1. Capital Improvement Program Post-Award Technical Assistance Call July 7, 2009

2. July 200922 Objectives  Describe the outcome of the Capital Improvement Program (CIP) application submissions  Review the terms and conditions of the CIP Notice of Grant Awards (NGA)  Explain the review process for CIP applications

3. July 20093 CIP Awards  On June 29, HRSA awarded $851.5 million in CIP awards  The eligible project types were: –Alteration/repair/renovation –Construction (new site or expansion of existing site) –IT/equipment-only purchase (single site or multi-site) –HIT-only purchase (non-EHR equipment) –Certified EHR-related purchase

4. July 20094 CIP Stats  1,123 health centers applied for funding to support 2,614 projects, including: –411 new or expanded health center sites (construction projects) –1,153 improved/upgraded health center sites (alteration/repair/renovation projects) –490 health centers with new equipment –176 health centers with new HIT projects –384 health centers with new/enhanced certified EHRs

5. July 20095 CONGRATULATIONS!!! You have the Notice of Grant Award. So…now what?!

6. July 20096 Understanding the NGA  NGAs were issued on 06/25/09  Project/budget period for the CIP is from 06/29/09 through 06/28/11  CIP activity code = C81  Recipients need to keep in mind—There is no ongoing support of CIP grant activities after the end of the 2-year project/budget period

7. July 20097 What it means?  Grant conditions  Grant specific terms  Program terms  Standard terms

8. July 20098 Grant Conditions  Notice of Federal Interest  SHPO/THPO Consultation  Environmental Information and Documentation (EID) Checklist  Environmental Assessment  Letter of Consent/Statement of Agreement from the Facility Owner  EHR Readiness Checklist

9. July 20099 Grant Specific Terms  Pre-award costs  Budget-specific/Project-specific issues –Incorrect categorization –Questionable costs  Draw down restrictions  Subordination of Federal Interest  Insurance coverage and policies  HIT technical assistance

10. July 200910 Program Terms  Timeline for obligation of CIP funds  Staff points of contact  Change in Scope (CIS) add new site requests

11. July 200911 Standard Terms  HHS Grants Policy Statement  HHS Appropriations Act  Medicare and Medicaid anti-kickback  Items that require prior approval  Payment Management System (PMS)  Fraud, waste, or abuse  Audits  Language assistance  Trafficking Victims Protection Act

12. July 200912 NGA Contacts  Division of Grants Management Operations (DGMO) Contact  One Bureau of Primary Health Care (BPHC) staff person will serve as the focal point for all CIP activity  Grantee-specific CIP Program Contacts will be finalized soon

13. July 200913 CIP Application Reviews  Completeness  Eligibility  Allowable Costs  Service Area Overlap  Architectural/Engineering Reasonableness  Federal Interest  EHR Readiness  Environmental Review  Historic/Cultural Preservation

14. Equipment Only Projects: Conditions [IT/Equipment, HIT, and EHR]  IT/Equipment and HIT –EID  EHR Projects –EID –Readiness July 200914

15. July 200915 Equipment Only Projects: Terms [IT/Equipment, HIT, and EHR]  Pre-award costs  Budget-specific/Project-specific issues –Incorrect categorization –Questionable costs  Draw down restrictions  HIT Technical Assistance

16. July 200916 Alteration/Repair/Renovation: Conditions  Environmental Information and Documentation (EID) Checklist  Environmental Assessment  SHPO/THPO Consultation  Notice of Federal Interest  Letter of Consent/Statement of Agreement from the Facility Owner

17. July 200917 Alteration/Repair/Renovation: Terms  Pre-award costs  Budget-specific/Project-specific issues –Incorrect categorization –Questionable costs  Draw down restrictions  Subordination of Federal Interest  Insurance coverage and policies

18. July 200918 Construction: Conditions  Environmental Information and Documentation (EID) Checklist  Environmental Assessment  SHPO/THPO Consultation  Notice of Federal Interest  Letter of Consent/Statement of Agreement from the Facility Owner

19. July 200919 Construction: Terms  Pre-award costs  Budget-specific/Project-specific issues –Incorrect categorization –Questionable costs  Draw down restrictions  Subordination of Federal Interest  Insurance coverage and policies

20. Condition: Environmental Information and Documentation Checklist (EID)  Each project must have its own EID  For IT/Equipment-only projects, if you (1) completed the project-specific EID, (2) attached this EID in the proper place in the CIP application, and (3) answered “No” to all questions, then you may proceed with your project (absent other conditions)  For all other project types, HRSA will lift the condition based on review of the EID July 200920

21. July 200921 Condition: Environmental Assessment  What projects require an EA? –All construction projects –Some alteration/renovation projects—upon review of the EID and application information, HRSA will communicate to the grantee if an EA is required  These projects must undergo a National Environmental Policy Act (NEPA) Environmental Assessment (EA). A Phase 1 Environmental Site Assessment (ESA) is NOT the same as a NEPA EA. –A Phase 1 ESA addresses only a small part of what is required for an overall NEPA EA and will not fully meet the requirements of a NEPA EA.  More information is available at http://bphc.hrsa.gov/recovery/faqdraftassessment.htm http://bphc.hrsa.gov/recovery/faqdraftassessment.htm

22. Condition: SHPO/THPO Consultation  Part of the Cultural Resource Assessment and Historical Preservation Review  If a grantee proposed a construction project, it is authorized to contact their State Historic Preservation Office (SHPO) and/or Tribal Historic Preservation Office (THPO) to obtain either: –A letter indicating a finding of no adverse impact, or –A draft MOA between the SHPO/THPO, grantee and HRSA detailing a plan to reduce the adverse effects. Upon approval by HRSA, it will be signed by all parties.  HRSA is reviewing alteration/repair/renovation projects to determine whether a SHPO/THPO consultation is necessary; if the consultation is necessary, HRSA will communicate this to the grantee. July 200922

23. Condition: Notice of Federal Interest  For ALL construction projects AND for alteration/ repair/renovation projects with a net project cost (excluding equipment) greater than $500,000, the grantee must: –File a Notice of Federal Interest (NFI) with the appropriate jurisdictional records, and –Submit a notarized and recorded copy of the NFI to the Grants Management Specialist  NFI must be filed prior to starting the construction or alteration/ repair/renovation project July 200923

24. Condition: Letter of Consent  For a leasehold improvement project that is: –A construction project, or –An alteration/repair/renovation project with a net cost, excluding equipment, of greater than $500,000  The grantee must provide HRSA with a signed Letter of Consent/Statement of Agreement from the facility owner demonstrating that the owner: –Approves of the scope of the CIP project –Agrees to provide the grantee health center reasonable control of the project site for at least 10 years –Agrees to file an NFI in the land records of the local jurisdiction when the project begins  If a grantee provided the Letter of Consent/Statement of Agreement within CIP its application, HRSA will still review for completeness  A template of the Letter of Consent/Statement of Agreement is available at http://bphc.hrsa.gov http://bphc.hrsa.gov July 200924

25. Term: Questionable Costs  A Grants Management Specialist will contact you to discuss any questionable costs  Once questionable cost issues are discussed, clarified, and resolved, the condition will be lifted July 200925

26. Term: Incorrect Categorization  A Project Officer will contact the grantee to discuss project types that appear to be incorrectly categorized (IT/equipment-only but should be EHR-related, alteration/repair/renovation but should be construction, etc.)  Once the correct project type is established, the grantee may need to submit additional required information, per the CIP guidance  New terms and conditions may apply  Projects may not begin until incorrect categorization issues have been resolved July 200926

27. July 200927 Program Term: Change in Scope to Add New Sites  HRSA is currently processing all new site requests, including new sites proposed through –CIP application –Normal CIS requests linked to a CIP project  HRSA will notify grantees if site is approved within 60 days  Verification within 60 days of the project completion

28. July 200928 Special Topic—Procurement Rules  All goods and services > $100,000 needs to be competitively bid  Simplified acquisition threshold applies to good and services < $100,000 –Recipients should keep in mind that they still need to get more than one quote (not bids) for the work to determine that the costs are reasonable, and the threshold shall not be broken down into several purchases or artificially reduced to smaller quantities to permit negotiations under simplified acquisition procedures

29. July 200929 Next Steps and Timelines  Responding to terms/conditions  Releasing terms/conditions  Draw down of funds Recipients can proceed with preliminary CIP work but will need to wait to break ground until the applications have been cleared through the various reviews

30. July 200930 Responding to Terms and Conditions DeliverableSubmit Within Resolving budget issues30 days or July 27 (July 25 is a Saturday) EID30 days or July 27 (July 25 is a Saturday) EA60 days or August 24 Notarized and recorded copy of the NFI30 days or July 27 (July 25 is a Saturday) SHPO finding of no adverse impact60 days or August 24 Letter of Consent/Statement of Agreement from Facility Owner 30 days or July 27 (July 25 is a Saturday) Documentation of insurance policies5 days of project completion All deliverables will be submitted via the Electronic Handbook (EHB) system into the official CIP grant file—HRSA will provide instructions on the submission process shortly

31. Releasing Terms and Conditions  Terms and conditions will be released on a project-by-project basis –Once all conditions for a specific project are met, a revised NGA will be issued that will authorize the grantee to begin that project July 200931

32. Draw Down of Funds  IT/Equipment, HIT, and EHR-related projects –Grantee may begin drawing down funds unless questionable costs or other conditions exist  Alteration/repair/renovation and construction projects –Grantee may draw down funds for planning costs (e.g., environmental assessment, A&E permitting, SHPO/THPO consult) –Grantee may not draw down funds to pay for other costs until HRSA gives final approval to break ground/begin project July 200932

33. Timelines  For IT/Equipment-only, HIT, and EHR-related projects: –HRSA anticipates resolving conditions and issues within 3 weeks  For alteration/repair/renovation and construction projects: –HRSA anticipates resolving all conditions and other issues in 8 to 12 weeks –If application is missing key information, grantee has not submitted required documentation, and/or additional issues are identified during reviews, process could be significantly longer July 200933

34. Tracking and Reporting  CIP funds must be maintained and tracked separately from any other Federal, State, or local funds, including other Health Center Program or Recovery Act grants  Grantees will report on CIP funds beginning October 10, for both Health Center Program and Recovery Act measures July 200934

35. Change in Scope of CIP Project  HRSA realizes that grantees may wish to change their original CIP proposal based on emerging information about the immediate needs of the communities they serve and/or on unforeseen circumstances.  HRSA will work with grantees to make and document minor programmatic or budgetary changes within their application that do not significantly affect the outcome of the project July 200935

36. Change in Scope of CIP Project (cont.) For changes that may significantly impact the originally proposed outcome:  Any proposed changes must result in a project that remains consistent with the intent of the CIP.  Grantees may not request a CIP award amount above the originally requested amount.  The grantee must submit the change request in writing to HRSA. Based on an evaluation of the information provided by the grantee in its request, HRSA will review and determine whether the request for a change in CIP scope of project will be approved. July 200936

37. Resources and Contact Information  Please refer to the technical assistance materials available online at http://bphc.hrsa.gov/recovery http://bphc.hrsa.gov/recovery  Send questions to bphcrecovery@hrsa.govbphcrecovery@hrsa.gov July 200937