ... .. . .. .. . . :. :. U.' I' ''rIJ" COUNn ..s...e... ..... ..... cc:cc .ess. .c= 28. ... ..... R e... . .....e.... ..... ..... 8ca.. ..B.. .............c- ae::- as:=s 
..... ...ae ...ew ===- ===== =CQ.. .a... ..... . .e:a: e  REPOTING PERIOD:
 19. JUlY', '988 TlIROOH SEPTEM8EI 30, MACH :11. 1989.
JANUARY I, 1909 TlIRWGH OCTOBR '. JUN 30DECEMBn 31, 1981 1988 TlIROOGH APR IL I, 1909 "IROUGH , 1989
 ..... .....m.............. .. ..=:s c:ca... =a=a: ..:.. ..... cc... ..... ..... ..... ..... ..... -:... ..: =2  UrnOtLZDoo/"ISP ONLY  I. .... .... CATEGORY 'OfAl DAYS/VISnS UNElMaJRSED TOTAL II DAYS/VISnS UNREIMlSED1 , COST PER COST PEl II UNREltlSED IUNREINURSED COTS II COSTS ....D ..... ...... ..... .... ..... ..... ..... ..... ..... ....
 I... 1..... ..... ..... . .. I. ... .. ... .. . .. .. .. MPATIENT 	I. . ... .. . .. .. . .. .. . 1... . 	11.. . .. .. 1 . 11" . 1' .... ..... ..... ... 	 I"......."'... ... . ............... "	1'....'....'.......
......c................................
11" .......... ,."'
1'. ..... ..... ..... ' ................................................................. 8S... e8=.. cae.. 	 aJTPATlENT PRENATAl AND POT PAIT'" CARE ONLY I. 	 .........0............... .......... ...... -.0. ..... ..... ..... ..... ..... ..... ..... 
 I ...  1... 1.. 1.. 1... 	PAITl' CtERED IY",C AND PARtlY 1700,"ISP
 .................. i 
1'.... ..... ..... .. . 1' ..... ..... . .... . . 1..' . .... ... .. ... . ' 1" . .. .. ... .. . 1.. .. .  1................ .. 1......... ..... .... 
1........ .. 1...... -......... .. 1. ..... .... TOTALS I .1.......... ..... ... . ......... 
 ."..................8......"......"............... ............ .................... D..=.
............................................. .c... 
 lUPT1NO NARRATIVE/METHOOGY	 e..... en nocouty feeilities en steff 8n c:lculeted. Delcrlbe how services Ulellnbursed COlts of were Indtlfled  en pot pert.. IdenUUed IId leper8ted betwee Describe how outpatient cere ..s prentet .. "edt'Cet 8nd Section !l000 perU., covered.  PIEPAIED IY: NUER: TITLEs DATE PREPAlEO I VELEPMONE  ~~~
~~~~
:!_... -:,""' "J,  :..,;.,:,-:: '!j.l).' ri:'  '': ''' ...: --. _._ ''''':