Loading...
HomeMy WebLinkAboutMINUTES - 12171996 - D13 D.13 TO:' BOARD OF SUPERVISORS F&HS-05 SE Contra FROM: FAMILY AND HUMAN SERVICES COMMITTEE Costa 4 County DATE: December 9, 1996 REPORT ON THE OVERSIGHT OF THE COUNTY'S CONTRACTS WITH SUBJECT: THE PITTSBURG PRE-SCHOOL COORDINATING COUNCIL AND UNITED COUNCIL OF SPANISH SPEAKING ORGANIZATIONS SPECIFIC REQUEST(S)OR RECOMMENDATION(S)&BACKGROUND AND JUSTIFICATION RECOMMENDATIONS: 1. AUTHORIZE the Executive Director, Private Industry Council, to simply file written reports to our Committee on the status of its contract with the United Council of Spanish Speaking Organizations (UCSSO), as long as there are no further substantive details which need to be addressed. 2. DIRECT the Health Services Director to report to the 1997 Family and Human Services Committee on the status of plans to put out to bid those contracts under the purview of the Department (such as the Senior Nutrition Program) which have not been put out to competitive bid for a number of years. 3. DIRECT the Community Services Director to report to the 1997 Family and Human Services Committee during the first quarter of 1997 on the status of the State's "Conditional Status" on its Child Development and Pre-School contracts with the Pittsburg Pre-School Coordinating Council (PPSCC) before terminating the existing pre-audit of the expenditures for the County's contract with PPSCC. 4. DIRECT the Community Services Director to report to the 1997 Family and Human Services Committee during the first quarter of the year on the status of the audit of the contract with UCSSO for calendar year 1995 for the East County Head Start Program. CONTINUED ON ATTACHMENT: YES SIGNATURE: RECOMMENDATION OF COUNTY ADMINISTRATOR RECOMMENDATION OF B AR C ITTEE APPROVE -OTHER Vk SIGNATURE(S): MARK DeSAULNIER SMITH ACTION OF BOARD ON December 17 1996 APPROVED AS RECOMMENDED _X OTHER VOTE OF SUPERVISORS I HEREBY CERTIFY THAT THIS IS A TRUE UNANIMOUS(ABSENT ) AND CORRECT COPY OF AN ACTION TAKEN AYES: 1)4�5) 2 NOES: None AND ENTERED ON THE MINUTES OF THE BOARD ABSENT: None ABSTAIN: 3 OF SUPERVISORS ON THE DATE SHOWN. ATTESTED nprpmher 17, 1996 Contact: PHIL BATCHELOR,CLERK OF THE BOARD OF CC: See Page 2 SUPE tSORS AND C UNTY ADMINISTRATOR BY DEPUTY F&HS-05 5. DIRECT the Health Services Director, Social Service Director and Executive Director, Private Industry Council, to make further reports to the 1997 Family and Human Services Committee on the status of their contracts with UCSSO and PPSCC and any associated audits during the first quarter of 1997. 6. REMOVE this issue as a referral to the 1996 Family and Human Services Committee and instead REFER it to the 1997 Family and Human Services Committee. BACKGROUND: On October 1, 1996, the Board of Supervisors approved a report from our Committee which included the following recommendations, among others: 2. DIRECT the Community Services Director to return to our Committee on either October 28,1996 or November 25, 1996 on the status of the State's audit of its 1995-96 contract with PPSCC before implementing any decision to take PPSCC off of the pre-audit of their contact with the County. 3. DIRECT the Health Services Director; Social Service Director; Community Services Director;and Executive Director,Private Industry Council to report to our Committee again on November 25, 1996 on the status of their contracts with both UCSSO and PPSCC and to detail any problems of which they are aware so our Committee is brought up to date on these contracts before the end of the calendar year. The Community Services Director reported to our Committee on October 28, 1996 that the State Department of Education was still reviewing Pittsburg Pre-school Coordinating Council's 1995-96 independent audit. The November 25, 1996 reports were postponed by our Committee to December 9, 1996. On December 9, 1996, our Committee met with staff from the Health Services Department, Private Industry Council and Community Services Department and reviewed the attached reports. In addition, the Community Services Director, Scott Tandy, reviewed the status of the audit of the 1995 UCSSO contract with our Committee. We are concerned that some of the Health Services Department's contracts have not been put out for competitive bid for many years. We have asked Dr. Wendel Brunner, the Public Health Director, to provide a status report to the 1997 Family and Human Services Committee on efforts to put these contracts out to bid to insure that we are receiving the maximum value for the funds which are being spent on these programs and that all qualified agencies have an opportunity to bid on providing these services. cc: County Administrator Health Services Director Public Health Director Social Service Director Community Services Director Executive Director, Private Industry Council Executive Director, Pittsburg Pre-School Coordinating Council Executive Director, United Council of Spanish Speaking Organizations -2- CONTRA COSTA COUNTY • Social Service Department ®w a �4 John Cullen, Director OQST9`COUIZ'�,� November 18, 1996 To: Claude Van Marter, Assistant County Administrator From: John Cullen, Director RE: Follow-up Report to the Family and Human Services Committee Regarding Social Service Department Contracts with Pittsburg Pre-School Coordinating Council (PPSCC) This is a report of activities done by the Social Service Department in conjunction with the monitoring of program and the financial status of PPSCC's contracts. For more details on contract services and prior department comments please refer back to the Department's reports sent to you dated June 5, and September 16, 1996. 21-050-1 Contract renewed - New Term 7/1/96 - 6/30/97 Payment limit $27,228 (Same as prior) • This is a contract to provide interagency Family Preservation services through community based services. No change in the contract status. 21-302 Term: 4/1/96 to 9/30/97 Payment limit $155,292 • A required six month Program evaluation report was sent to the FPSP Collaborative (contractor) for completion. The required 6 month Evaluation Report has been received and reviewed by the Family Preservation Services Program Advisory Committee. As part of the response evaluation the contractor was to submit a 12 month service plan for the remaining portion of the contract incorporating the Advisory Committee recommendations. The 12 PPSCCI0.DOC ADMINISTRATIVE OFFICE: 40 Douglas Drive - Martinez - CA - 94553-4068 - Voice (510) 313-1500 - FAX (510) 313-1575 , month service plan has been received. The department is now in the process of developing a contract amendment to reflect the findings and recommendations adopted by both PPSCC and the committee. 20-443-18 Contract renewed - New Term 7/1/96 - 6/30/97 Payment limit $9,236 (Same as prior) • This is a departmental contract for state child care services and state funding. No change in contract status. 21-246-1 Contract'renewed - New Term 7/1/96 - 6/30/97 Payment limit $99,850 (Same as prior) • This contract is for the provision of Therapeutic Infant Care. No change in contract status. The department previously reported that the contractor hired a full time Controller. The new Controller has been most helpful in complying with the department's requests and requirements. The agency's supporting documentation for claimed costs is now better in terms of accuracy and detail. The agency annual audit has been received for the FY 95-96. Our review of the audit concluded that audit did not contain any negative comments or notes as measured against federal regulations or generally accepted accounting practices in reference to internal control polices, procedures, or administrative practices. The Department has no further plans for extra ordinary follow up with the agency. The department will continue to follow agency contracts in our normal monitoring mode. PPSCCI O.DOC Community Services DepartmentContra Child Development 3744-3994 Child Nutrition 374-3850 Administration Costa CommHead Start 646-5540unty Action 313-7363 1220 Morello Avenue, Suite 101 Martinez, California 94553-4711 I Housing and Energy 646-5756 (510)313-7350 C U n ty Fax: (510)313-7385 Scott Tandy, ' Director o di:mwe __ sra'coon DATE: November 21 , 1996 TO: Family & Human Services Committee FROM.* Scott Tandy, Director, Community Services Department SUBJECT: Status Report..Pittsburg Preschool Coordinating Council This memorandum is to provide members of the Committee with a status report regarding the Department's FY 1996-97 contract with the Pittsburg Preschool Coordinating Council (PPCC). We have been advised by the Manager of the State Department of Education Office of External Audits that the State is still in the process of reviewing PPCC's FY 96-97 audit (see attachment number one). As we have discussed previously, the State Department of Education placed PPCC on "conditional status " for its State funded FY 96-97 Child Development and Pre-School contracts. It is the Department's recommendation that PPCC remain on pre-audit until the State Department of Education removes the conditional status from PPCC's contracts. cc: Frances Greene Wilda Davisson Steve Shaltes Affirmative Action/Equal Opportunity Employer • , . Community Services DepartmentContra Child Development 374-3994 Child Nutrition 374-3850 AdministrationCosta Communty Action 313-7363 1220 Morello Avenue, Suite 101 Head Start 646-5540 Martinez,California 94553-4711 Count` , Housing and Energy 646-5756 (510)313-7350 Y Fax: (510)313-7385 Scott Tandy, Director s ST'9 COUN'- November 18, 1996 Mr. Steve Shaltes, Manager Office of External Audits California Department of Education 560 J Street, Suite 270 Sacramento, Ca 95814 Dear Mr. Shaltes: This letter is to confirm our November 18, 1996 telephone conversation regarding the status of Pittsburg Preschool Coordinating Council's (PPCC) FY 1995-96 annual audit report to your agency. Per our 11/18/96 discussion, you confirmed the receipt of PPCC's FY 1995- 96 independent audit by Mr. Angelino P. Cayanan, Certified Public Accountant. You further indicated that your office would attempt to conduct a desk review of PPCC's audit within the next 30 days, and would notify both PPCC and the County in writing of your findings and recommendations. As we have discussed, the issue of PPCC's current contract status with the State Department of Education along with PPCC's FY 95-96 audit has been discussed at both the October, 1996, and November, 1996, meetings of County Board of Supervisors' Family and Human Services Committee. This letter will be shared with the Committee to provide them with an update regarding this matter. Please call me at (510) 313-7361 if you have any questions. Thank you for your assistance. Sincerely, Al rince Administrative Services Officer cc: Frances Greene, Pittsburg Preschool Coordinating Council Inc. Scott Tandy, Director, Community Services Department Wilda Davisson, Child Development Program Manager 2 CONTRA COSTA COUNTY PRIVATE INDUSTRY COUNCIL 2425 BISSO LANE,SUITE 100 CONCORD, CA 94520 (510)646-5239.........FAX(510)646-5517 DATE: October 15, 1996 CONTRA COSTA COUN' 'Y ' RECEIVED TO: Claude Van Marter, Assistant CAO OCT 17 1996 OFFICE OF FROM: Arthur C. Miner, Executive Director. COUNTY ADMINISTRATOR Private Industry Council SUBJECT: STATUS REPORT - UCSSO CONTRACT The PIC currently has one contract with UCSSO for FY 96/97 with a payment limit of $110,294. This contract was awarded as a result of a competitive RFP process in June 1996. (By State regulation, JTPA service provider contracts must be competitively RFPed at least every 3 years.) UCSSO was the only bidder .for the Far East County PIC Regional.Office contract. This contract is. to provide employment and training services to JTPA Title II economically disadvantaged adults and out of school youth in the far east section of the County (Oakley and east; the area beyond Antioch). Services include: recruitment and orientation; eligibility determination and documentation; intake and assessment; alternate program referral; LMI; counseling; case management; referral and payment for vocational classroom, OJT, work experience and private sector internship training; documentation of competency attainment; child care and transportation stipends; job development and job placement. We anticipate enrollment of approximately 30 participants with a positive program termination rate of 75% and a 65% or better adult employment retention rate 13 weeks after program exit. The concept of the Regional Office is to bring together for eligible applicants at one location eligibility, training, case management and job development. Of the contract funds approximately $95,000 are for UCSSO expenses, the balance for vendor payments authorized by UCSSO. We act as the fiscal agent for all vendor payments; the internal expenditures are subject to pre-audit. Pre audit is a risk-minimization process. It is designed to validate that the service provider has documentation and by projection, administrative systems in place to support the cost reimbursement. There are no guarantees. There is also no standard pre-audit process of which I am aware. Pre-audit is restricted in scope, it focuses on the individual program or contract. The single audit is agency wide and focuses on the complete agency and its administrative and fiscal systems. As an example: if an agency has more than one program, when seeking reimbursement for space expenses (rent, utilities, maintenance, etc.) it should allocate those expenses equitably each program. There are multiple possible methods of allocation; possible bases are: square footage assignment, number of employees or hours charged to each program, salary costs per program, total direct charges per program, or participants per program. What' is important is that the same base be consistently used for all programs. A pre-audit would not necessarily identify situations wheredifferent bases were being used. Nor would a pre-audit necessarily identify a process where billings were made on the basis of four programs if there were really five programs - which would be a 25% overcharge. (For the sake of simplicity I have selected examples where the practice could be considered fraudulent - and pre-audit is a poor protector against fraud. However, when an agency has multiple programs, different funding levels at different points in the year, different program funding cycles, different cost categories and limitations - honest allocation mistakes could be made that a pre-audit might not identify.) Hence, the single audit is very important. Pre- audit is a limited horizontal review, the single audit is a broader more comprehensive vertical review. I understand UCSSO expects to have its FY 95/96 audit (in compliance with the Federal Single Audit Act) completed, with the report issued by the end of November. For continued PIC funding, that Single Audit Act audit is important._ ACM:bj y:picoffice\staff\ucssocao,doc _a D' C a a � C O A C I I O .4=o a E aEi m a E o a E d c ? a o 0 -lz� nua� o o _ N a`� p � c c = d �' c _ °N' - s c v o 0 0 0 0 � o w I'- o o i� v d O p o o p N o y > 3 o N c No :a o -B w E Cl- co E a o > N S C — O U O E N L] N a p a C� O C C _ o c E °� o �' Z w c v -p c c Q c 0 -a s N C Q' N C C a C -«N- `7 a G -N-• U O O E C 3 a' co 0 0 °� o a • c o co a� a s O E a s o E y v a 2 E _ `n N `" a -v > a •� � � a '-` D °' E n E n a� E � E N N a> � _N � ..U- C C O O U O O T O N N C) �O 1 O L o p p L a 'o _a N p a N p p E a a'E O E a c E c N U o E °' a I- c c_ E °' a+ c a I p n E c E 77 C O O C a V V V O V Q7 L QJ V U Q' 4J E V O D' 4J d `O w O N 0 o N a E o cn Ci � a .E E � E a 3 = o N a '� o N a '� a ¢` N E o a� _U N V U :nU N 4J O O `� N O 4J cn C O N .0 L N \»N \ N 47 _N p_J N _N C > U CT C (D QJ a � C1 p '� U V V V N O O O U 'V 3 E 00 E -6 N .�. O N U O N N 'p �r> - o O z 1<5 � _ 0 U j N U C- Q M a`� a� t� N d > .� �O N U O 'c O r - v > U U V V O N C CD = C N O C > C N ¢� O _ O N O O O O N L u'1 > N U O a� V � N N v a N Q) C _ C > C1. > N V V > E V 7 Co C1^ N > *5 U C L C y 4J E N '� N U p� a'.v a '� o c E c '� O 'c E •a' a> o a� c E a� V H 00 u a' .D N Ot! ") Ln O .L] O ") O O l.C') V — Q> Cl- M Ln x U O ¢ a� O ma - v "p O C� 1r N p O N p c c N VCo W a� rri a a 3 '� N o c a p rn a�l a o U o o ..r a U N o ' .r _o W o _o cn E o a a`, - cl a' E N w U <L> Q O GJ O O ly C1 O O Q -p T v C N O O Q O Q O o p aCi c C1 O •nil V C C a' O a �_ O U N E V N N O N U o w .a C -p Urn o 3 co o N ry O � +S QJ O O A ,G - T V 4J U QJ 'a N C 1] O i Qi N a' U a 'a U -- U -a p -a o N a- °� 3 O 3 •N O 3 N 0 c p a a E o E aJOi C N " — °' > N o -a c v+ C x O r.y a� V U Q N ¢ 3 ¢ O U U O xo � V :" .m O co CZ) o .Q C o = 1� O C=> M O� 1�1�, •+••�I 64 [•A i� Mme+ 64 �1 a a� a co cp r co a, ZDcxl c0 M O 1 I I I I C') c0 cD Cn Ln _ M _ aci w N N N U 0 Ln a 0 O N Ln C, O v o m m m ° a U p p � o o 2 4 ¢ Q �- vi Cl_ a. a. a E p Q Q Q Q U O I I I I I v i V• � v N N N N N N N N N N N N N N N 4- CD -O O CO CO A 0 0 � N cn o 0 o O 0 0 0 0 0 S = S m m ^ c c p c'D 0) M CD � 0 0 n n CCD C CD CD CD CD j f9 y O O O O O Q Q I I I I I A tT w � w rn rn y w w w w w Q0 cn C b r� w � o o c W N O O -A CJS O O O 00 O Q 0 D A P.O. O W O � n_ o C-) n n n n a O O Q O A' d p d N EL. rD 3- ."•_ = moo v b 'O"! 11 0. O C7 CD D < -- D �- n On O S y H• n O d CD .D CD 00 'C CD CD C W- =, <> =3 C CD l 1 I I 1� 14 00 <'� OC,- CND CD n 7 < 'LID) (p n. G. n O O CD' < < 00 N C'1 < CD O G CD- t"> CD (D v zv -O N �. -O •• Q N 3 C> N v-' 0CCD O N cr O n O O 3• O v? n c] •`n CD 'o n 3 o rn 3 0" o N o �' D o CO ()o CD a rAy n �D �� cn ` a N CO d II o cNn II O o 3 n �_ � N 'n CD bb LO I, O N =3 0 .--` 0 O G O N n" s �__ v 0 3 0 0 O C O In 'O N C-7 N O C O CD ~ O N N �_ N c0 J O O tD- tND CD 2- n O CD p O CD_. O N (n WC N G CD O (n CD (D ._-�• d cz� C7- CD 1 C) G CD O N N O C � 3 C C � C C O O O n Q O C' O 7 CD E3 0 3,n o 03 v - 3 3 7D 3 -C FDCD Z CD - I p O n - 1 O D 7- O O G CD oo � � o ::3 n3n n � � o a 0 3 CD n n 3 n o Cr ti = 3 cn D ID o rn — = 3 w o= o Cu — B a a n a iD O o _ S O �-.n a v- n ,--.n C a v- cn CD � o f9 TI = CD �- C CD �'! � O CD �- C O .n' C Q p n N O O n O N O n A - !ND A S - <D O 7 p = O N O C> CD Q- O CD p c CD N O � G O O -op�•�� �, has O p p � •G... T• O T N O �v �'� U P N O � N aJ J � .G G'G `i ✓ G jj � <,.� J d U N .✓ c d D v o p a a J O 'rG r G O6- y, > D N F O u •a _wp p on o u, .0 G i �� N LP o- W- CJ N- ✓ 'p= O o L9 D t,t7•G N� �•� N � � � O N 4 o N v � r•- N '� -O a� d ro- w w O oc-- C- 10 •id ...0 OP p .G O G U a i N N ..�' y a N .r N J O -e- U, J O N Gy GV O N N .on- Q Z �v `cx-�: .p `� 4, ..., •" �w � �F O O r "O O T^--•_ N a W p• J ,,... 17 p U O b O O•J p p W- /"'a' o � '"' •d a � � P w °' d `� c O -a o-� Gy No-a � � rn U G O C1 O J d •♦ � lyr, � rG O"� O � G ay J d v" O U P • + v V .O o G y O Q Q a .a- v Q �- r p CLO IPA L r IA N 1 rA a N O Q Q 6J U O a O O, O Q •3 N O a d C3- 0 d d` O_ a � � N 1 P N rn 1 N N N N N N N N CT ? Oo -A NO cD W Oo Oo I I I I I D n C7 o v 3 3 3 0 0 a a <n N (n O C Q 3 3 =• 00 3 3 0 -2 N A C C D a - � O p a < < O O N (./) A CD C C --4 CSD =3 rn _4CD OO= O n CD Q A A N S S _ W O O \O \p O c�) � rn I I I I N Q) WCn \ \ W 00 O W W V \ \ O O rn cJo rn cp v (rQ b "4 o OCD � ro eD 0 n � n o n A n 3' 3' cr) r-I p o < o cr 70 =3 n cn -+ D a+ � O 121 O CD O p O O — Q O p_ `G CD CD O CD O W CD 1.+• F+ v 3 -o moi) _ o 3 �- m n 3 = A CD c7 p ZE o 0 3 CD O a noN � n o Q p on N 3 c No O c= CDcon a A7 C, c�. -C-7- CD ?- 3 C K Q_ ^^ CD = 7 CD _• p' a p_ I.+ e A 3 p_.n Q � n c a n o CD o a 3 CD cr o CD o �c O n ip O S O) O n- O tD 'O A C CD 64`'� p r. Q o Q s Q CD O o n Q a rn W O Q CD C L `C N n_ O 'O p_ C> CD O N _ CD x N Q C = Cl1 O O A F+ O S � A O CD O N O p Aa Q_ " N O O CD10 O CD A N CD CD CD QCD C/) CD• co n o =, O D O� Q- CD A n n C O CD O C cO C p_ CSD N S Q CD d CD Q �D o n o p_ O O_ 'p N -C - C A N 0 O Q � S w — O Cl) O C. _0 O N Z N p =3 cr p_;O N x r C n W -->4 A f'rl l'A'/• Q O CID CT Co CD S (D CD n (n !p n CD � * Jr CD : N CD N A A CD =, (p A Vl A CD CD _ CD r-I p CD A CD C7 A 0 4 O A C) a N p Q CD D 7 CD CD CD N N CS CD O CD p N S O O_ O Q O Q CD ID 7 N CD C p_ Q O A A n C-Di 01 p p 3 C) p O CD C7 d C �_ p CD od O CD Cr Q' d CO O G N A p S O UD Cp NCD lbCD <1> Q CD A 7 3 -Cl CD n -6 7 CD `G O A 3 0 N O CD O tD O d A O 0 3 2- 3 ao O_ CD O O p a 01 � 3 O _. O Q O CD p S N 3 CD O O O I CD n S �•q y CD Q CD O. n = CD 3 F, O• p_ N. -0 N a-u TI TI CIo s n 3 a n c o 0 3 0 3 n CCD CD o =- o o C o n n o o3-• 3 I 3 n a QC � CD cn CD S C p 7 O Q N Q CD (n O Q C CD p r=3> CD CNDN N CD d N CD Q 3 A o p o p a 3 a 3 0 p p p o O O O O Q d w O 3 Q' = — N ip O_ P M A N Q. y• A N_ CD O � d � C7 U> Q CD O r CD O O N p = a Q to S O 3 o v p p o A 3 o N < N o s ti c o n c TI 3 c Qcy- 0 3 C _ Cti MoD .CD � zcr3 a O o o Wm o = o n In o Q v c o a s n o Q D - o S <D'O 3 -• Q rJ a CD O O A p fD N O an CD Q_ C Q O O O n_ c cD c 3 Q o a 3 n n_ o o i o < a o 3 Q C p n• CD n n D- O C") A -� a 3 CD D CD cn n Q O CD Z I a CD zz a o 'cl o o_ o S Q 3 o a p CD N N N N N N N N N N N CT C.7i Vn O N N N CJS w N N I 1> W N n a a CD CD CD 0 0 0 D � Ln cn oo• 0 0 o z z 0 0 0 3 oo cn z cn = cn s z C> Cf7 CD < CD < <o C o � CD �- CD 0 CD o m 0CD > > > CD Q O cn (n N CD � n o O O a CD CD O CD cn . p CD CD(n tn Cn �. CD CD < N n- (D (A O O O O CD O c\0 CID c\D c\0 C cn 07 cn C7 Z � m w w \ \ w\ O CCD rn \co C co co � v Z rn rn v n Co �_ x O +f# M {AM !fi b4 l N W -o W D Ln 0 0 0 o a QD o Z V) Z O O A A 0 d TI CO 0 D O t0 0 O CD D � � CD � � M = z a o rz o CD I NC, cn n V) \a N `n <> c ' p cCD D CD m j " O 0 0 0 cD c c a 3 C7 �' n Z CD Cl- Q <. ON N N CD O CD n. f N a :-...• 0 Q. Q :D M CGD to � CD Fc,— O � Q N - � G �a s �' a <' D o w n <' o 3 o n <' o N C (DO S CD .p 00 CD Q N O �_ CD o' c .. rn O co .. � O � o � o. oA o cn `D Z O -p. O N -O O.tD N "O a D CD D w a 0o rn 0 C A ID -p A - CD ADD. 12 C D C, 00 IR Q � CD � N p ?' W p d N _ `�G O Q C S Q ID _ O — a cD' -d .� tD .a ID' p a p < N CSD tSD I CD CD N <S `D CD O CD A A p S A CD CD CD A C x Q O 01 Ip O O CD C O 70 CD 1 m CD CD CD Q. A to CD 0 O � a N CD ^' a y O Q 0 s'] O O O ^ CD A Q (D A = o C/1 C.!) N N C D_ y _. CD C7 N O CD .`D tD CD CD CD 0 O N O CD Q 3 < < < C', N d C A C (n d n- n• CD O a S !D a C •-.- CD CT CD CD CD � C0 C O O A = O N N CD A N 'JJ 0 0 Q — C D -. a O c.- ? n O 0 d � A � O O p O fD p N A O •--•- CD c = S = I ID I O