Chapter 5
Cost for Administration, Planning, Evaluation, and Quality Monitoring  TOP

Introduction

The CARE Act defines administrative activities in Title II programs to "include routine grant administration and monitoring activities." Title II grantees may not spend more than 10 percent of their grant on planning and evaluation activities, not more than 10 percent of their grant on administration and, when combined, not more than 15 percent of their grant on planning, evaluation and administration. An exception is allowed for those States that receive a minimum allotment under the CARE Act Title II formula; they are limited to spending "not more than the amount required to support one full-time equivalent employee."

While the legislation does not require any single provider to meet administrative cost caps on their own, the State grantee must limit the aggregate administrative costs of its first-line entities to 10 percent of the total funds awarded to those entities. Grantees may also use up to five percent of their grant, or $3 million, whichever is less, for quality management programs.

The CARE Act includes several requirements regarding the use of Title II funds to carry out administrative activities. Some of these requirements apply to grantees, while others apply to lead agencies, consortia, and subcontractors.

Legislative Background  TOP

Section 2618(b) of the CARE Act defines administrative activities for Title II grantees under the following provisions:

Planning, Evaluation, and Administration Costs

Section 2618(b) limits Title II grantees to spending not more than 10 percent of their grant on planning and evaluation activities, not more than 10 percent of their grant on administration, and, when combined, not more than 15 percent of their grant on planning, evaluation, and administration. The provision reads as follows:

"(3) PLANNING AND EVALUATIONS.-Subject to paragraph (5) and except as provided in paragraph (6), a State may not use more than 10 percent of amounts received under a grant awarded under this part for planning and evaluation activities.

"(4) ADMINISTRATION.

"(A) IN GENERAL.-Subject to paragraph (5) and except as provided in paragraph (6), a State may not use more than 10 percent of amounts received under a grant awarded under this part for administration.
"(B) ADMINISTRATIVE ACTIVITIES.-For the purposes of paragraph (A), amounts may be used for administrative activities that include routine grant administration and monitoring activities.

"(5) LIMITATION ON USE OF FUNDS.-Except as provided in paragraph (6), a State may not use more than a total of 15 percent of amounts received under a grant awarded under this part for the purposes described in paragraphs (3) and (4)."

Exemption From Administrative Cost Cap

Section 2618(b)(6) exempts from the administrative cost caps those States that receive a minimum allotment under the CARE Act Title II formula. Those States are limited to spending not more than the amount required to support one full-time-equivalent employee, as follows:

"(6) EXCEPTION.-With respect to a State that receives the minimum allotment under subsection (a)(1) for a fiscal year, such State, from the amounts received under a grant awarded under this part for such fiscal year for the activities described in paragraphs (3) and (4), may, notwithstanding paragraphs (3), (4) and (5), use not more than that amount required to support one full-time-equivalent employee."

Regarding the 10 percent administrative cost cap, the Joint Explanatory Statement of the Committee on Conference, which accompanies the CARE Act Amendments of 1996, states:

"such expenditures [are limited] to 10 percent as measured across all entities receiving funding from Part A or Part B grantees, without regard to whether an individual entity is above or below that percentage. For example, if a state or eligible area awards $1 million to 10 service providers, regardless of the amount an individual provider spends on administration, the amount spent on administration added across all 10 providers cannot exceed $100,000 (10 percent of $1 million). For Part B grantees, entities subject to this cost cap include the lead agencies of consortia in carrying out their administrative duties associated with the operation of the consortium.

The Conferees wish to emphasize that grantees and subcontractors that can restrain administrative costs to less than 10 percent should do so. The set amount should be regarded as a ceiling, not a floor."

Subcontractor Administrative Costs

Section 2618(b)(4) limits the administrative costs of entities to which Title II grantees distribute funds. These costs are capped at 10 percent of the aggregate amount distributed to those entities. It also limits the administrative costs of the grantee, which are capped at 10 percent of the grant award. The provision reads as follows:

In the case of entities and subcontractors to which the State allocates amounts under the grant (including consortia under section 2613), that State shall ensure that, of the aggregate amount so allocated, the total of the expenditures by such entities for administrative expenses does not exceed 10 percent (without regard to whether particular entities expend more than 10 percent for such expenses)."

Section 2618(b) defines administrative costs for entities receiving CARE Act funds from Title II grantees as follows:

"(C) SUBCONTRACTOR ADMINISTRATIVE COSTS.- For the purposes of this paragraph, subcontractor administrative activities include-

"(i) usual and recognized overhead, including established indirect rates for agencies;
"(ii) management oversight of specific programs funded under this title; and
"(iii) other types of program support such as quality assurance, quality control, and related activities."

Quality Management

Section 2612 (d) requires States to establish quality management programs and identifies up to five percent of grant funds, or $3 million, whichever is less, for this purpose, as follows:

(d) Quality Management.-

(1) Requirement.-Each State that receives a grant under this part shall provide for the establishment of a quality management program to assess the extent to which HIV health services provided to patients under the grant are consistent with the most recent Public Health Service guidelines for the treatment of HIV disease and related opportunistic infection, and as applicable, to develop strategies for ensuring that such services are consistent with the guidelines for improvement in the access to and quality of HIV health services.

(2) Use of funds.-From amounts received under a grant awarded under this part for a fiscal year, the State may (in addition to amounts to which section 2618(b)(5) applies) use for activities associated with the quality management program required in paragraph (1) not more than the lesser of-

(A) 5 percent of amounts received under the grant; or
(B) $3,000,000.

HAB/DSS Expectations  TOP

HAB defines quality as follows: "Quality is the degree to which a health or social service meets or exceeds established professional standards and user expectations." Evaluations of the quality of care should consider: (1) the quality of the inputs; (2) the quality of the service delivery process; and (3) the quality of outcomes, in order to continuously improve systems of care for individuals and populations." HAB supports several activities to improve the quality of HIV/AIDS services. These include the Primary Care Assessment Tool, HIVQual, and a series of Technical Assistance Monographs on quality.

A. Quality Management Programs Should Accomplish a Three-fold Purpose:

1. Assist direct service medical providers funded through the CARE Act in assuring that funded services adhere to established HIV clinical practice standards and

Public Health Service Guidelines to the extent possible;

2. Ensure that strategies for improvements to quality medical care include vital health-related supportive services in achieving appropriate access and adherence with HIV medical care; and

3. Ensure that available demographic, clinical and health care utilization information is used to monitor the spectrum of HIV related illnesses and trends in the local epidemic.

B. Quality Management Programs Should Have the Following Characteristics:

1. Be a systematic process with identified leadership, accountability, and dedicated resources available to the program;

2. Use data and measurable outcomes to determine progress toward relevant, evidenced-based benchmarks;

3. Focus on linkages, efficiencies and provider, and client expectation in addressing outcome improvement;

4. Be a continuous process that is adaptive to change and that fits within the framework of other programmatic quality assurance and quality improvement activities (i.e., Joint Commission on the Accreditation of Hospitals Organization (JCAHO), Medicaid, and other HRSA Programs); and

5. Ensure that data collected is fed back into the quality improvement process to assure that goals are accomplished and that they are concurrent with improved outcomes.

HAB/DSS will monitor grantees to ensure compliance with the implementation of the new requirements through questions in the application guidance, progress reports, and site visits. Chief Elected Officials will be asked to sign assurances in the annual application attesting that quality management programs are in place that meet the above outlined objectives.

(2) USE OF FUNDS. From amounts received under a grant awarded under this part for a fiscal year, the State may (in addition to amounts to which section 2618(b)(5) applies) use for activities associated with the quality management program required in paragraph (1) not more than the lesser of:

(A) 5 percent of amounts received under the required grant; or
(B) $3,000,000 whichever is greater.

A. The use of an additional 5 percent of funds is intended to assist grantees in evaluating and improving the quality of primary care and health-related supportive services provided under this act. Grantees may use up to 5 percent of amounts received or $3,000,000 whichever is less. The 5 percent or $3,000,000 is calculated against the Title II Award. In deciding what activities to undertake, quality management should be coordinated with currently funded quality assurance activities.

B. As applied to clinical quality programs, these costs include, but are not limited to activities such as: 1) chart review; 2) peer-to-peer review activities; and 3) data collection to measure health outcomes or indicators, or other types of activities related to the development or implementation of a clinical quality improvement program.

Many of these same activities and costs may apply to the development or implementation of a support service quality management program. While the focus and ultimate goal of quality management is improved health status for clients, the quality management program looks beyond clinical services to include consideration of both supportive services that link clients with health care and community/population outcomes.

C. Title II grantees must separate administrative costs from planning and evaluation and quality management costs. Grantees using funds for quality management activities must multiply their award by 20 percent and ensure that, when combined, the selected levels of spending for planning, evaluation, quality management, and administration are within that calculated amount.

Definitions  TOP

Defining Administrative Costs  TOP

Following are definitions of administrative costs for Title II grantees, first-line entities, and first-line entities with management and oversight functions.

Title II Grantees  TOP

Administrative costs associated with the 10 percent administrative cap for Title II grantees include the following:

• Development of funding applications
• Receipt and disbursal of program funds
• Development and establishment of reimbursement and accounting systems
• Preparation of routine programmatic and financial reports, including the minimum requirements of completing the CARE Act Data Report (CADR)
• Compliance with grant conditions and audit requirements, and
• All activities associated with the grantee's contract award procedures, including the development of requests for proposals, contract proposal review activities, negotiation and awarding of contracts, development and implementation of grievance procedures, monitoring of contracts through telephone consultation, written documentation or on-site visits, reporting on contracts, and funding reallocation activities.

First-Line Entities  TOP

Administrative costs associated with the 10 percent aggregate cap for first-line entities funded directly by the grantee include the following:

• Depreciation or use allowances on buildings and equipment
• Operating and maintaining facilities
• General administration and general expenses, such as the salaries and expenses of executive officers, personnel administration, and accounting
• Overhead and indirect costs (including indirect cost rates)
• Management and oversight activities of specific programs under Title II, and

First-Line Entities/Lead Agencies with Management and Oversight Functions  TOP

While first-line entities are subject to the aggregate cost cap associated with the administrative activities listed above, they may also be subject to the grantee administrative cap associated with the following activities:

• Developing funding applications and proposals
• Receipt and disbursal of program funds
• Development and establishment of reimbursement and accounting systems
• Preparation of routine programmatic and financial reports, including the minimum requirements of completing the CARE Act Data Report (CADR)
• Compliance with contract conditions and audit requirements, and
• Subcontract monitoring and reporting, through telephone consultation, written documentation or on-site visits, developing funding applications and proposals, and the receipt and disbursal of program funds.

Non-Administrative, Non-Service Activities  TOP

Planning and Evaluation (Grantees)

Planning and evaluation includes grantee activities related to planning for the use of Title II funds and evaluating the effectiveness of those funds in delivering needed services. Specific activities that planning and evaluation funds may support include the following:

• Capacity-building to increase the availability of services
• Technical assistance to contractors
• Program evaluation
• Assessment of service delivery patterns
• Assessment of need
• Obtaining community input
• Developing and implementing the Statewide Coordinated Statement of Need, and
• Consortia support.

Consortia may use CARE Act funds to support certain activities related to carrying out their legislatively mandated functions. These activities include the following:

• Planning and development of comprehensive outpatient health and support services
• Assessment of service needs within the consortium region
• Developing standards of care
• Case management coordination
• Periodic evaluation of the success of the consortium in responding to identified need, and
• Evaluation of the cost-effectiveness of the mechanisms used by the consortium to deliver care.

Program Support and Quality Control by First-Line Entities  TOP

Program support and quality control activities for first-line entities include the following:

• Client satisfaction surveys
• Technical assistance to subcontractors, and
• Staff training.

Calculating Administrative Cost Caps  TOP

Grantees

Title II grantees must separate administrative costs from planning and evaluation costs. For each category of costs, grantees multiply their award by 10 percent and select a level of spending for each category that is within that calculated amount. Grantees must then also multiply their award by 15 percent and ensure that, when combined, the selected levels of spending for planning, evaluation, and administration are within that calculated amount. For example, if a Title II grantee receives an award of $3,000,000, it can spend up to 10 percent ($300,000) on administration and up to 10 percent ($300,000) on planning and evaluation. However, the combined total cannot exceed 15 percent ($450,000).

First-Line Entities

The basis for calculating the aggregate administrative cost cap under Title II is the total amount remaining after the grantee takes its administrative, planning, and evaluation costs out of the award. The 10 percent factor is applied to this total amount. For example, if a grantee receives a grant award of $3,000,000 and uses the maximum amount of 15 percent ($450,000) for its own administrative, planning, and evaluation activities, $2,550,000 remain for distribution. For first-line entities which receive that $2,550,000, a maximum of 10 percent ($255,000) can be charged to the Title II grant for administrative costs. That is, regardless of how much an individual first-line entity spends on administrative costs, when added across all such entities, administrative costs that are paid for with Title II CARE Act funds cannot exceed $255,000.

Applying Administrative Cost Caps  TOP

Grantees

Title II grantee administrative, planning, and evaluation costs charged to the Title II grant must fall within the limits as calculated above. Title II grants include a Federal earmark for the AIDS Drug Assistance Programs (ADAP). The calculations for administration, planning, evaluation, and quality management costs must be done separately on each portion of the grant. The selected percentages taken from each part of the grant do not have to be the same, but they each must fall within the caps as calculated above. Any funds taken out of the ADAP earmark must be spent on the grantee's administration, planning, evaluation, and quality management costs related to the ADAP.

Title II grantees are free to use as much of that non-earmarked amount for ADAP as they see fit. There is no requirement that funds taken out of that non-earmarked amount for administration, planning, and evaluation be used in any set proportion between ADAP and other program components.

First-Line Entities

The 10 percent administrative cost cap applies only to first-line entities. First-line entities include consortia lead agencies, any service providers or other entity funded directly by the State, and State-run programs such as ADAPs, Health Insurance Continuity Programs, and Home- and Community-Based Care programs. A program's administrative costs may be separated from the grantee's administrative costs if the program is run by the grantee itself or by a closely related unit of State government.

Given the clear Congressional intent to limit administrative costs, grantees, through their contracts with first-line entities, should impose a separate 10 percent administrative cost cap on any "second- or third-line" entities which receive CARE Act funds from a first-line entity. That is, of the amount awarded to an individual second- or third-line entity, a maximum of 10 percent can be spent on administrative costs. Consortia, especially, should be required to limit the administrative costs of the entities to which the lead agency distributes funds. Without such a requirement, an entity receiving both Title I and II CARE Act funds could be subject to two different cost caps since it is a Title I first-line entity and a Title II second-line entity. While exact parity in costs caps is not necessary, some restriction on the Title II consortia funds should be required.

During the contracting process, grantees must work with their first-line entities to negotiate a final budget that appropriately classifies funded activities, personnel, supplies, material, and other expenditures as administrative or service costs. Administrative costs count against the 10 percent aggregate cost cap; service costs do not. For those situations in which a unit cost system is used to pay a contractor, the unit cost must be broken down so that the distinction can be made between administrative and service costs. The same administrative costs caps apply.

Because of the diverse characteristics and accounting practices of governmental units and nonprofit organizations, it is not possible to specify the types of costs that may be classified as administrative or service-related in all situations. A case management organization, for example, may include some telephone expenses as a service cost, since it is directly related to service delivery. A food distribution program may assign some or all rental expenses as a service cost because storing the food is directly related to delivering the service.

In general, grantees should utilize their own guidelines in making these classifications. Guidelines used to assign particular costs to the CARE Act should be consistent with guidelines used to assign particular costs to local funds or other, non-CARE Act, Federal funds. However, requirements specific to the CARE Act must be followed. The legislation stipulates that administrative costs for first-line entities include usual and recognized overhead (including indirect cost rates), costs associated with management and oversight of specific programs funded under Title II, and costs associated with program support such as quality assurance, quality control, and other related activities.

The legislatively mandated functions of consortia are not counted against the administrative cost cap. These activities include the consortium's planning and evaluation costs. Because consortia are subject to State requirements regarding their administration and functioning, Title II grantees should require consortia to identify these consortia support activities and allocate a reasonable amount of funds to carry them out.

Documentation and Compliance  TOP

Grantees

Title II grantees are required to submit categorical budgets and narrative justifications to the GMB for approval. These budgets must be submitted for administration, planning, evaluation, and services. Project officers and grants management staff review the grantee budgets and determine whether the grantee's administrative costs fall within the statutory limits.

Attachment 1 at the end of this chapter is a sample of the completed budget form and narrative that breaks down each budget category (administration, planning, evaluation, and services) by object class categories (e.g., personnel, travel, equipment, supplies).

First-Line Entities

Governors (or their designees) are required to sign program assurances with their application to HRSA for funding (SF 424B, Program Assurances). Included among them is an assurance that the 10 percent aggregate administrative cost cap requirement will be met. Like all other program assurances and legal requirements, compliance is subject to audit by such entities as the Office of the Inspector General at the Department of Health and Human Services and the General Accounting Office. DSS strongly recommends that grantees encourage first line entities to use a budget format that clearly identifies the costs for administration (as defined in this chapter under "Definitions, Defining Administrative Costs, First-Line Entities").

In their budget justifications, grantees will be required to identify the following information for "first-line" entities:

• Aggregate amount of funds available for the entities to spend on administrative costs
• Estimate of the total amount of administrative costs those entities will incur over the budget year.

At the end of the budget year, as part of the final progress report submitted to the GMB, this information must be updated to reflect actual expenditures. Both the initial and final documentation of these figures will have to be signed by the financial officer in charge of the CARE Act grant.

REFERENCES  TOP

Health Resources and Services Administration, HIV/AIDS Bureau, Division of Service Systems. Title I Manual. Rockville, MD: U.S. Department of Health and Human Services, 2002.

ATTACHMENT 1  TOP

Ryan White CARE Act - Title II Formula Grant
Budget Narrative/Justification

1. Program Development Supervisor, 1.0 FTE $70,618
This individual is responsible for the overall planning, development, and evaluation of the community-based care consortia initiative. Responsibilities include: develop/review/ evaluate all program objectives and activities; perform individual program evaluations; perform strategic planning for the expansion of the consortia model, and serve as the consortia development and resource person. This individual will supervise the Program Development Specialist I in charge of planning and the Supervising Public Health Representative in charge of Ryan White coordination.

2. Supervising Program Development Specialist, 1.0 FTE $61,791
This individual will serve as the unit supervisor in charge of monitoring all Ryan White funded contracts and letters of agreement. Will supervise the Community Service Officer I and Public Health Consultant II.

3. Program Development Officer, 1.0 FTE $57,063
This individual will serve as one of the community-based care consortia program officers. Responsibilities include: oversee the consortia health service grants via monthly site visits to monitor the work activities and the achievement of objectives; serve as resource/ contact person for developing linkages with other AIDS service providers; review grant expenditures to ensure fiscal compliance; accumulate, edit, and analyze program data; assist grantees in pursuing additional technical and financial assistance; and prepare correspondence and reports necessary for this initiative.

4. Program Development Officer, 1.0 FTE $61,291
This individual will serve as one of the community-based care consortia program officers. Responsibilities include: oversee the consortia health service grants via monthly site visits to monitor the work activities and the achievement of objectives; serve as resource/ contact person for developing linkages with other AIDS service providers; review grant expenditures to ensure fiscal compliance; accumulate, edit, and analyze program data; assist grantees in pursuing additional technical and financial assistance; and prepare correspondence and reports necessary for this initiative.

5. Public Health Consultant II (Nursing), 1.0 FTE $65,027
This individual will plan, organize, direct, and evaluate the delivery of health care services by the grantees and subgrantees under Title II. Specific Responsibilities include conducting site visits, performing chart audits, conducting patient flow analyses, and providing consultation on the efficient and effective delivery of primary care for individuals with HIV. Forty percent of this individual's time has been approved as direct client service.

6. Supervising Program Development Specialist, 1.0 FTE $70,618
This individual will administer the AIDS Drug Distribution Program. Specific activities include negotiation and monitoring Title I ADDP contracts, negotiate rebates with pharmaceutical companies, and prepare programmatic and fiscal reports. In addition this individual will supervise the Program Development Specialist I and provide additional administrative support and supervision for the HIV Insurance Continuation Program.

7. Program Development Specialist, 1.0 FTE $59,177
This individual is responsible for the development and implementation of the HIV Insurance Continuation Program. Responsibilities include developing policies, processing applications, insuring payment of premiums, and preparing fiscal and programmatic reports. Ninety percent of this individual's time has been approved as direct client service.

8. Health Data Specialist II, 1.0 FTE $56,461
This individual will provide assistance to the Research Scientist II in all efforts related to the development and maintenance of those databases requisite for program monitoring and evaluation under Title II. This individual will be responsible for the routine tasks of data checking, cleaning, and data entry and for producing summary reports using the structures developed by the Research Scientist II.

9. Research Scientist, 1.0 FTE $48,023
This person is responsible for all coordination activities between Title II programs and other Ryan White-funded programs in the state. This person will attend Title I Planning Council meetings, serve on their subcommittees, serve as liaison with both the Title IV Pediatric AIDS centers and the Title III early intervention clinics, and coordinate all Title II activities with the following entities; CDC community planning group, AIDS Clinical Trials Group, AIDS Education and Training Centers, Ryan White Special Projects of National Significance, HUD Housing Opportunities for People with AIDS, and the CDC HIV counseling and testing sites.

10. Program Planning Director, 1.0 FTE $61,291
This individual is responsible for the development of a comprehensive state plan for the delivery of health and support services for individuals and families with HIV. This plan, a requirement of continued Ryan White funding, will serve as the blueprint to guide Ryan White efforts in future years. This individual will be responsible for initiating and staffing a statewide Ryan White Title II task force to assist this Division in developing the appropriate programs to meet the needs of the HIV-infected population in the state, and for planning and implementing a service of public hearings to be held to gather community input into the planning process.

11. Contract Officer, 1.0 FTE $53,860
This position oversees processing of all the Ryan White health service grants. Responsibilities include the review and processing of required reports, such as expenditure reports, cash status reports, and budget revisions/justifications.This individual will ensure fiscal compliance from all granting agencies.

12. Principal Clerk Typist, 1.0 FTE $30,920
This individual is responsible for all of the data entry activities related to the administration of the Health Insurance Continuation Program.

13. Office of the Assistant Commissioner, $52,500
A percentage of the time of the Office of the Assistant Commissioner is charged to the grant for administrative oversight. (See Business Proposal).

14. Programmer, 1.0 FTE $36,942
This individual will be responsible for data programming and analysis for the Aids Drug Distribution Program (ADDP). This person will be assigned to the Division of Human Services, which administers ADDP.

15. Claims Reviewer, 1.0 FTE $34,380
This individual will review and process all applications and claims for the AIDS Drug Distribution Program, and also will be assigned to the Division of Human Services. Ninety percent of this person's time will be considered direct client service.

16. Perinatal Counselor, 1.0 FTE $55,776
This individual will be responsible for working with all Ryan White providers in ensuring access of pregnant women to HIV counseling and testing and the providing of pharmaceuticals to prevent perinatal transmission. Overseeing compliance with spousal notification is also this individual's responsibility.

17. MIS Assistant, 1.0 FTE $33,447
This individual is responsible for the organization, input, processing and output of client data and client services under the HIV Home- and Community-Based Care Program. Specific activities include assistance to agencies in the preparation of service data, communication with staff regarding computerized outputs, preparation of payment vouchers, and assistance to the program supervisor with administrative, fiscal, and program review and evaluation.

18. Administrative Assistant, 1.0 FTE $40,200
(See below)

19. Administrative Analyst, 1.0 FTE $40,200
| These 2 individuals will be responsible for conducting site visits to each of the 83 provider agencies installing new and/or revised data management systems and providing on-site technical assistance. They will provide training, identify system errors, and oversee the exporting/importing of data amongst service providers, the consortia, and this Division. They will play a key role in quality assurance activities designed to verify they accuracy and completeness of the data by reviewing client level data and provider/consortia verification reports to improve data reliability and quality. They will also assist in the development of user manuals and standard operating procedures.

20. Data Processing Analyst II, 1.0 FTE $48,407
This individual will be responsible for assisting in the development, implementation and quality assurance activities related to the databases of the four Title II funded activities. Specifically, this will involve conducting system analyses, designing new software systems and reprogramming existing systems to ensure compatibility with the URS client level data required by HRSA; systems testing; installation, and/or conversion to new or revised systems; investigating problems, developing and recommending solutions, planning and initiating corrective action measures; and, designing quality control activities to verify the accuracy and completeness of the data.

1. As per business proposal 20.95 percent

1. Out-of-state travel for 10 trips (5 two-day meetings attended by 2 persons each) from Elmwood to Washington, D.C. for technical assistance and consultation meetings with other grantees and HRSA staff. Estimate for train fare, meals, lodging, taxis = $4,000

2. Local travel is to support the 18 professional positions during FY'97 in state travel to subcontract and consortia sites for technical assistance and consultation. The following formula is used approximately 4333 miles/month x 12 months x $0.25 mile (per business proposal) = $12,999

This activity will consist of a study by an outside peer review organization that will assess the prescribing patterns of physicians who enroll clients in the State's drug assistance program for quality assurance purposes. Details of this endeavor can be found in the ADAP Narrative Section of the application.

To modify a portion of the Division's existing office space to comply with confidentiality requirements associated with the data initiative described in the Implementation Plan for 1998.