,

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IMPLEMENTATION OF THE STATE


LEGALIZATION IMPACT ASSISTANCE


UNDER THE IMMIGRATION 

REFORM AND CONTROL ACT OF 1986 GRANTS 

STA TE OF CALIFORNIA 

OFFICE OF INSPECTOR GENERAL 

OFFICE OF ANALYSIS AND INSPECTIONS 

DECEMBER 1989 
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OFFICE OF INSPECTOR GENERAL


The mission of the Offce of Inspetor Gener (OIG) is to promote the effciency, effectiveness, and integrty of progr in the United States Deparent of Health and Human Services (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 Congrss fuy and curently inormed about progr or maagement problems and recommends 

corctive action. The OIG perform its mission y conducting audits, investigations, and insptions with approxiately 1,300 sta strategicaly located arund the countr. 

OFFICE OF ANALYSIS 
 AND INSPECTIONS


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 Investigations. Inspections ar conducted in accordace with professional stada developed by 

OAI. These inspections ar tyicaly short-term studies designed to determe program effectiveness, 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 

Hugh Owens, Project Leader Apryl Wilams 

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


STATE OF CALIFORNIA 

Richard P. Kusrow 

INSPECTOR GENERAL 

OAI-07-8002 DECEMBER 1989 
.

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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 

The SLIAG progr 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 

because of the varety of program they offered, the number of eligible legalized aliens in the 

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 

ths report. This report represents the review conducted in the State of California and reports 

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 

FINDING: Since 
 1987 FSA ha held IUnai conferences and issued informaton to 

Stats on implementing the SUAG program 

The FSA held several national conferences begig 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 

work grups, to help implement the SLIAG progr in Calorna. These 

argements have helped cross-pollate ideas thugh report of plang and 

progress. Also, these argements have aide diferent method for estiatig 

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. 
, 

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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 communitybased 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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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 

The FSA and the State of Calfornia both commente on the drt 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. 
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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

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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


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


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


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


whether present or projecte policies and prours adere to FSA gudelies. The FSA also


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


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


as these new residents obta Englsh laguage and civic skis nee 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 (F) 1988 thugh 1991 for SLIG grts, less an amount 

identied as the "Fedra offset." With few exceptions, eligible legalze alens are ineligible 

for federaly funded public assistace progr 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 

who ar eligible for them. In FY 1988, the law alocated $928. mion to States. 

To reeive SLIAG fuds, States must apply to the FSA Division of State Legaltion


Assistace, which is responsible for approvig applications and adisterig 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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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 

be the same ones avaiable to the genera public. States canot create new progr in these 

aras speifcaly for eligible legalze alens. However, States may create new or adtional 

education progr for the eligible legalze alen popultion. States may also clai 

reimbursement for progr adstrtive and SLIAG adstrtive costs. 

Reimburement for public assistace and public health assistace is lite to the amount of 

State and local funds expnde for SLIAG-relate costs. The maum SLIAG 

reimbursement for educational servces is an average of $500 per year per eligible legalze 

alen. Determnation of progr adtrtive costs is mad in accordce with the fial 

regulation at 45 CF 402.22. 

The FSA is responsible for adsterig the program Because SLIG was a new program, 

FSA real that problems would surace early in its implementation. In addtion to the 

nor diculties encountered in cratig new processes and proedurs, FSA reogn 

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 

servce population, maitang 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 

varety of progr 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. 

Pror to conductig the inspetion, the OIG develope strctu discussion gudes for each 

major program activity at the State and local levels. In the State of Calorna, we held 

intervews in Sacento with appropriate sta. Ths include the single point of contat and 

representatives frm public assistace, public health assistace, and education. In adtion 

we interviewed appropriate sta in th 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 

planed implementation of the SLIAG progr In Caiforna, SLIAG-funded program 

be county-adstere as is the case with their other progr. 
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CALIFORNIA' S ORGANIZATIONAL STRUCTURE 

The governor has designate the Health and Welfar Agency as the single point of contat and 

lead agency to implement the SLIAG progr 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 

The Deparent of Social Servces is respnsible for State adstrtive functions associated , 

with effectively implementig public assistace progr 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 

Imgrtion Progrs Brach wi be priy responsible for coordiating and

adsterig the SLIAG progr 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 

Responsibilty for adsterig youth and adult SLIAG-relate educational progrs 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 

FINDING: Since 1987, FSA Iu held IUna conferences and issued informaton to 

Stls on implementing the SUAG program 

The FSA held severa national conferences begig in 1987 to shar 

inormtion with States on SLIAG legislation, the implications for States, the 

application prss, 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. 

The Dep nt of Social Servces, the grte 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 unts to handle SLIG-relate fuctions. 

The State has used advocacy grups, along with State and local governenta 

work grups, to help implement the SLIAG progr 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 
. . ,

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.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 

State public assistace servces to be fude include Genera Assistace, AFC­

(unemployed parent), Supplementa Securty Income/State Supplementa Progr, foo 

staps, Med-Ca, and other programs as indicate in the State s approved application for 

SLIAG fundig. No new progrs have ben ad 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 

dictly provides al servces. 

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 

Resident Car) wi be ma. The counties can retractively clai SLIAG-related costs if 

they can document the servces rendere 

In Los Angeles County, eligible legal 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 

would requir furer 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 

forms have been provided to counties to clai 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 

specified servces to the eligible population. A specific code AA (Amesty-Alien) is used to 

identiy services rendered to this population group. 

Administrative Costs


At the State level tie 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, 
, ., ;

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Deparent of Health Servces, and State Deparent of Education. Funding reuests 

ma no sooner than th days before they ar nee 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 

cover tuberculosislleprosy, sexualy trsmitt 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 

avaiable progr. Public healthublic assistace includes Calorna Chidren s Servces 

and the Adolescent Famy Lie Prgr Public assistace includes the Medcaly Indigent 

Servces Prgram the County Medcal Servces Prgr, and priar car clics. 

No new progrs have ben ad for FY 1988 beause of SLIAG fundig. Envinmenta 

health and foster car servces have ben ad for FY 1989. Those servces provided ditly 

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 Health and Disabilty Prvention. The State 

contrts with priar car clics to render some pri 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 

For puroses of filg the SUAG application, cert public health program ar classified as 

public assistace. Ths reuies identig individual eligible legal 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 

the applicant s status afr 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. 
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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 

more accurte count of those persns using SLIAG fude servces. In Orge County, 

adtional sta have ben ad to identi the eligible legal alen population. The 1-688, 

Tempora Resident Car or I-688A, Employment Authorzation Car issued by INS 

identiy the eligible legal alen patients by an alen registrtion number begig with 

A9. In Santa Clar County, forze 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 alen status is fragmente To date, only two State progrs 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, 

Employment Authorization Ca The Community-Bas Periata Services wi accept any 

one of the followig th pieces of identication: . (a) a facsime of the 1-688, Tempora 

Resident Car or I-688A, Employment Authorization Car (b) the amesty application form 

or receipt for application fee, or (c) the number on the INS card or receipt. Ths proess 

causes more adstrtive workoad beause of the inconsistencies in obtag eligible

legal alen verication. 

RECOMMENDATION: The Stat should issue directives to the counties to ensure greatr 

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, 

population ratio method to identi 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 reuests. Orange County is also waiting for State instrctions. Once guidelines have 

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


At the State level, sta uses tie sheets day to reor SUAG-relate activities. These tie 

sheets ar use to apporton costs by progr These costs ar report on the HCFAquarrly expenditu report form. The adstrtive cost center includes salar, frge 

benefits, and a percentage of operatig and equipment costs. The indiect cost rate is 25 

percent as determed under the Cost Alocation Pla pertent to public health. 

In Los Angeles County, no prours ar yet in plac to identi adstrtive costs. A 

possible samplig of employee servces is being conside Orge County uses ti sheets 

to reord adstrtive tie alocate to prgr. Admstrtive costs ar computed as 

ratio of SLIAG costs to tota costs. The Orge 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 Deparent of Social Servces, the 

grte agency. Up to a 25 percent advance can be mad to a pri care clic or smal 

county. The cash advance wi be reuced as clai ar 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 alert 

Interagency trsfer of funds is not done at the county level. In Los Angeles County, SLIAG 

funds would go to the trasurr-ta 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 gudelies on th proedur. Lage cash balances would not 

occur because al servces are paid for by reimbursement. Orge County Health Deparent 

sta ar not aware of any proedurs for the trsfer of SUAG funds frm the State to the 

county. Cah balances probably would not occur. In adtion, Santa Clar County sta 

indicate that cash balances probably would not occur. 

EDUCATION 

Assistance or Serve Activities 

Servces rendered are adult education and kidergarn thugh gr 12. Technical 

assistace wi be furshed to educational institutions by the State Deparent of Education 

and the Chancellor s Offce of the Caorna Community Colleges. No new progrs have 

ben ad due to the avaiabilty of SUAG fundig. The community-bas 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 

one college servg Orge County, approximately 10,00- 11,00 persons are enrolled in 

English as a Second Language classes, and approximately 2,500 are eligible legalzed alens. 

One of the requirements of the SUAG progr 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 

The SLIAG provisions lit State educational agency adstrtive costs to 1.5 percent of 

tota SLIAG educational costs. Tune sheets wi be used to captue ti spent on the SLIAG 

progr. Th SLIG-related education positions ar funde by the State Deparent of 

Education and are not charged to the SLIAG progr. 

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 

gudelies frm the State to determe adistrtive costs. No tie sheets are used to 

determe sta tie devote to SLIAG activities. The college wi develop its own 

methodology for determg adstrtive costs for SLIAG puroses. 

In other aras reviewed in Caforna, schools were improvising methods for claig adstrative costs. Most were using tie 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 1987- 1988, an elementa school plans to have school personnel 

reonstrct how much ti they spnt on SLIG progrs from calenda, notes, etc. This 

would include tie 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. 

Applications were to conta brief descrptions of the State progrs 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 for servces rendered by communitybased 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 

rendered in good faith, and determine whether a modificaton to its position would 

warranted. 

FINDING: Conficting interpretations of the term "public charge" has caused uncertainties 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 

people are afd to identify themselves as aliens for fear of being considered a public charge. 

Some qualifed designated entities are tellig alens not to apply for SLIAG-related progrs 

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 

instrctions from the Deparent of Health Servces on how to determne alowable progr 

costs. Th county wil captu whatever cost information the State requests. Orange County 

Health Care Agency staff are also waiting for State instrctions. Once guidelines have been 

issued by the State, Orge 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 

guidelies or they were awaiting receipt of guidelines. In the case of one community college a 

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 

The FSA has generaly agr with the OIG report findigs and recommendations. The FSA 

has taen a number of steps to improve implementation of the SLIAG progr 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 recent discussions with States ' offcials that demand for servces nationally is 

falg behid earlier projections. 

The draf report states that "For purose of fig the SLIAG application, cert public health 

progrs ar classifed as public assistace. 

The FSA replied that they see ths priary 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 

alternative method is responsive to the nee of the progr 

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 

cases, would reui considerable revisions to the States' system or statutory reuirments. 

However, we do agr 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. 

The FSA made numerous comments to identify cert matters of fact, policy, or proedures. 

We have included these comments verbati in Appendix B. 
The Sta of California 

The State has generay agr with the OIG repo fidigs and reommendations. Their 

comments ar include verbati in Appendi C. The comments clared the State 

organzational strctu use to adster the SLIG progr as well as the report 

descrption of the State s drwdown of fuds and the handlg of cash balances. Since the ti of the on-site review, the State has taen signcant steps to effectively implement the 

SLIG progr though procedur and system changes. 
:_ .!, ,;::: ::...... :_,.:..(. ;:,. :;;;..:'i: :n:. 

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 

groups, to help implement the SLIG progr in Caora. These argements have 

helpe cross-pollate ide thugh report of plag and progrss. Also, these 

argements have aide dierent method for estitig progr 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 

SLIG-funde education progr. 

The State has taen steps to establish an organzation that wi help adter 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. 

Al of these IRCA cooatig units have develope the expertse necssar to 

implement the prgram at the State level. Since Caora administers may of its 

progr 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 

Serces is the grte 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 

"."..IU Memorandum 

Date: August 10. 1989 

From: 

Subject: 

To: 

Acting Assistant Secretary 

for Family Support 

OIG Draft Report: Implementation of the State Legalization 

pact Assistance Grants Under the igration Reform and 

Control Act of 1986 - California (OAI-07-88-00442) 

Richard P. Kusserow 

Inspector General 

Attached are the Family Support Administration comments on 

the above draft report. Many of our coments are technical 

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 

round of reviews of the SLIAG program. 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': 

Implementation of the state Lealization X-pact Assistace 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


examinations required of all applicants for legalizations. 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 

for public health assistance or public assistance services. 

Page 2 (Background) -- The draft report says, .States must 

develop a method acceptable to FSA for determining administrative costs. iil 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 associated with administering HHS grants, is governed 
 y 45 CFR


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 be funded by SLIG 

include General Assistance, APDC-U (unemployed pat), Supplemental Secuity Inco.e/State Supplemental Proqam, food stamps, and Medi-cal. No nev proqaJ 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 

studies. All other services will be fuished directly by the 

counties. . It is imrtt to note that all progam of public assistance must .eet thee criteria. 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 8eliqible legalized aliens. 

Additionally, it is not clear what is aeant by child abuse 

studies. The statute and reqlation would preclude the State 

from developinq or conductinq studies on bealf of 8eliqible leqalized alien. The final report should aae these points clear. 

Page 5 (Assistance or Service Activities) -- The draft report
 states, "The state has indicated the counties that the costs


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
 will not qo below the proqram level to identify these costs for 

SLIAG fundinq purposes. We cannot determine from the 

description what is meant by this statement. We request that the 

final report provide clarifica ion. 

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 

l:' Public Health ssi tanJ 

Page 7 (Assistance or Service Activities) -- The draft report


ists California Children I s Services and Adolescent Family Life 

Program as Pulic health/public assistance. The final report 

should note that since the OIG program review, the State has 

resubmitted the California Children I s 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 

assistance or public health assistance 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 SLIAG. (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 

single ratio of the number of ELAs in 'the service population to 

the total service population to establish actual costs for public 

health assistance programs, as defined for SLIAG. Implicit 

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 

overstate costs, dramatically in some cases. We have indicated 

to States that we would allow use of the population ra io method 

empirical basis to indicate 

that doing so would not overstate costs. for any program for which there is an 


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


securi ty numbers. That is 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. 

Page 8 (Documentation of Eligible Legalized Alien status) -- The 

draft report further states that, "Los Angeles County found that 

sampling eligible legalized aliens would identify more SLIAG 

costs than using their system to count individuals. Samples of 

inpatients were taken on two occasions. In the opinion of the 

county, this resulted in a more accurate method of determining costs. This method is under review by -the state. It is unclear 

to us how taking a sample of inpatients would yield better 

resul ts than counting actuals. The regulation allows costs for 

public assistance programs to be established by (1) establishing 

costs associated with identified eligible legalized aliens, (2) 

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 

what costs to claim or how to docuent these costs. 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


primary care clinic or small county. 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


to reimbursement.


request that the final report clarify whether payment 


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 

guidelines from the State to determine administrative costs. 

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' 

SLIAG-related costs for each program or activity for that 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 

public assistance and public health asshfcance to' &Octivities that 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 

actions featured in the draft report. 

RECOMMNDATIONS 

FINDING	 The FSA' s policy of denying payments for 

services rendered by community-based 

organizations and qualified designated 

enti ties prior to the state I s application 

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 providers of communi ty­ 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 
. ..., 

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i::,	 :i. 'A.' .:L':, ';''i.\.;..:.L.',- .J; .:-i, ':/;:.J, 

FINDING Conflicting interpretations i,t the" term-" 

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 

presentations at virtally all of our 

workshops and conferences. At these 

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.

.::::.. ;:.: ::._ ; ,.. ...... :::_ ...:,,, :.,,,, :,, ,,,,.,:.,;,,.., . :;..., ::.._

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),,./ .1'; -'':r- "".c,­

APPENDIX C


CALIFORNIA'S COMMENTS

.. ,. 

. ,.. .

. GEORGE DEUKMEJIAN. Governor STATE OF CALIFORNIA 

HEALTH and WELFARE AGENCY 

OFFICE OF THE SECR


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

Sacramento, California 95814


(916) 445-6951 

SEP 1989

Richa P. Kl1sserCM, Instor General 

Office of Anysis & Instion 

HH Office of Inspector neral 

Cohen Bu lding, Ro 5660 

330 Indepndence Avenue

Wahingon, DC 20201 

De Mr. Ku..c=:sercw: 

Put to your reqest an subseqent disclls.c;ion wi th Mr. Hugh (Mns of 

yo staff, I am sllbnittiDJ th enclosed conts 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 th yarJ:r staff who were thoroughly 

profesional an well orgnized in thir reiew of a broad scope of 

issues and procedures affecting Caiforna s imlemntation of IRCA. If 

I may be of any futhr asistance to yo in the reiew of yo drft or 

the explication of ollr cots, pleae do not heitate to telephone me 

at (916) 445-0196, 

Sincerely, 

RICH A. EPIN

Spial Asistant 

Enclos 

cc: Hugh R. Ka City, K) 

Normn L. 

DHHS 
.:, 

;:.;.. .: , :, ..:. ::;_ :. . . , ,.. . ., :.:. ,,, ,,,,_ ;\. . , , ..... .,, : ,. ,;,, .:... .. u -- ' .-:c'- ''':'i., ' _d t. J;_ 0 . '"'',--P'. 

Slate or Callrornla Departmenl or Educallon 

Memorandum 

To: Richard Epstein 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 page:2 ot tne reDort unaer Memoaology 

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 IS tt'e Migrant ana Amnesty EaucatlOn DivlS10n

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 " contract" 1n the first 

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 
. _

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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 recordkeepmg 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 provIded with free materIals and ongoing

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 approvalletter was superceded by this 

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 I1m1t for k-12 adult 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, 

: , ,, , _:... . .:::::.:.,, :,,... , ,. _.; :;;, . :;.:;.:: ::. :,..

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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-proftt provIders who had limtted resources, 

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 twomonth period. The Department wil1 publish a Program Operations Manual on 

or before October 31 , 1989 to further assist providers. I have no Quarre I 

with the finding Out argue that more clarification of the sltuation IS needed. 

Th1S fmdmg IS further d1scussed on page 13 of the report. In the last 

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 

management system in place, the IRCA Pre-Enrollment Appraisal. 

Therefore, they do not r'eed to negotlate wHh the State on methods of 

determining ratios and samples.

, ,

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c. ' :'f!., .:c.:.:.;"' ::,L. ';2.-

Ste of Caifornia Healtb and Welfare 19eD


MEMORANDUM 

To: Richard Epstein 

Spec ial Assistant - IRCA T';;t. June 28, 1989 

Heal th and Welfare Agency 

1600 Ninth Street, Room 450 

Sacramento, CA 95814 

Subject: Office of Inspect 

General (OIG)

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 State Department of Education 

(SDOE) is respon sib le for ed uca tion. Eac h agenc y will 

request funds from the Grantee Agency, which is the SDSS. 

Sta te De partmen t of Soc ial Se rv ic es

We suggest the following language for the third paragraph.


The State Department of Social Services (SDSS) is responsible for administering (Grantee Agency) and 

complying with SLIAG functions at the State level. 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. 

Public Ass istance 

The programs mentioned in the sixth paragraph do not

incl ud e all th e ae tiv it ies/serv ice s funded under public assistance. In 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-­

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i. ..E i::i.' :J 2U.il:.,.. 

I.' 

Drawdown of Funds Balances f! 

The third paragraph on the drawdown process is not
 accurately described. The attached flow chart clearly 

illlustrates the drawdown process in California. The 

following is a brief statement on the drawdown process: 

The SDSS is responsible for the Grant Management activities


which include the drawdown of Federal funds. 

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. 

Good Pra ctices 

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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-r ATlc)J, 

"RECUE' . 
. ..

Sta ." Caia Department of Health Seices 

Memorandum 

: Richarcf ' pstein . Dae : July 5, 1989 

Special Assistant to the Secretary


Health and Welfare Agency Subject: Comments on Dra 

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 DHHS Inspector General (IG) report entitled "Implementation of the State Legalization Assistance Grants under the Immigration Reform and 

Control Act of 1986 - State of California"


DHHS Finding (Pg. 8):


Pulic health assistance programs need defini ti ve quidelines
 from the state on how to identify eligible legalized aliens. 

Response: 

In the year that has elapsed between the IG visit and the 

publication of their report, California has made significant strides in establishing financial reporting systems responsive to federal requirements. All local government agencies claiming SLIAG reimbursement for public health and public health assistance costs associated with providing services to eligible ' legalized aliens (ELA' s) based 

documentation or statistically valid sampling have been 

provided with the Family Support Administration' (FSA)

guidance on the documentation of ELAs contained in Module of 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 attached "MISP" Counties LIMA Guidelines - Fiscal Year 1988-89" to 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 

was in fact viewed in each instance and to record the INS alien registration number from the documentation that was 

viewed. 

C..9 
We are aware that this documentation requirement may resul t in an 	 er.statement associated with serving ELA I S or Ci&courage ELA 	 m u
 ilizing available services because of the uncertainties and confusion surrounding the 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 indicated above , additional guidance was 

promulgated on a program by program basis (see attachment). 

We also note that the report states on page 7 that the Department of Health Services documents administrative costs using time sheets. This was the case during State fiscal year 1987-88. Beginning 7/1/88 the Department began directly allocating staff 

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 Health Services 

(DHS) Legalized Indigent Medical Assistance Proqram (LI). LIMA 

is the State' s program for reimbursing counties for unreimursed 

heal th care services paid for or provided to persons eligible under Section 17000, Welfare and Institutions Code (WIC) and who have become leqalized residents under provisions of the Federal Immigration Reform and Control Act of 1986 (IRCA) . These guidelines cover only LIM expendi tures for the 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 ;provided to the State through the federal governent' State Legalization Impact Assistance Grant (SLIAG) proqram, are intended to reimburse counties for actual unreimbursed costs of heal th care services provided to IRCA-legalized persons who are eligible for services under Section 1 i.OOO WIC. SLIAG funds are subiect to these restrictions:

o SLIAG funds may be used only for programs or activities 

which are generally available to the citizens of the State. 

Scope of services for IRCA leqalized persons must be

identical to services provided to other program recipients. 

Unreimbursed costs are actual costs after all applicable revenue and reimbursements have been subtracted. Claims may include direct unreimbursed administrative costs and eligibility costs. 

o Counties must account for the differences between 
 costs services and charaes for services if charge data is the 

basis for computinq all or a portion of the LIMA Cost Report. In most instances provider charges exceed costs; LIMA can only pa::t' for actual
 costs. Counties are required to explain their method of ascertaining costs, in relation to charges; generally, a ratio is applied to charges to determine costs. For further details, please see reporting 

form instructions.


o In order to be SLIAG reimbursable, services must be provided only to persons who meet all existing program requirements, including share of cost. 

o LIMA funds may be used to reimburse eligibility determination and administrative costs, as well as for 

costs of providing health care services. (See next two 
. . . .. . ...

EXHIBIT C


section for more detailed eligibility information). 

.(4. :t. o : 1.ru.::t1: . i .;:i v.. costs must determinecl \... C1 ordi:nce with allowable federal regulation 'set forth in 45 CFR Part and Part 402. Indirect Costs must be determined in 

accordance with A-87 guidelines as established by the 

Division of Local Governent and Fiscal Affairs of the 

state Controller' Office. 

o Administrative costs related directly to the medical care of IRek legalized persons should be buil t into patient costs. LIMA administrative costs should include those costs that are directly related to the administration of SLIAG Grant Fuds, i. e., planning, consulting, record keeping, data collection and cost report preparation.


LI funds cannot be used to reimburse costs of an abortion 

unless the abortion is required to save the mother' s life. 

o LIMA funds cannot be used to pay IRCA-legalization application fees' or fees for the medical examination 

required for IRCA legalization. 

o Costs reimbursed under these quidelines are for heal th services (including administrative costs, and eligibility determinations) provided between July 1, 1988 and June 30, 1989. The method of accounting used must 

consistent from year to year of claiming. 


o Costs claimed shall meet applicable federal reguIations pertaining to the implementation of section 204 of Pulic 

Law 99-603.


SLIAG ELIGIBILITY REOUIREMENTS:


o Counties receiving SLIAG funds are responsible for identifying and documenting the IRCA-legalized status 

persons whose health expenses are claimed for LIMA reimbursement. The only certain proof that a person is IRCA legalized is the Lawful Temporary status card 1-688 (green card. If the I-b88 is unavailable, the Employment Authorization card I-688A (red card) provides indication that the person has applied for legalization and paid the application fee. However, a small percentage of persons receiving the I-688A card do not receive their lawful 

temporary resident status and the 1-688 card. Another 

indication that the person has applied for legalization is the . Immigration and Naturalization Service computer printed 

document verifying payment of fees required for application 

for temporary resident status. 

o Counties should retain copies of documentation used 

establish eligibility. 
::.

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:,, . 

EXHIBIT C


o The effer:t:ive r\at	 f legal status ":1:: tl be the individu filed' is or her application and - paid the required fee. It 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 so on or after July 1, 1988 and had IRCA legal status 

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 related health care to IRCA legalized pregnant women who are only. 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 services 	 IRCA-legalized persons eligible under Section 17000 (WI C) . 

DOCUNTING HEALTH CARE COSTS 

payments are based on unreimbursed costs of services to IRCA-eligible recipients of services under Section 17000 (WI C). 

Counties will therefore want
 he following:	 to document these costs by recording 

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 xeroxed copy of both sides of 

Form I-688 (temporary resident) or Form I-551 (resident alien) or other document verifying the individual' immigrant status, and/or notation in case or program files 

showing the person' Alien Registration Numer (I'A"

numer), the effective date, and expiration dates of the documents, and date(s) the individual received services. Not recommended: self-declaration of immigrant status. 
:;:;;, ;;.. ::.:::;,:,:. ,,,;. j; :, :, ;.:, . .._ .,, :..: :; .;::;.:,...... , ,;, ,. ; ,.:.:, , . . , ,;:,; ,._,.., . .. ,:.: .. ,.. ,., ,.,__,....__.,,

.. J _ fJ'-7. l ,. - -:.-- n r.,, O. - 'J . 'n. 

EXHIBIT C


Counties may document the nUmQ of IRCA-reimbursable uni (visits, inpatient days, and eligibility determinations) either by actual record or by use of a statistically valid sample. If the latter is used, the statistical sampling method must conform to federal qui de lines, and any revisions or modifications by Departent of Health and Hum Services as indicated in 

"MODUL 13" , SLrG Guidelines, attached. The Department should be 9i ven an explanation of the sampling technique used. Audi t 

exce tions resul tina from use of a sam na method must be borne 

bv the countv.


The costs of IRa-reimursable units may be documented either reporting actual costs/uni ts of services or by determining an average cost per unit of services. Costs may be computed based on the actual costs associated with specific LIMA patients or the average cost of service in a program or acti vi ty. Average costs must provide a reasonable me&sure of actual costs. 

Averaged costs should. not exceed the total cost of services 

associated with LIMA patients.


In arriving at county unreimbursed LIMA costs, the county must reduce medical care costs by any revenues and re imbursements received by or on behalf of an IRCA legalized person, e.g., Medi-Cal -reimbursements, Medicare, third party reimbursements, 

share of costs payments, fees, or other payments. 

LIMA ON AB8/MISP SCHEDULES


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

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 

A9reement for 1988-89 LIM funds, and complete and submit the appropriate cost report forms to the Departent on timely 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 

GENERAL INSTRUCTIONS POR COMPLETING TH LIMA COST REPORT PORMS 

FISCAL YE 1988/: 

The MISP /LIMA Cost Report is desiqned to claim LI unreimursed 

costs for the period July 1, 1988 rcu;h J e 30, 1989 on 

quarterly basis. Please submi t separate reports for each 

quarter. The quarterly reports are necessary to pay LI funds 

to the county and are due to the County Health Service Branch 

indicated below: 

Quarter

Quarter

Quarter

Quarter 

Endinq September 30, 1988 

Endinq December 31, 1988 

Endinq March 31, 1989

Endinq June 30, 1989 

- Due March 15, 1989 

- Due March 15, 1989 

- Due May 15, 1989 

- Due August 15, 1989 

This report form is also designed for use as your Actual Final 

State Fiscal Year Cost Re ort for the period July 1, 1988 through June 30, 1989. This report is due no later than March 31. 1990 and is a cumulative report of costs previously reported in the 

quarterly reports and any addi tional costs not previously 

reported. This report will be used to make a final settlement 

LIMA funds. Please read the following instructions and the LIMA 

guidelines prior to completing the form. 

Section A -- Enter the name of the County. 

Section B -- Please indicate the quarter being reported or if it is
 the Actual Final State Fiscal Year Cost Report. 

Check the appropriate reporting period (s) . 


Section C -- This section provides cost and utilization data. 

Please report costs for services provided on dates within the reporting period. The following persons or categories of health services are eligible for LIMA 

reimbursements. 

o Unreimbursed costs of health care services regularly 

provided to IRCA-legalized persons ligible for services under Section 17000 (WIC) in the county, 

(including MISP) 


o Unreimbursed county costs of providing non-pregnancy related medical care to IRCA legalized pregnant 

women, who are Medi-Cal beneficiaries for preqnancy 

related services only. 

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. 
. 

. ::: ::,;..;:, :./: : :;: :\::, .;.j. ::,,;).;.,::: ;\.) ,... ,;:.:,.::::_,: . .:.:::..;: ::.:, :!. ;:),:,::.:,,; ..,. :.. :,:. :_ ::,.;,,,:., . i.. i;;,	 :/J.:"jJ' :i.'.!i:, :' 1 , 'J, --:o_. .o:J.., 

Colum 1 -- Enter the total numer of Patient Days, Visits, and Section 17000/MISP Eligibility tenuinj!Ji,=n!= for 

the period covered by the report.


Colum 	2 -- If 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 	 If you completed colum (charges are reported) you . must enter the necessary ratio in order to reduce 

charges to costs. Please explain how these ratio(s) were determined. 

Colum 	4 -- If you completed colums 2 and 3, multiply them and enter 	the resul ts. If you are starting in this colum with costs, it should be noted that weighted average costs per unit of service is acceptable. If 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.


Colum -- If applicable, multiply colum (units
 services) by colum (costs per unit of service) and enter 	the results. Enter the costs 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 REIMUREMNTS received 

(Medi -Cal , 	CMP, third party or share of costs, etc. for services, MISP eligibility determination and LIMA administrative costs 

claimed in Colum s. 

Colum 7 	 Subtract colum 6 from 5 and enter the results.
 This colum should represent the unreimbursed


county costs of providing medical care to persons
 legalized pursuant to the Immigration Reform and
 Control Act CIRCA) for: 1) indigents; 2) MISP
 eligibility determinations; 3) the unreimbursed


County cost of LIMA administration.


C-16

.;::;. :, ;,.. ,,,,, ,,;._. :., ...:. ,,_., :_,,,. ....,,..

'i=!;. i.. ::':L.:"' .J:, ;.:r': 4"'- o:" ;...":L_ .I"-' 

section D -- This section indicates how the data disclosed Colum 1 are docuented. Indicate if the data are 

based on complete case specific records or .:ed 

a valid statistical sample. 

Section E -- Enter for each category, the numer of legalized indigents served and indicate with a check mark 

it is an unduplicated or duplicated count. 

Section F -- This section provides for the following: 

Line 1: The sumary of the net costs previously reported to the Departent, (enter a zero 

for first quarter of the State Fiscal 

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 G -- The person responsible for preparing and submitting the report must sign and date the report indicated. 

bection H -- Only the Actual Final state Fiscal Year Cost Report must be signed and dated by the . County AUditor/Controller. This report is due not. later 

than March 31, 1990. 

Section I -- Complete the questions in this. section and explain the methodology and assumptions used in completing this Cost Report. Completeness of this section is 

required for the approval of the cost report and 

disbursement of LIM funds. Therefore please be specific as possible in answering the questions 

this section.


-l 7 
.... ..... .............................. .

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.. . . . . . . . . . . . . .. . . . .. . . . . . . .. 

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!......... !..... .... .... !. .... ..... ..... ...., . !........ ..... ..... !. ::. 

.. ... .................... ..... ..... ..... ..... ..... ...... .... ..... ..... ..... ..... ..... ..... ..... ..... ..... .......

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..:e: -=8=e .c2ee = =S8 ..=:- .2 .. ..... ..e:- D=aa: : 2 === e:_:c =c=e: = = =s =e= =- .E e. eaaee =sa == c:ce. _:=ea ..as. 8cae:=esce c=== ...a: ..=:8 -== =: = = e&: === == === == c I MISP COONIIES I A. N/\E OF Co./Nn

1988/89 I FISCAL YEAR 
 REPOT (Rcv. I LEGALIZED INDIGENT MEDICAl ASSISTANCE (LIMA) COSTS 	 01'26/09) 

;;;;: ;e=. =ee e. a..== =e... = a... ..=.s ..... ...:. e.:e: a.:ee =e=... .....82.. ..a............ ..... ..a.e =..ae =e= ee e=: aa ...


ACTUAL UHRE IH8U1SED lIHA cons rOR TIlE QUARIER (NO I NG: SEP IEHnER 30, 1988 . Due Hnrch 15 , 1989 
ACTUAL UNREIMBUSED LIMA COTS fOR TilE WARTER ENDING: OECEHDER 31, 198 . Morch 15, 1969
ACTUAL UNREIHBUSED LIMA COSTS 'OR TilE WARTER ENDING: HARCH 31, 1989 . Due Hay 15, 1989 


ACTUAL UNREIMBUSED liMA COSTS fOR THE WARTER ENDING: JUNE 30, 1969 . Due August 15, 1989


fiNAL STATE f. Y. REPOT fOR THE PER 100: JUy " 1988 THROOGH JUNE 30 , 1989 . Due Much 31, 1990


..=.....=................ .......... .......... as... ..s.=t.............. ...Dt ..... 
 8==-: 

C. fiSCAL DATA I COUM I COUMN 2 I COllJ 31 COlll 4 I COlUt 5 COlU4N 6 COU". 7 I D. BASIS Of 'OT
 .... .a.828=s..........=a......................... 8=........ a==.. :....s................."..."
 ===. ..aaa ... 8..=...... ..C.. 8.8== ==Z=-
 I. lItt ELIGIBLE 1U8ER Of 	I CHARGES I RATIO COSTS I TOTAL COONTY COSTS I TOTAL REVENUES I UlREUIiURSm lItt SERVICES PROVIDED I PATlEIIT DAYS, I PER I COSTS I PER I Of PROVIDING I or REIMBURSEMENTS 	 (Check the 

VISITS, DAYIVISIT I TO DAYS , VIS ITS, I SERVICES TO I RECEIVED BY co.nuy COSTS CLAIMED .ppoprl.te box) TO 

REPOTED (NET COON" COSTS) I INDIGENTS LEGALIZED or I CHARGES OR IRCA I fOR COSTS (COC. 5. 6) I PURSUANT TO IRCA I EliG. DETER. I I EliG. DETER. I lEGALIZED INDIGE..TS I IN COLUM 5 


'_:..8...= ..... ......................... ...e. ..:-. ...:- aD:== _:C8. ===2. 88:_:_==78..=8. =.... aa8.8 ..= .......a....s...... ........"...=Z .a=:= ==a:. ===:= ==-,
IIReA M/C BENEflCIARIESI I (COL. Z II 3)1	 Stottltlcal slIPle 

Case Specific
 INO.EMERGENCY COSTS 	 '.G'. ...1 ..... ..... .G'.'. .... .'G.' .....
 I"""". ..... 	 Statistical S8llel II ))1 	 1- IIIICA HIC 8ENEfiCIARIE	 I (COL. Z I . . . . .. . 

I SECT . 17000,MISP IIICA I I (COL. 2 X 3)1 (COL. 1 X 4) 	 I _ StatlsUc.1 s_plel I' I ; 	 C.5e Spec! fie
 I INPATIENT SERVICES 

I;;	 j ..... ..... i.. 

! ..... "..G 

St.tlstlcel 511,e 

ISECT. 17000,"15P IRCA 	 I (COL. Z X 3) (COL. 1 X 4)
 EMEIlGENCY SERVICES 	 C.5e Specific ..................0................ ..	.. ..... ..... ...1
 I.... ..... ..... 

IXXXXXXIIXIIXIIXXXXIIKIIIIKXXI ISECT. 17000'"ISP IRCA I 	IXXXXXXXXXXIxxxxxxxxxI I (COL. 1 X 4) 


i;;;;;;;i;;;;:;:; i;;;;;;;; i;;;;;;;;;;;;;i..... ..... .......... . i.................. '	 i;;;; -;;;;I
 Of LIMA IXXXXlOlOXXXlOxlxxxxxxxxxx I XXXXXXIIIIX I XIIIIIIICXXIIIIIIXX I 	 IXXXXXXXXXXXXlIlIxxxxxxxl 

I'.."'.'. ..... G"" .................... ..,'G ..... ..... ..... ...G. ..... ..... ..'G. ..... .'.'. ..... ..... ...G. ..... ..... .......... .......... ,.'G. .......... ..'G' ...1


IxxlIlIlIXXIIXIIXXllllllllllllxxl 

IIIIIJOJOIOJOXXXII I XICXXXXXIIX I XXXIIIIXIIIIII I XXXIIXXXXXIIIIXII I IXXXXXIIXllllxxXXlIlCxlIlIxxl 

......c........."....."............... CCDE: .. .==a..==_: c... .....=. ..... ..... ..=....88...... ........"."..."....2.. ..:.. .a.-:....= .... 

TOT A l IIIXIOJOXXXJOIOXIXIIXXXXXIIII IIIIIXXXIIXXII IXIIIIXXIIIIXIIKIIIIIII 

I E. 

IUBER Of IReA 170,"ISP ELIGIBLES SERVED: 1=1 UNtJlICATED COT 1=1 DUiCATED CON' 

NUBER Of IRCA.AfDC BENEfiCIARIES RECEIVING


NO. EMERGENCY SERVI CES	 I UNOtJLlCATED COUNT I DUL ICATED CONT 

NUBER OF IRCA.MEOI.CAL BENEfactARIES, PREGNANW 

UDN RECEIVING NO.PREGNANCY SERVICES I UttJLBCATED COUN' I DULICATED COJNT 

. 828== z... ........ ............... ..... aa... 2..:S ..-:- a.... ....- .e... ..... .E... ..... ..... ...ce K8e.. ..... ..... ..... ...:- ...ca 8C... ...== ===== -===: &=:== _=Z8 
,. :. 

. . .. . . . 

.. . .

.. . . . .. . .. . . . . . . . . . . .. . . . . . . . . . . . . . .. . . . . . . . . .. ... . . . 

.. . .. .. ... .. . .. .. . . . . . ... . .. . . . .. . .. .......... .................... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... 

..... ..... ... ..... ..... .................... ..... ..... ... 

........ ... 

..... 

........................................ ............... .

....... ..

............ . . 

,

;:

; ; . ; ;;; . ; ; 

.......... ..... ..... ..... c...: . ..aa . r.c= ..


..... .e ....s ..... ..... ..... ...........c... ..... ...e. ......e.....eaa ..... .c.......... e...... .......... ..... ..... 

00 00 ... :. .. 00 00 . 00 .. . : oo. . .. .. . .. 00 . .. 00 . . . . . 00 . .. . . 00 . . 00 .. . .00' .0000 .00 .. . . 00 . . .. .. . 00 .. .. oo. .0000 . 00 00 .00" . .... .00 .. .00 00 . 00 .00 t :

QURIER(S) ' I I. lorAl LIMA COSIS CLAIMED IN PREVIOOS 1900/09 


.... . .... i .. 

COIS ClAl1U FOR THE PERIOD JUy I, 1988 IHROJGH JU 30, 1989 10 DATE I J. lOlAl LIMA .......... .................... ...ass..:. ........


..... ....: s.... ......C:.8 :DS== :ZD== ...a. ..... ....-


I hereby cert Ify that the net C08tl reprted represent the actulII U1relnburled COlts Inc..red by ou cOlty In providing _Ical care to Indlgenta
 I G.


legal hed pusuant to 1..lgratlon Reforl an Control Act(lRCA) end thllt the cOlty has on file doUlentatlon to It.pot .uch unel""raed cost.. . .


REPORI PREPARED IY PHONE NUMER DAlE PREPARED 

8S... ..... ..... .................... ............... .E:.. Z..=. =. c.... ..... ..... .ess. ...s. ..... ................................... ..sa. 


COTROLER (REQUIRED ON FINAL RErORI ONLY) STAlE US ONL' ' I H. CE.TIFICATION IY COUNT' AUDITOR 


I hereby cert Ify that the Tota' Unelllrsed lIlI Cost ctal.ed above Is st.poted by IREVIEVED IT: DAlE -
 DAlE Offlcla' Comty Records .nd t. ICcur.te to the bet of II knowledge. IAPPROVED 8Y: 


SIGNAIUtE OF AUDITOR COTROllER DAlE CERTIfiED IPAYMENT AUTHOIZED .'1 

AMOI AUTHORIZED: DAlE AUHOIZED (or duly euthorhed rep.lentatlve 


with cop of offici a' authorization attached) ......... ......""...".......=8S8CZ.. ..... ...8
 .....c.... ..... ..... ......ac.. 

n I. lAaa MATERIAL (ATTACH ADDITIONAL PAGES TO ANSUER THE FOllOlING QueSTIONS) 

I. Oocunt Cellplaln) the .thod used In dete..lnlng U1reillsed LIMA costa a. Indicated In Section D. Depnding up the bo checked, plee.e ellplaln 

the .ethod utlilled; co.lete ca.e specific data or valid statistical lamle. 

a. How wa. the laml e drawn?


estlonnlre. b. Plea.e IUblt the lamle 


c. Does the S.-le take Into accout the.e factorl:


C I) freqnc
 (2) 'I.lng of lam'e (3) Tren over tI­ (4) lamle II Ie In relation to service poplation 

d. Are the 8ethod u.ed 'oglca' en result In a statlltlcallv ve'ld .aMple? 

e. "'at ..s the ..tiNted cost. In doing the lamle" 

2. Docunt (ellplaln) the ..thodlogy used to Idetify eligible. for when LIMA costl are cllilld. In acltlon, Indicate the t)p .. location of the 

domentetlon which Is available for audit purposes. 

3. Please explain how chargel an COstl wer, deterMine. 

4. If charges are recbed to costl by using the ratio lIethod (Colum 3); docunt how each retlo was deterMined. 

5. If couty adlniatrative cOlt. of LIMA are claill CColu. 5) which are not Included In patient COltl, pleale e.plaln the ty, 8IUtt, en .ethod of 

deter.lnlng different aclnlltratlve cost cants. 

6. If revenus and relllrletnts are not bosed on actual Individual reverues or rehnbUsellts for speel flc patlenta, please describe the Method used to 

determine the 880ts of revenue or reimbusemets. 

7. Oocunt cexpleln) how the ruer of users (Reported! Un \!ect9oo U Nail deterlIOne. 
.......... .................... ..... .. ..... ..... .......... ..... 

...... 

.. ..... ... ............... .. .......... .................... 

......!..

.... 

. !...

!...

..

......!.....

.....!...

....... ............... ...

.................... 

.....

........ ............... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... 

..... ... 

;:. ............... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... .......... ..... ..... ..... ..... ... 

!......... 

!....... 

:. !... . . 

!. ............. . 

!.... 

.... 

:..!................ .....

.... ::::::

..... .......................................................... 

........:

..... ..... 

.................... .................................................................................... I HISP COUNtiES I A. NAME OF 

,

j

.... ...... .... j ;;; ;;;:; . . ;. ; ;;

; 

;;;;. j 

; 

;;j

.

.. . ;. ;. 

,

. ;;

. .... sa. a: ..c.. a:... -== =2 ..... ..s.. 8C= == ae.=c e sc:e= S D.. a: =.8 = : == = 8=== s ==a ..... ..aZ2. :8C8 ...=8 . c e= E .:ca 8 cce === d: -==== sea.: =e... e == z= ===: = z =: %= = =z == .8 COUty 

19BR/89 I 'ISCAL YEAR 


I lEGALIZED INDlf Nr HEDICAl ASSISrANCE (lIHA) COStS REronr (Rev. 01/26/09) I 

..... .22.. .e ..... ..E.. ..... ... ea ..... ..... 


I. RErotlNG rERIOD: (Check tho Ippoprloto 'Ines) 

ACtUAL UNRElH_SED LIMA COIS FOR THE GUARIER ENDING: SEPUMDER 30, 19M . Due March IS, 1989 

ACrUAl UNREIHIUSED lIHA COST;; 'OR TIle ClARnR ENDING: DECEHIER 31, 190 . Duo Hirth 15, 1989 

ACtUAL UNRElM_SED LIMA COJS FOR "IE GUAInER ENDING: "ARCH :U, 1989 . Due "ay IS, 1989 ACtUAL UNREIH_SED LIMA cors fOR rIf GUAlnER ENDING: JUE 30, 1989 . Due August IS, 1989 

FINAL STATE f.Y. UPOT '01 TIl PERUD: JUy " 198 tHROUGH JUNE 30 , 1989 . Due March 31 , 1990 .... ....s...........k8........................s.. ................................... 8Z8:8 ..se......... c. ..... 


REPOr 

1 D. 8AS IS OF 

LIMA ElIGI8lE U8ER OF I CHARGES RATIO I COStS I TOTAL COUNTY COSTS I TOTAL REVENUES I UlREU8URS'E I 

SERVICES PROVIDED I PATlEN' DAYS, I PER coStS I PER I OF PROVIDING I or REIHBURSEMENtS I LIMA 

DAYIYISn ro DAYS , VISITS, SERVICES TO I RECEIVED BY COO"I COStS CLAIMED eppoprlet4. boA) TO I VISnS CHARGES OR REPOTED lUlU C(INTY COSTS) (Check the IlIlGENfS LEGALIZED or IRCA I 'OR COSTS 

(COl. S. 6)


I PURSUANT TO IRCA I EliG. DETER. I EliG. DUER. llEGALIZED INDIGENtS I IN COllRl 5 

............811. ..... ..... .......... ..... .......... ...a. ..... ........-......................... a-
 I......... .J. - Stetl,tlc,-, S8I1.
 IRCA MlC 8ENEFICIARIESI (COL. Z X 3)


- Cn. Spec: lI' EMERGENCY cosrs 


I.... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... .... ..... ..... ..... .00.. ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... Stetlstlcel SlIle 

IIICA MlC 8ENEFICIAIIESI
 lI PREG RELATED COSTS I I (COL. 2 X 3)1 Cese Spec. ':Ie 

C) .... ..... ..... ..... ... ::CA I , I X 4) ::I :8Il. 

I =
 :;T I (COL. 2 X 3) 1 (COL.­

i" .... ..... ."' i"""'" i . ;.. i". I;;;; :. Ces. Speel fie I (ITPATlEN' SERVICES I 


I.... ..... ..... ..... ..... 


IICICXXXXXXXXXXXXXXXXIC ISECr. 170oo/"ISP IRCA I IXJOXXlOxxlJOXXXXXJOI I (COL. 1 .4) 

I XXXXXXXXX lau" AD" I N I S TIA TI (I IxxJOXJJOXIOX I XIOIO XIOXX IIOXXXIOIOIIOIOIlIOXXXXXX I XIOIO XJOXIO Of II MA Ix ICXXXX I XXXXXXXXXIII XXXX XIOIO I XXXX XXXXX XIOIII IIOJOXXXXX XIOXX XIOJOXJO 

I"" .. i::: ::i::::: i::::::::i::::::::j""""""." ...... i'" ................ i"'."'" ..... i:::::
 ...e......................................... ..... ..... ..c.. ..ac: :..=8 8eaa...... 


NUBER OF IReA 170,"ISP ELIGI8LES SERVED: 1:1 UIUCATED muT 1:1 IIICATED C(INT 

NUER OF IRCA'AFDC IENEFICIARIES RECEIVING


NO- EHERGENCY SERVI CES C:I UNtIliCATED CONT 1:1 DULICATED COUNT


NUBER OF IRCA'MEDI'CAlIEMEFICIARIES, PREGNAM'


UDN RECEIVING NO.PREGNANCY SERVICES i== UNLICATED COr 1:1 IIICATED COUNT

..:. .. .................... ...... ..... ..... 

\ .. .. ... . . . 

.. .. . ... . . . 

.. .. . .... ... .. ... .. 

.. . .. 

.. . .. .. . .. . . . . . .. . .. .. . . . .. . .. . . . . 

.. .. . . . .. . . . . . . .. .. . .. . . . .. .. . .. .. . .. .. ..... . .... . ... . . . . . . . .. . . .. .. ... 

..... .......... ............................:

..... ........ 

.: ..... ..... ............. 

..... ..... .......... .......... ..... 

:

;:. ; :;: ;;;.; .; ;;; . ;; ; . ;;;:;; .... ..... ..... .,... ...... ..... .... ..... ..... .......... .,... ..... .....

:;; ; 

;

;

;;;

; ;

;

;;

;;:: ;;;;;

; :;:

; 

;;; 

as... . . ancw. es. ..... ..... ..... ..... ..... ...sa ..... a.a= :.'.8 ..... ss 8S t c: e e:ee 8 .......... ee... ..... ..... ..... as=.. ..... ..... ..... ..... 8SS.. 2.= c..e ::


SUHRY OF COSTS
 1 ,. 
 . ..... ...1 

I.... ..... ...,. ..... ..... 


, 1. TOTAL LIHA COSTS CLAIMED IN PREVIOUS 1988/89 OURTER(S)


1-. .. . .. .. 


UM aJn CLAIMED fOR 'HE Pfllm JUy " 1988 THROUH JUE 10, 1989 TO DATE..... i .. I J. TOTAL 
 ;:S ;= : ;8;;:8:;;8:::;:8 ;:;;;:::;8 ;	 :: 8 ;;8;:8 ; :S8.= 8.. 

Icgel hed pusuant to 1..lsratlon aefonl en Control Act(lRCA) end thet the cCKty has on fHe dounentatfon to I pot luch UWelnbrled costl. . 

REPORT PREPARED BY PHON NUHER DA TE PREPARED 

..8S ...82 ................................... ..... 88..........:..28::2 -=.....28:..... ..... ..... ..... 


STATE US ONLY
 COUNTY AUDITOR CONTROLER (REQUIRED ON FINAL REPORT ONLY) I H. CERTI FICAT ION .Y 
 ATE I hereby certify thet the Total UneldJrsed U.. Cost Clallled ebove I s I Ported by IREVIE"ED .Y: DAlE Off Ielal CCKty Recorc1 and II eccurate to the bes t of rt knowl edge. IAPPROVED .Y: 

AUTHORIZED: DATE AUTHctlZED 

SIGNATURE OF AUDITOR COTROLLER	 (or duly authorized repelentatlve DATE CERTIFIED 'PAYMENT AUTHOIZED .Y: AMOT with cop of official authorllatlon atteched) ............... .......... Z&8=a a:c.:: 2....... ..... a=C.8 _.=as c.=...... 

'( I. BACKUP MTERIAL (ATJACI ADDITIONAl PAGES TO AHS R THE FOlLOIING QUESTIONS) 

1. Docllt (explain) the _thod used In dete..lnlng mreillursed LIMA coste al Indlceted In Section D. Depnding the bo checked, pleose explain 

the Method uti I lied: co.lete cese lpeclflc dete or vllid Itetlstlcal I Ie. 

a. How WIS the 1..1. dra..?
b. Pleese s lt the 1..1. queltlonnlre.


c. Does the SUMI. tet. Into accout these fectors: 

(1) F rl!nc (2) TI.lng of sMfI. (J) Tren over tllI (4) leml. II Ie In relation to service popletlon 

d. Are the Method used loglcel and result In e stetisticlily velld slRple?


e. "'et wes the esth.ted cost I In doing the s Ie? 

2. Docunt (expl.ln) the IIthodiogy used to Idetify eligibles forwhOlUM coati ere clellned. In acUltlon, Indicate the typ en locetlon of the 

dounentetlon which II aVlnebie for 8Idlt purposes. 

3. Pleese expleln how chergel end costs were deter.lne.


4. If cherges are redued to costl by using the retlo Method (Colum 3): doC:lIt how each retlo wes deter.l.-d. 

5. If couty edlllniitretive COltl of LIMA are claill (Colu. 5) which are not Included In patient cOltl, pleale explain the typ, 8IWlt, and .ethod of 

deter.lnlng different 8dlnlstratlve cost compots. 

6. If revenul end ralllrs_ntl are not based on ectuII Indlvlduel reveruel or rehllbulelltl for lpecl flc patlentl, pleese describe the lIethod used to 

deter.lne the emotl of revenue or reimbusemets. 

7. Documt (explain) how the nuer of userl (Reported 9n $ gon we. deter.One. 
. . ;;

:;. 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 services and costs 

included on Section C, lines 5, 6, and 7 of the LI Costs Report (Section 17000/MISP LI Inpatient Services, Outpatient 	services, and Emergency Services respectiv The intent of this table is to separate out those LIM 

services and unreimbursed costs provided by county facilities and staff from those provided by non county facilities and staff. Note that the requested data is for "unreimbursed costs" (Colum 7 from the LIMA Costs Report). 

Colum 1 Enter the numer of LIMA days or visi ts provided by

county facilities and staff to IRCA legalized residents on the inpatient, outpatient and emergency services lines as appropriate.


Colum 	 Enter the unreimbursed cost per unit of service on each line 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 and staff for each type of service. 

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 how these costs were 

identified and calculated.


Enter totals for all colums. Please ensure that the
 total unreimbursed costs incurred by county and non 

county providers sums to the total of colum 7, lines 

6, and 7 of the LIM Costs Report.


Section B


This. portion of the LIMA Supplemental Data Form is 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 and the county, and those who were entirely funded by the county. Note also that we are a.. 'd. ng for qross cost 

i:':"-:ormati -. as well as r anues from di'-\:cll cind other sources in this portion.


Colum 

Colum 2


Colum 

Colum 

Colum 5


Colum 

Colum 7


Enter the numer of pregnant women falling into each 

category for the reporting period.


Is the numer of services or encounters provided?


Is the qross cost of the services provided during the


reporting period?


Is this total gross cost of services provided?


Is this fiqure the amount Medi -Cal payments
 received (billed)?


Is the amount of other revenues (e. g. patient
 payments, other third parties ) received or billed indicated? 

Is this figure the unreimbursed cost charge to LIM 

for the reporting period? 
...............

.............. . 

..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... ..... 

....... 

!!....... .

. .... ..... ..... ..... ...... .... .......... ..... ..... ..... ..... ..... ........... .... ....... ... 

. . .... ..... ... . 

: ... .. 

..... ..... ... . 

. 

.... . .... .... . .. .. ... .. . .......... .......... ...... ......... ..... ..... ..... ..... ..... ..... ..... .......... ..... ............ ...... .............. .... :. ::: . .. :. :.. . 

... 

!,... .... 

.... .

..... 

:.. 

.... . .... ..... ... .. . .. .. . . . .. .

......... .......... ... . 

..... .......... ..... ..... ..... ..... ..... ...... .... ..... ..... ..... ..... ...... .... 

..... ..... ..... ..... ... .................... ..... ..... ... ;.

.

..

,. ..... .

.... ;;;;..; ; ;;;;;. . .. . ;; 

;...... . .... ..... ,.... ..... ..... .... :;;; 

I' ''rIJ" U.' 1 '1; 'l f_ 

COUNn l;: 

..... R e... . 28. ... .....e.... ..... ..... 8ca.. ..B.. cc:cc .ess. .c= . .e:a: e ===- ===== =CQ.. .a... ..... ..... ...ae ...ew ..s...e... ..... ..... .............c- ae::- as:=s 


REPOTING PERIOD:


JUlY', '988 TlIROOH SEPTEM8EI 30, 19. JANUARY I, 1909 TlIRWGH MACH :11. 1989.


OCTOBR '. 1988 TlIROOGH DECEMBn 31, 1981 APR IL I, 1909 "IROUGH JUN 30, 1989


..... .....m.............. -:... ..: =2 =a=a: ..:.. ..... cc... ..... ..... ..... ..... ..... .. ..=:s c:ca... 

UrnOtLZDoo/"ISP ONLY 

CATEGORY I. .... .... 

UNREIMlSED DAYS/VISnS UNElMaJRSED 'OfAl II DAYS/VISnS TOTAL 

COST PEl IUNREINURSED COTS II COST PER UNREltlSED COSTS 

....D ..... ...... ..... .... ..... ..... ..... ..... ..... ....


1..... ..... ..... . .. I. ... .. ... .. . .. .. .. I. . ... .. . .. .. . .. .. . 11.. . .. .. I... 1... . 	 . f' MPATIENT 	 1 . 1 , II 

1' .... ..... ..... ... 	 11" . I"......."'... ... . ............... "	 1'....'....'.......
 1'. ..... ..... ..... ' 11" .......... ,."'


................................................................. 8S... e8=.. cae.. 	 ......c................................


I. 	 aJTPATlENT PRENATAl AND POT PAIT'" CARE ONLY 

r.­ .........0............... .......... ...... -.0. ..... ..... ..... ..... ..... ..... ..... 


I ... 

1... 1.. 1... 	 1.. 

PAITl' CtERED IY",C 

AND PARtlY 1700,"ISP


1'.... ..... ..... .. . 1' ..... ..... . .... . . 1" . .. .. ... .. . 1..' . .... ... .. ... . ' 1.. .. . .................. i 


1. ..... .... 1...... -......... .. 1........ .. 1................ .. 1......... ..... .... 


TOTALS I .1.......... ..... ... . ......... 


."..................8......"......"............... ............ .................... D..=.
 ............................................. .c... 


lUPT1NO NARRATIVE/METHOOGY	 I:; 

e..... - f 

Delcrlbe how services en Ulellnbursed COlts of nocouty feeilities en steff were Indtlfled 8n c:lculeted. Describe how outpatient prentet .. pot pert.. cere ..s IdenUUed IId leper8ted betwee "edt'Cet 8nd Section !l000 en perU., covered. 

PIEPAIED IY: TITLEs VELEPMONE NUER: DATE PREPAlEO I 
:!_... 

:,:..,;.,:,:: : ...:. _._ : "J, '!j.l).' ri: