A North Carolina county or municipality that receives opioid settlement funds must spend them on strategies the state Memorandum of Agreement (MOA) allows, authorize each expenditure before it is made, and file up to four reports on 90-day clocks. Integral Healthcare Solutions (IHS) drafts the reporting calendar, spending authorization procedure and evidence file that a county, a municipality or a contracted provider adopts. This page covers North Carolina only.
IHS is a consulting firm, not a law firm. Your counsel advises on the MOA and state law; IHS turns what counsel confirms into working documents.
Last updated: November 2026
What is opioid settlement funds program readiness in North Carolina?
Opioid settlement funds program readiness is the set of procedures, calendars and records that lets a North Carolina local government, or a provider it contracts with, show that settlement money was authorized, spent and reported as the MOA requires. It is an IHS consulting deliverable, not a state program or an accreditation.
IHS opened the North Carolina MOA, the NC Department of Justice FAQ on the MOA (updated December 2024), Exhibits E and F as modified, and the MOA compliance supplement for auditors (July 2025) on 2026-11-05. The FAQ says that if it conflicts with the legal documents, "the terms of the underlying legal documents always take precedence." IHS did not open the supplemental agreements, the national settlement agreements or other states' plans.
What reports does a local government file?
These go to CORE-NC, the Community Opioid Resources Engine for North Carolina, the settlements' reporting hub.
| Report | Clock |
|---|---|
| Local spending authorization report | Within 90 days of the passage of the budget or resolution authorizing the expenditure |
| Option B report and recommendations | Within 90 days of the date it is submitted to the local governing body; required of a government using Option B |
| Annual financial report (Exhibit E) | Within 90 days of the end of every fiscal year in which the government receives, holds, or spends funds |
| Annual impact report (Exhibit F) | Within 90 days of the end of any fiscal year in which the government receives, holds, or expends funds |
The compliance supplement says the impact report is due when funds "were expended," narrower than Exhibit F's "receives, holds, or expends"; IHS plans to the wider wording, and your counsel decides. CORE-NC's sub-recipient guide says to file both annual reports by September 27 each year.
What is the difference between Option A and Option B?
Option A lets a government fund strategies from Exhibit A, the shorter list, without a required planning process. Option B has four steps: run the Exhibit C collaborative strategic planning process, draft a report and recommendations, present them to the governing body, and submit them to CORE-NC within 90 days of that presentation. The body may then fund Exhibit A or the longer Exhibit B list; the recommendations are not binding.
The MOA says: "Before spending any funds on any activity listed in Exhibit B, but not listed on Exhibit A, a Local Government must first engage in the collaborative strategic planning process described in Exhibit C." NC DOJ's FAQ sets three rules based on MOA section E.5.b, effective January 1, 2025; the MOA text limits them to a strategy listed in Exhibit B but not in Exhibit A:
- For one year after presenting its report, a government may authorize any Exhibit B strategy, whether or not the report recommended it.
- After that year, it may authorize an Exhibit B strategy the report recommended or one it authorized during the year; a strategy that was neither needs a new planning process first.
- To keep funding an Exhibit B strategy, it must repeat the planning process every four years from the date of its most recent report, or more often if it wishes.
A government may run both options at once, may use Option A Strategy 1 to pay for Option B planning, and faces no general deadline to pick an option. Where both an Exhibit A and an Exhibit B strategy fit, NC DOJ recommends Exhibit A, a recommendation and not a requirement.
What must a spending authorization say?
MOA section E.6.a lets the governing body put the authorization in its budget or pass a separate resolution. NC DOJ goes further and says a government must adopt both an authorizing resolution and a budget ordinance, because the MOA resolution "is not sufficient under the Local Government Budget and Fiscal Control Act to authorize the expenditure of the opioid settlement funds." The FAQ lists the annual budget ordinance or an amendment, a settlement project ordinance, or a capital project ordinance as budget routes.
MOA section E.6.b says the budget or resolution should, and the FAQ says the resolution must: indicate that it authorizes expenditure of opioid settlement funds, name each strategy by its Exhibit A or B letter and number, and state the amount dedicated to each for a stated period. One sum cannot cover several strategies, per the FAQ.
Who needs it and what triggers it
Per the FAQ, every local government receiving funds from the settlements the MOA covers must abide by it. The triggers:
- A county or municipality must follow Option A or Option B, authorize spending properly and report on up to four clocks. Each county receiving funds must also hold at least one annual meeting, open to the public, with every municipality in the county invited.
- A nonprofit, charity or other entity that wants to implement a strategy can contract with a local government, and the FAQ recommends the contract carry the MOA reporting duties.
How IHS helps
IHS converts the MOA duties your counsel confirms into documents your staff run monthly. Thomas G. Goddard, JD, PhD, IHS founder and former URAC Chief Operating Officer and General Counsel, leads the work. The work sits in Program Development, alongside the Compliance Services and Accreditation Consulting practice lines.
- Gap assessment: what you do today against the rules above, with each gap listed.
- Evidence mapping: each strategy tied to the resolution, ordinance, payments and report showing it was authorized, spent and reported.
- Drafting: a reporting calendar, a strategy-to-evidence file, a sub-recipient contract checklist, a spending authorization procedure and a readiness brief for your leaders to adopt.
- Readiness review: IHS walks the file as an auditor using the compliance supplement would, an IHS method and not a state step.
You supply your governing-body actions, ordinances, contracts and ledgers. Your organization decides, signs and files.
What to have ready
Gather these before the first session.
- A written record of your option path and, for Option B, the date the report was presented.
- Every authorizing resolution and budget ordinance, with strategy letters and numbers, amounts, periods and CORE-NC submission dates.
- Your special revenue fund ledger by fiscal year, checked against the Exhibit E rule: opening balance plus funds received plus interest and investment gains, minus investment losses, disbursements and audit costs, equals closing balance.
- Each sub-recipient contract with the MOA reporting terms written in. A government at 0.2 percent or more of the Exhibit G allocation that disburses funds in a year must also list each sub-recipient paid 50,000 dollars or more, or ten percent or more of that year's disbursements.
- The names of the calendar owner and the spending approver.
The compliance supplement tells auditors to test whether each financial-report expenditure was previously authorized and reported to CORE-NC, and whether impact-report strategies match those expenditures. The free introductory call is where IHS walks through this list with you.
How it compares
IHS names the FAQ's routes without telling you which to choose.
| Route | What the sources say |
|---|---|
| Contract with a nonprofit, charity or other entity | Allowed. The government keeps ultimate legal responsibility, including reporting, and may not assign its right to receive payments or its responsibility for funding decisions. |
| Contract with another local government | Allowed. The first government still complies with the MOA for funds it received. |
| Municipality arranges for future payments to go directly to its county | The municipality is relieved of reporting duties for those future payments. |
A provider's CARF accreditation is a different subject; see CARF opioid treatment program accreditation.
What it costs
The documents IHS reviewed state no fee to hold or report on settlement funds. The MOA addresses audit costs: "Reasonable audit costs that would not be required except for this Section F may be paid by the Local Government from Opioid Settlement Funds." Whether any other cost, including consulting, may be paid from the funds is for your counsel.
IHS scopes each engagement after a free introductory call. Scope moves with the strategies funded, the authorizations and sub-recipient contracts to document, and the fiscal years of records to review. Your staff time is a third cost.
What this is not
- It is not legal advice. IHS is a consulting firm, not a law firm, and gives no opinion on the MOA, state law or procurement.
- It is not a guarantee that any state office, auditor or governing body will accept a decision or report.
- IHS does not apply for funds, file reports or contact any state office for you.
- It does not cover the national settlement agreements or any state other than North Carolina.
Frequently asked questions
What reports are due and when?
Up to four, each within 90 days: the spending authorization report, from passage of the authorizing budget or resolution; the Option B report and recommendations, from submission to the governing body, for Option B governments; and the annual financial and impact reports, from the end of a fiscal year in which funds are received, held, or spent.
What is the difference between Option A and Option B?
Option A funds strategies from Exhibit A, the shorter list, with no planning process required. Option B adds a planning process and a report to the governing body, which opens the longer Exhibit B list as well. Per the FAQ, funding an Exhibit B strategy without it violates MOA section E.5.b.
Do we file the annual reports if we only held funds and spent none?
The MOA requires the annual financial report for every fiscal year in which a government receives, holds, or spends funds, so holding funds is enough. Exhibit F says receives, holds, or expends for the impact report, and the compliance supplement says expended. Your counsel decides the reading.
Can a nonprofit or treatment provider receive settlement funds?
The FAQ says a local government may contract with a nonprofit, charity, or other entity to implement opioid remediation strategies. In IHS's reading, a provider reaches the money through that contract, not by applying to the State, an inference limited to North Carolina.
Can we take an administrative percentage?
No, per the FAQ: the MOA does not allow a local government to dedicate a set percentage of funds to administrative expenses, indirect costs or overhead, such as 10 percent, or any percent, off the top. The FAQ gives the same answer for a third-party contractor.
When does the 90-day clock start on the spending authorization report?
It runs from the passage of the budget or resolution authorizing the expenditure, so capture the vote date that day.
Can settlement funds pay for a building or vehicle?
Yes, on three conditions in the FAQ: the asset implements a properly authorized Exhibit A or B strategy; if it serves several authorized strategies, its cost is prorated among them; and if it also serves another purpose, settlement funds cover only the share used for authorized strategies.
How long do we keep records, and what if we spent outside the MOA?
The MOA requires expenditure records and supporting documents for at least five years. A government that spends inconsistently with the MOA has 60 days after discovery to cure it by budget amendment or repayment; otherwise future payments are reduced by that amount.