1. Ryan White HIV/AIDS Program Part B It All Adds Up! December 14, 2018
Good morning and welcome to this RWHAP Part B Business Institute
My name is Rene Sterling, Deputy Director for the Division of State HIV/AIDS Programs often referred to as DSHAP, and I am joined here today by the DSHAP ADAP Advisor, Glenn Clark, and the DSHAP Program Advisor, Yemisi Odusanya.
This morning, we are here to present to you “It All Adds Up!” designed to provide you an overview of fiscal requirements important to your management of Ryan White Part B programs, including the AIDS Drug Assistance Program.
How many people here this morning are Ryan White Part B
Recipients?
Subrecipients?
How many of you consider yourself to be part of your organization’s “fiscal team”
And please raise your hand if you have been working for a Part B program for less than three years?
Okay. Thank you
Well, it is often said that Ryan White Part B is one of the more complex Parts within the Ryan White Program, and it can often take a couple years to learn it well.
Complexity arises from various levels, including
specific legislative requirements regarding the awarding of funds,
the focus on developing comprehensive systems of care at a state or territory level, and the
Expectation that Part B recipients lead efforts to ensure service delivery coordination across their jurisdiction, which in some cases includes a geographic area that may have quite a bit of diversity within it
by HIV prevalence or
by the number and dispersion of health care and support service providers for examples
So during this session, Glenn, Yemisi and I will provide you a fairly high level summary of key fiscal requirements in hopes of supporting your work.
We will pause for clarifying questions at several points during the presentation and we ask that you hold your questions until then.
Rene Sterling, Deputy Director
Glenn Clark, ADAP Advisor
Yemisi Odusanya, Senior Program Advisor
Division of State HIV/AIDS Programs (DSHAP)
HIV/AIDS Bureau (HAB)
Health Resources and Services Administration (HRSA)

2. Health Resources and Services Administration (HRSA) Overview
Supports more than 90 programs that provide health care to people who are geographically isolated, economically or medically vulnerable through grants and cooperative agreements to more than 3,000 awardees, including community and faith-based organizations, colleges and universities, hospitals, state, local, and tribal governments, and private entities
Every year, HRSA programs serve tens of millions of people, including people living with HIV/AIDS, pregnant women, mothers and their families, and those otherwise unable to access quality health care
We trust that all attendees will leave this conference knowing that the Ryan White HIV/AIDS Program is one of 90 programs supported by the Health Resources and Services Administration, all of which work to address the needs of
geographically isolated and
vulnerable communities.

3. HIV/AIDS Bureau Vision and Mission
Optimal HIV/AIDS care and treatment for all.
Mission
Provide leadership and resources to assure access to and retention in high quality, integrated care, and treatment services for vulnerable people living with HIV/AIDS and their families.
In our administration of the Ryan White program, we work toward a vision of optimal care and treatment for all.
And as suggested by our mission statement…

4. Ryan White HIV/AIDS Program (RWHAP)
Provides comprehensive system of HIV primary medical care, medications, and essential support services for low-income people living with HIV
More than half of people living with diagnosed HIV in the United States – more than 550,000 people – receive care through the RWHAP
Funds grants to states, cities/counties, and local community based organizations
Recipients determine service delivery and funding priorities based on local needs and planning process
Payor of last resort statutory provision: RWHAP funds may not be used for services if another state, federal, or private payer is available
84.9% of RWHAP clients were virally suppressed in 2016, exceeding national average of 59.8%
As the payor of last resort, we provide leadership and resources to ensure low income people living with HIV have access to a comprehensive system of HIV primary medical care, medications and essential support services
We are all very proud of the data we have demonstrating that overall, viral suppression among Ryan White clients far exceeds the national average among people living with HIV.
Source: HRSA. RWHAP Annual Client-Level Data Report 2015; CDC. HIV Surveillance Supplemental Report 2016;21(No. 4)

5. Learning Objectives
Identify the authoritative source documents guiding the Ryan White HIV/AIDS Program (RWHAP) Part B
Review the major RWHAP Part B legislative and programmatic requirements.
Become familiar with the RWHAP Part B fiscal reporting requirements
As objectives for this session, we want to ensure you can
identify the various authorities that set requirements for Ryan White Part B
We want to
review the major legislative and programmatic requirements for Part B
And we want to ensure your familiarity with fiscal requirements, in particular.

6. Outline RWHAP Part B Basics and Background
RWHAP Part B Fiscal Requirements
Federal Financial Reports (FFR) and Penalties
Key Resources
Our presentation is divided into four major sections:
A basic overview of RWHAP Part B
A review of key fiscal requirements that are
specific to Part B and
some that apply across all federal grant programs,
In the third section, we are going to review fiscal requirements that have a financial penalty associated with them, and show you how the Federal Financial Report requirement is used to assess compliance and determine penalties
We will close by highlighting a few resources

7. I. RWHAP Part B Basics and Background

8. Relevant Authorities
Legislation: Title XXVI of the Public Health Service Act, 42 USC. Section 300ff-11s as amended by the Ryan White HIV/AIDS Treatment Extension Act of 2009 (P.L )
The RWHAP under Title XXVI of the PHS Act as amended by the Ryan White HIV/AIDS Treatment Extension Act of 2009 (Public Law , October 2009) authorizes formula and supplemental grants designed to assist states/territories in developing comprehensive HIV/AIDS service delivery systems that includes delivery of essential core medical services and appropriate support services
Regulation: 45 CFR Part 75 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards
Department of Health and Human Services (HHS) Grants Policy Statement
Key legislative and regulatory authorities appear on this slide. They guide DSHAP’s monitoring and stewardship over the program, and set requirements for program implementation.
First the Ryan White legislation which, under Part B of the legislation, authorizes the awarding of formula and supplemental grants to states and territories, for development of systems of care that provide essential core medical and support services.
The Code of Federal Regulations, specifically 45 CFR 75 outlines financial requirements for all federal grant awards.
The third authority is the Department of Health and Human Services Grants Policy Statement (HHS GPS), which
makes available, in a single document,
the general terms and conditions of HHS discretionary grant and cooperative agreement awards.
Of note, the HHS Grants Policy Statement aligns with but does not (last modified 2007) reflect all requirements in the 45 CFR Part 75
Available at
Available at

9. Relevant Authorities
HRSA HAB Policy Clarification Notices and Program Letters
HRSA HAB RWHAP Part B Guidance
RWHAP Part B and ADAP Manuals
National Monitoring Standards – Program, Fiscal, Universal
RWHAP Part B Notices of Funding Opportunity (NOFO)
Notices of Award (NoA)
Grant, Program-Specific and Standard Terms
Reporting Requirements
In addition to legislation and regulation, HRSA policies are established in Policy Clarification Notices, Program Letters which
operationalize the legislation and
provide guidance to recipients in understanding and implementing legislative requirements.
Finally, it also is important for all recipients to be aware of the specific requirements and expectations outlined in Notices of Funding Opportunity and Notices of Award, which can vary across funding opportunities awarded to Part B recipients.

10. RWHAP Part B Program
RWHAP Part B of title XXVI of the Public Health Service Act (Public Law ) provides grants to States and Territories to improve the quality, availability, and organization of core medical services and support services.
The AIDS Drug Assistance Program (ADAP) is a state and territory- administered program authorized under Part B that provides FDA-approved medications to low-income people living with HIV who have limited or no health coverage from private insurance, Medicaid, or Medicare. ADAP funds may also be used to purchase health insurance for eligible clients and for services that enhance access to, adherence to, and monitoring of drug treatments.
The Ryan White legislation for Part B includes grants to states and territories for the
Provision of core medical and support services (referred to as the Part B HIV Care Program) and
funds for the administration of AIDS Drug Assistance Programs or ADAPs.
ADAPs can
Provide FDA approved medications
Pay for health insurance premiums, and/or
Provide allowable services that support access to, adherence to, and monitoring of treatments

11. RWHAP Part B Program
Through authorities established in the RWHAP legislation and the Section on 311(c) of the Public Health Service Act, HRSA HAB awards the following grants:
RWHAP Part B HIV Care Program (X07): Base Award, RWHAP AIDS Drug Assistance Program (ADAP), ADAP Supplemental, Emerging Communities and Minority AIDS Initiative (MAI)
Budget Period: April 1- March 31
Current Project Period: April 1, 2017 – March 31, 2022 (5 years)
RWHAP Part B Supplemental Funds (X08): RWHAP Part B Supplemental award based on demonstrated need.
Budget Period/ Project Period: September 30 – September 29 (one year)
ADAP Emergency Relief Funding (X09): Additional funds to address the ADAP crisis in the US
Budget Period/ Project Period : April 1 – March 31 (one year)
Three specific grant programs are captured under Part B through the Ryan White legislation, and Section 311© of the Public Health Service Act
I’ll refer to each by name and HRSA grant activity code
Describe each

12. RWHAP Part B – State/Territory Models
HRSA RWHAP Part B Award
State/Territory
Lead Agency or Consortia
Direct Service Providers
HRSA RWHAP Part B Award
State/Territory
Direct Service Providers
Part B programs are implemented through a variety of models.
Depicted here are two models that are common.
In the first model, states or territories receiving Part B funding issue federal funds to subrecipients through subcontracts who then provide direct services to people living with HIV.
In the second model, states/territories award funds to a lead agency or a consortia, who then, on behalf of the jurisdiction, awards funds to direct service providers.
Within a state or territory, particularly those that are geographically large, or epidemiologically diverse, a combination of these two models may exist.
Direct Service
Lead Agency/Consortia

13. RWHAP Clients and Services
Services are offered to Eligible Clients when…
Individual is confirmed HIV positive
Individual meets income eligibility requirements established by recipient
Individual is uninsured or underinsured
Annual certification and 6-month recertification process is completed
Allowable Services include…
Core Medical Services
Support Services
Another key issue before we move into some specific budget requirements, is that
Part B, along with all other parts of the Ryan White program, must ensure that
services are offered to eligible clients, and
That services provided are allowable.
Two important policy clarification notices to help you understand and meet these requirements are
PCN regarding eligibility determinations and recertification requirements and
PCN titled Eligible Individuals and Allowable Uses of Funds, which will list and describe the core medical and support service categories that can be supported with Ryan White funds
Policy Clarification Notice (PCN) #13-02: Clarifications on Ryan White Program Client Eligibility Determinations and Recertification Requirements
Policy Clarification Notice (PCN) #16-02: RWHAP Services: Eligible Individuals and Allowable Uses of Funds Recently Updated

14. Questions
Let’s pause for a moment to see if there are any questions on what’s been shared so far

15. II. RWHAP Part B Fiscal Requirements
Let’s continue to our second major segment of this presentation, the fiscal requirements

16. RWHAP Part B Fiscal Requirements
Fiscal implementation of the RWHAP award starts with requirements and terms set forth in the RWHAP legislation, HRSA HAB PCNs, NOFO, and NOA
Budget Development
Financial Management
Unallowable Costs
Property Standards
Payor of Last Resort
Auditing Standards
State Match
Cost Principles
Maintenance of Effort (MOE)
Fraud, Waste and Abuse
Imposition of Charges
Listed here are 11 fiscal requirements we want to review today, some in more detail than others.
Again our goal is to provide you a high-level overview of these requirements and the source documents that you can review in more detail later for additional information.
You project officer is always available to answer questions
In some cases, it can be useful to have more detailed information about your specific program, how it is structured or what you are trying to achieve, to provide the best guidance.
As we move through this presentation, we will continue to pause periodically to see if there are any clarifying questions we can answer for your this morning

17. Fiscal Requirements Budget Categories
Our first fiscal requirement is budget development. Overall, the development of your budget should include support for and arise from your Integrated Planning process, particularly
Needs assessment
Resource inventories
Priority setting and
Resource allocation activities that have been implemented or developed in your jurisdiction
As part of budget development, I will spend some time reviewing the four budget categories we ask recipients to use on the SF 424 when submitting your Part B HIV Care Program budget.

18. Budget Development RWHAP Part B HIV Care Program (X07)
Budget Categories (used for SF-424)
Administration, including administration, planning and evaluation, and clinical quality management
ADAP, including medication and health insurance assistance
Direct Services, including state/territory direct services (core medical and support), home and community-based care, MAI, and health insurance continuation
Consortia and Emerging Communities
The four categories include Administration, ADAP, Consortia and Emerging Communities and Direct Services.
Of note, while the first budget category label we ask you to use is “administration,” we ask you to include
Admin costs, along with two costs that are not administrative (those being…
Planning and evaluation costs, and
Clinical quality management costs into this column of the SF-424
You will notice in the allocations report we ask that you submit, each of these three costs are documented separately. Here they are combined solely we are limited to four columns on the SF-424
The second and third budget categories are
ADAP including medication, health insurance and cost sharing and ADAP flexibility costs.
Direct Services including those for core medical services, support services, MAI, home and community based care and health insurance continuation funded by RWHAP Part B not those funded through ADAP.
Finally, we ask that you place funds for consortia and emerging communities together in a fourth category.

19. Budget Categories Administration: Admin, Planning/ Evaluation, CQM
ADAP
Direct Services
Consortia and Emerging Communities
We are going to start with some detail around ADMIN, P&E and CQM costs.

20. Budget Category – Administration
So again, within the Administration budget category, you are going to include your budget for
Administrative Costs, Planning and Evaluation Costs, and CQM Costs
Let’s start with Administrative Costs.
HRSA HAB PCN goes into details regarding administrative costs, which are subject to a 10% cap for Ryan White Parts A B C and D. You will also want to read relevant sections in the Uniform Administrative Requirement where you can find definitions for administration, direct costs, and indirect costs.
Per PCN 15-01, the types of costs at that are subject to the 10% administrative cap include
Routine grant administration and monitoring activities, including the development of applications and the receipt and disbursal of program funds;
Development and establishment of reimbursement and accounting systems;
Preparation of routine programmatic and financial reports;
Ensuring Compliance with grant conditions and audit requirements;
All activities associated with procurement procedures, including the development of requests for proposals, subrecipient and contract proposal review activities, negotiation and awarding of contracts;
Subrecipient monitoring activities including telephone consultation, written documentation, and onsite visits;
Reporting on contracts, and funding reallocation activities; and
Related payroll, audit and general legal services.
Two key points here
First, recipients must know how expenses are budgeted at both the recipient and subrecipient levels to ensure adherence to cap requirements. This will require appropriate training of staff involved in procurement, and subrecipient fiscal monitoring.
Second, recipients and subrecipients must be able to show how administrative costs are allocated across all funding sources, especially where multiple funding streams may be used to cover the total cost of a particular expense.
Administrative Cost Allocations
Recipients must know what is considered an administrative cost versus a direct cost
See PCN #15-01 Treatment of Costs under the 10% Admin Cap for RWHAP Parts A, B, C, and D
Recipients must have knowledge of subrecipient budgets
Obtain entire agency budget or budget for RWHAP-funded services
Recipients and subrecipients must show how administrative costs are allocated across all funding sources

21. Budget Category - Administration
Recipient Level
Administration – Capped at 10% of grant award, including indirect costs
Planning and Evaluation – Capped at 10% of grant award
Administration and Planning/Evaluation Combined – Capped at 15%
Clinical Quality Management – Capped at 5% of grant award or $3 million, which ever is less
Subrecipient Level
Administration – Capped at 10% of total allocation across all subrecipients for direct core medical and support services
I mentioned the 10% admin cap and I would like to make a few comments regarding the application of those caps at the recipient and subrecipient level.
At the recipient level, administration is capped at 10% of the award, including any indirect costs.
Planning and evaluation (or P&E), which we will talk about next, are capped at 10% of the grant award as well.
In regard to Admin and P&E, the two of them combined cannot exceed 15% of the award.
CQM costs are capped at an additional 5% of the award, or $3 million, which ever is less.
We will talk in a bit more detail about consortia, but if you are using a consortia model, the admin, P&E and CQM costs budget for consortia count toward the recipient caps for each category.
Now if a consortia or lead agency issues subcontracts on behalf of the state, then those subrecipients are treated as first line subrecipents of the consortia or lead agency. Administrative costs are capped at 10% of subcontracts awarded for direct core medical and support services, in aggregate, not for each subrecipient.

22. Budget Category - Administration Administrative Costs (10% Cap)
Recipient Level
If a RWHAP Part B recipient contracts with a lead agency or consortia to provide statewide or regional RWHAP management and fiscal oversight (i.e., acts on behalf of the recipient), then the administrative cost of that contract counts toward recipient’s 10% admin cap.
Subrecipent Level
If a RWHAP Part B lead agency or consortia contracts with subrecipients to provide direct services, then those direct service providers are considered first-line subrecipients of the lead agency or consortia and are therefore subject to the aggregate 10% admin cap for subrecipients.
Before we go onto planning and evaluation, two other points for clarification
If a RWHAP Part B recipient has contracted with an entity to provide statewide or regional RWHAP management and fiscal oversight (i.e., the entity has entered into a vendor or procurement relationship with the recipient, and is acting on behalf of the recipient), the cost of that contract, exclusive of subawards to direct service providers, would count toward the recipient’s (grantee’s) 10% administrative cap.
Admin costs associated with agencies providing direct services count toward the subrecipient 10% aggregate administrative cap. This would include those admin costs associated with direct services provided by the recipient or consortia agency.
Additionally, please be aware that any P&E or CQM in the consortia budget goes toward the recipients legislative caps for P&E and CQM.
Again, we encourage you to read PCN entitled, “Treatment of Costs under the 10% Administrative Cap for Ryan White HIV/AIDS Parts A, B, C and D for more details

23. Budget Category – Administration Planning and Evaluation Costs (10% Cap)
Related to planning for use of RWHAP Part B funds and evaluating effectiveness in delivering needed services.
Specific activities that P&E funds may support include:
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
Drug utilization reviews
This slide provides examples of some of the costs that may be allocated to Planning and Evaluation.
As a reminder P/E and CQM are not admin costs but are grouped together on sf424

24. Budget Category - Administration CQM Costs (5% or $3M cap, whichever is less)
The RWHAP requires the establishment of a clinical quality management (CQM) program. A CQM program is the coordination of activities aimed at improving patient care, health outcomes, and patient satisfaction.
It is important to know the difference between Quality Improvement (QI) and Quality Assurance (QA). You CANNOT charge QA to CQM. QA can only be charged to administration.
For more information see
PCN #15-02 Clinical Quality Management at
Frequently Asked Questions to PCN #15-02 at
All recipients must have a clinical quality management (CQM) program; In, PCN entitled “Clinical Quality Management” you can learn how this requirement must be implemented.
A CQM program is the coordination of activities aimed at improving patient care, health outcomes, and patient satisfaction.
A common mistake with charging costs to CQM is not knowing the difference between quality assurance and quality improvement. You cannot charge quality assurance activities to CQM.
Quality assurance is part of the larger administrative function of a recipient’s program or organization. It may inform the clinical quality management program, but quality assurance activities by themselves do not constitute a CQM program. Quality Assurance activities must be charged to administration. For example, anything that has to do with compliance standards and reporting requirements, such as data collection for the RSR requirement are administrative in nature and cannot be charged to CQM.
Quality improvement can be described as the development and implementation of activities to make changes to the program in response to performance data results. Quality improvement activities are aimed at improving patient care, health outcomes, and patient satisfaction.
At the bottom of this slide you will see links to our PCN on Clinical Quality Management.

25. Applies to subrecipients
Budget Category - Administration Salary Limitations (Appropriations Act 2018)
Salaries charged to HHS grants are limited to the Federal Executive Pay Scale Level II
Individual’s base salary, exclusive of fringe benefits and outside income earned
Applies to subrecipients
Award funds may not be used to pay the salary of an individual at a rate in excess of Federal Executive Level II of the Federal Executive Pay Scale. The 2018 salary limitation applied to HHS grants is $189,600. 
This amount reflects an individual’s base salary exclusive of fringe and any income that an individual may be permitted to earn outside of the duties to the applicant organization. 
At the bottom of this slide is a link to Office of Personnel Management or OPM’s Executive Pay rate scale.
See OPM website:

26. Budget and Budget Narrative – Equipment and Supplies
Equipment- tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost which equals or exceeds the lesser of the capitalization level established by the non-Federal entity for financial statement purposes, or $5,000
Supplies- tangible personal property other than those described in Equipment. A computing device is a supply if the acquisition cost is less than the lesser of the capitalization level established by the non-Federal entity for financial statement purposes or $5,000, regardless of the length of its useful life
separate items into three categories: office supplies (e.g., paper, pencils), medical supplies (e.g., syringes, blood tubes, gloves), and educational supplies (e.g., brochures, videos).
On the slide you can see the definitions for Equipment vs. Supplies. This information comes from the Uniform Administrative Requirements in Title 45 part 75 of the Code of Federal Regulations.
Read slide.
Source Per 45 CFR §

27. Budgets and Budget Narrative – Indirect Costs
Indirect (Facilities and Administration or F&A) costs means costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved.
Governmental departments or agency units receiving more than $35M in federal funds MUST have a federally negotiated indirect cost rate agreement (NICRA)
Recipients that do not have a federal NICRA may do one of the following:
Direct cost all expenses, or
Negotiate a rate with the Federal Government in accordance with 45 CFR part 75
De minimis rate of 10% of modified total direct costs (MTDC)  (45 CFR part (f)
This is our last slide related to administrative costs.
Indirect costs are incurred for a common or joint purpose benefitting more than one cost objective. These are costs necessary for the administration of the agency but not necessarily attributable to a specific grant or service category. Agencies receiving more than $35 million must have a negotiated Indirect Cost rate Agreement or NICRA.
The bottom of the slide has options for organizations with no NICRA.
Read slide

28. Budget Categories Administration: Admin, Planning/ Evaluation, CQM
ADAP
Direct Services
Consortia and Emerging Communities
Next we will review some requirements related to the ADAP and Direct Services

29. Budget Categories – ADAP
All dollars in ADAP Base need to be used for ADAP-related costs (even when carried-over).
The three primary service areas covered by ADAP are full-pay medication assistance, health insurance assistance (including premium and medication co-pay assistance) and ADAP Flex (access, adherence and monitoring services related to ADAP)
Costs related to the provision of medication (e.g., medication cost, cost of PBM, dispensing fee, etc.) are direct costs.
Funds awarded for ADAP must be used for ADAP alone and cannot be reallocated to other Part B services. This includes any carryover funds.
ADAP service categories include full-pay medication assistance, costs associated with health insurance premiums and co-pay assistance, and ADAP Flexibility services which includes those that support access to, adherence to, and monitoring of medication treatments. Recipients must request approval to use funds for ADAP flex services with each application or non competing continuation.
It is important to note that all costs associated with the distribution of medication such as those associated with a Pharmacy Benefits Manager or with a dispensing fee may be included as a direct services cost.

30. Budget Categories – Direct Services
A minimum of 75% of direct service funds must be spent on Core Medical Services
Includes ADAP
A maximum of 25% of direct service funds must be spend on Support Services
Exception: Recipients can apply for a Core Medical Services Waiver. See HRSA HAB PCN #13-07: Uniform Standard for Waiver of Core Medical Services Requirement for Grantees Under Parts, A, B, and C
Service Category Definitions: Policy Clarification Notice (PCN) #16-02: RWHAP Services: Eligible Individuals and Allowable Uses of Funds program-letters
The legislation requires that no less than 75% of direct services funds must be spent on Core Medical Services and a maximum of 25% of direct services funds be spent on support services.
For RWHAP Part B recipients all direct service funds spent through the ADAP on medications, health insurance, and to ensure adherence and access to drug treatments count toward the 75% direct services requirement.
If a recipient finds through needs assessment, resource inventory development or other planning activities, that there are unmet needs for support services and there are other sources of funds or payers for core medical services, then the recipient may can submit a request to waive the 75% core medical services requirement for a specific grant award.
Waiver requests must come in with the annual application or within 4 months of the budget period.
This may be an important tool for recipients looking to develop budgets that incorporate federal funds and rebate revenue collected through the ADAP

31. Budget Categories Administration: Admin, Planning/ Evaluation, CQM
RWHAP ADAP
Direct Services
Consortia and Emerging Communities
For the final budget category, we ask you to include line-items related to Consortia (if you use that model) and Emerging Communities.

32. Budget Category – Consortia and EC Consortia
Consortia: An association of public and nonprofit healthcare and support service providers and community-based organizations with which the state/territory contracts to provide the following for a specific region(s) or the entire state/territory
Needs assessment
Planning
Service delivery, either directly by consortia or by contract
Program and fiscal monitoring, including evaluation
Reporting, including required HRSA HAB and RWHAP Part B reports
A consortia is defined in the Ryan White legislation as an association of providers and community based organizations with which the Part B recipient contracts to provide the five services listed here.
Recipients can elect to establish a consortia if they feel the model works well for them and they would like to contract out all 5 of these activities.
While there are only a handful of states that use the Consortia model to implement the RWHAP Part B, it is important for those states to understand how to budget dollars distributed through consortia.
For example, all direct services contracted through a consortia are counted as support services. So states with consortia models need to ensure they meet the 75% core medical services requirement and/or request a waiver.

33. Budget Category – Consortia and EC Emerging Community
Emerging Communities (EC) Award: For eligible states/territories with jurisdiction(s) reporting between 500 and 999 cumulative AIDS cases over the most recent five years
EC funds can only be used for services within the designated EC and are not eligible for carry over.
Geographic boundaries for an EC may cross state lines. In these cases, states must collaborate on needs assessment and planning.
For FY 2019, there are 16 emerging communities.
EC dollars are provided to states to increase service provision in metropolitan statistical areas or MSA with between 500 and 999 cumulative AIDS cases over the most recent 5 years. In FY 2019 there were 16 ECs.
A couple of notes:
EC dollars must be spent within the boundaries of the MSA which in some cases may cross state boundaries. For example, the Cincinnati MSA includes counties in OH, KY and IN, although the funds are awarded to the state of Ohio.
EC dollars cannot be carried over.
So for this budget category, if you don’t utilize consortia or have emerging community funding, than you would report zero funds for this category of the SF-424.

34. Funding Restrictions
In addition to the general restrictions included in Section 4.1.iv of the SF-424 Application Guide, funds may not be used for the following:
Charges that are billable to third party payers;
Purchase or construction of new facilities or capital improvement to existing facilities;
Purchase of or improvement to land;
International travel;
Cash payments to intended RWHAP clients (as opposed to non-cash incentives to encourage participation in evaluation activities);
Pre-Exposure Prophylaxis (PrEP) or Post-Exposure Prophylaxis (nPEP) medications or related medical services (RWHAP recipients may provide prevention counseling and information to eligible clients’ partners per Program Letter, 6/22/16);
Syringe Services Programs (although some aspects are allowable with HRSA's prior approval and in compliance with HHS and HRSA policy);
Develop materials designed to directly promote or encourage intravenous drug use or sexual activity.
 Other non-allowable costs in 45 CFR part 75 – subpart E, Cost Principles.
As you develop your budget across these categories, we also wanted to remind you that in addition to the general funding restrictions that appear in the SF-424 Application Guide, funds may not be used for items listed here, which are also listed in the Part B HIV Care Program NOFO
You are likely familiar with many of these. I’ll point out a few
Since RW is a payor of last resort, you would not use your award for charges that are billable to other payers
We heard a lot in the opening session about PrEP. While RW infrastructure can be used to support access to PrEP, funds can not be used to purchase PrEP
I am going to turn the presentation over to Glenn to discuss a few slides focused on budget developemnt
Please note that 45 CFR Part 75 – Subpart E also identifies unallowable costs, so be sure to review those if you have not already.

35. Fiscal Requirements Budget Development
I am going to turn the presentation over to Glenn to discuss a few slides focused on budget development
Next lets talk about approaches for developing your budget.

36. Budget Development – Account for All Resources
Total Budget
Grant Award
Rebates
Program Income
Reimbursement
Non-Federal Funds
Recipients should budget for all resources across budget categories and consider how costs across funding streams will be allocated in the budget (e.g., salaries).
There are a number of considerations for recipients when sitting down to develop the budget. First, the recipient should include the allocation of all funding sources including the federal award, rebates and program income generated by the award, reimbursements associated with the award and non-federal funds applied to grant eligible services.
Ensure your services are allocated appropriately across all of your grants and be sure to document your expenditures by funding stream throughout the year.
Additionally, the budget should be consistent with the Integrated Plan, the state needs assessment and other applicable strategic plans and priorities.
The recipient should consider the full portfolio of funding available and think strategically about how to weave to those funds with other leveraged funds such as those available through the CDC and the US Department of Housing and Urban Development to create a full compendium of services for clients.

37. Budget Development – Account for All Resources Program Income
Program income means gross income earned by the non- federal entity that is directly generated by a supported activity or earned as a result of the federal award during the period of performance.
PCN #15-03: Clarifications Regarding the Ryan White HIV/AIDS Program and Program Income
The slide details the definition of program income. Program income must be spent back into eligible program services. This can be tricky in larger systems. Program income generated in the RWHAP program must stay in the RWHAP program and cannot be spent, for example, in other clinic or hospital programs.
On the bottom of this slide we have provided a link to Policy Clarification Notice #15-03 which provides program detail to support legislative requirements.

38. Budget Development – Account for All Resources Program Income
Recipients and subrecipients must pursue payment from Medicaid, Medicare or other health care coverage to further program objectives
If a service is billable to Medicaid, the subrecipient must be certified to bill and collect for the service
Recipients do not collect program income from subrecipients but monitor subrecipient use of program income.
Because of the payer of last resort requirement which my colleague Alice Litwinowcz will review shortly, all recipients must aggressively pursue payment from all other payment sources including Medicaid, Medicare, and health insurance. All services which can be billed to those sources should be. Failure to do so could result in an audit finding.
Recipients do not need to collect program income from subrecipients but should monitor that those funds are applied back into the subrecipients program.

39. Budget Development – Account for All Resources Pharmaceutical Rebates
ADAPs that purchase medications through a retail pharmacy network at a price higher than the 340B Drug Pricing Program price can submit claims to drug manufacturers for pharmaceutical rebates on medications or medication copayments, coinsurance, or deductibles to achieve cost savings comparable to those received by RWHAP ADAPs that directly purchase medications at the 340B price.
(Rebate: a return of a part of a payment)
PCN Utilization and Reporting of Pharmaceutical Rebates
RWHAP ADAPs are the only entity that may receive 340B Drug Pricing Program and Supplemental (i.e., ADAP Crisis Task Force) Rebates.
340B and Supplemental Rebates that RWHAP ADAPs receive are not considered program income and are not part of the RWHAP Part B award.
All rebates generated must be spent before federal funds and can only be spent on RWHAP allowable services

40. Payor of Last Resort
RWHAP grant funds cannot be used to make payments for any item or service if payment has been made, or can reasonably be expected to be made with respect to that item or service under any State compensation program, under any insurance policy, or under any Federal or State health benefits program, or by an entity that provides prepaid health care.
The legislation as cited here requires that RWHAP be the payer of last resort meaning that if another funding source can pay for the service it should.

41. Payor of Last Resort Recipients and subrecipients must:
Collaborate with Medicaid, Medicare, and other payers.
Create appropriate accounting and billing systems to submit for reimbursement and track funds.
Ensure budget and allocation plans include receipt and utilization of reimbursement from various payers.
For the RWHAP program a big requirement regarding the implementation of payer of last resort is a required collaboration with Medicaid, Medicare and other sources that pay for health services for those with limited access.
This that both recipients and subrecipients must establish connections with Medicare and Medicaid and as appropriate create billing systems and accounting systems to submit for reimbursement and track those funds. The recipients budget and allocation plan should include the receipt and utilization of those funds to pay for services. .

42. Questions
Before I turn the floor over to my colleague, I want to pause for questions. We went over a lot of information. We have about 5 minutes for questions.

43. Fiscal Requirements Imposition of Charges
RENE OR ALICE

44. Imposition of Charges
“Imposition of Charges” is a term used to describe all activities, policies, and procedures related to assessing RWHAP patient charges as outlined in legislation
It’s the law!
Public Health Service Act Sections 2605(e), 2617(c), and 2664(e)(1)(B)(ii)
Based on individual (not family income)
Prohibits charges imposed on RWHAP patients with incomes below FPL
Requires charges imposed on RWHAP patients with incomes above FPL
Established annual caps on charges
No RWHAP patient shall be denied service due to an individual’s inability to pay
HRSA RWHAP statute does not require that patients that fail to pay be turned over to debt collection agencies
You might be wondering what exactly is “Imposition of Charges?”
This term comes directly from statute where it refers to “Requirements Regarding the Imposition of Charges for Services.”
So what does that include?
HAB uses the phrase “Imposition of Charges” to encompass all of the elements necessary to meet the requirements in these sections of statute. This isn’t‘ TA on how to impose a charge, or ‘ask for payment’ from your RWHAP patients – although that is certainly a part of this training! Rather, it is all activities, policies, and procedures related to assessing RWHAP patient charges as outlined in statute.
So, why is it important? Because IT’S THE LAW! We will include excerpts from the statute in today’s slides, but here is the citation, for reference.
It’s important to note that imposition of charges is based on the income of the individual and not the total household income or family income. Some of the key points in statute that relate to imposition of charges include the provision that prohibits charging patients whose incomes are less than or equal to the federal poverty level; requires charging patients whose incomes are greater than the federal poverty level; and sets limits for annual charges.
Our statute also states, “no one shall be turned away due to their inability to pay.” This requirement makes clear that recipients should not deny services or turn RWHAP eligible patients away because they cannot pay the imposed charges. Statute does not require that patients that fail to pay be turned over to debt collection agencies if they are unable to pay for the charges imposed but RWHAP recipients should ‘vigorously pursue’ such payments.

45. Imposition of Charges Schedule of Charges Cap on Charges
Talking Points from “schedule of charges – layman’s terms” slide in PPT:
Schedule of charges is a term used in our statute and a requirement for our recipients. It refers to fees imposed on the RW patient for services based on the patient’s annual gross income.  A schedule of charges may take two different forms- a varying rate such as a sliding fee scale or a flat rate.
Your schedule of charges describes/defines the fees that are to be imposed on RWHAP patients for the RWHAP services they receive.
The statute does not state what the schedule of charges looks like. It may take the form of a flat rate or a varying rate (e.g. sliding fee scale). The design of the schedule of charges is left up to the recipient. The only statutory requirement related to the schedule of charges is that RWHAP patients at or below 100% FPL cannot be charged and those RWHAP patients with income above 100% FPL must be charged.
The statute also explains that RWHAP recipients may impose a nominal charge. So what is that?
A nominal charge is a fee greater than zero. Some providers have incorrectly interpreted nominal charge to be zero.
Talking Points from “cap on charges – layman’s terms” slide in PPT:
Cap on Charges is the limitation on aggregate charges imposed during the calendar year based on a RWHAP patient’s annual gross income.
The RWHAP legislation outlines specific FPL categories related to cap on charges. The first one is % FPL. Patient’s whose income fall in this category are capped at 5% of their annual gross income. Patients with annual gross income in the % FPL category, are capped at 7% of their income; and patient’s with annual gross income > 300% FPL are capped at 10% of their income.
Remember that providers cannot charge patients with incomes ≤100% FPL. Therefore, it goes without saying that they would not need a cap defined since they are not charged.
Schedule of charges and cap on charges are the two requirements that make up “imposition of charges.”
An Imposition of charges policy should include the following;
a schedule of charges that does not impose a charge to RWHAP patients with income at or below 100% FPL,
imposes a charge for all RWHAP patients with income over 100% FPL, and
limits aggregate charges during the calendar year for all RWHAP patients (cap on charges).
Includes a process to capture documentation of RWHAP patient’s annual gross income needed to determine placement on the schedule of charges and annual cap on charges;
Outlines a process to assess, document, and track the charges that the agency imposes on their RWHAP patients, and also tracks the charges imposed on their RWHAP patients by other RWHAP providers (as submitted by the client).
Finally has in place a reliable system to alert the billing system that a RWHAP patient’s cap has been reached and the patient should not be further charged for the remainder of the calendar year.

46. Imposition of Charges Webinar on October 2
HRSA HAB presented a technical assistance (TA) webinar on imposition of charges
The recording and slide presentation are available on TargetHIV
We encourage you to review the HRSA HAB TA webinar presented on October 2nd. You can find the recorded webcast on TargetHIV.

47. Fiscal Requirements Cost Principles and Auditing Standards

48. HHS Uniform Administrative Requirements–45 CFR 75
45 CFR 75 codified in 2016 established requirements related to:
Cost Principles
Subpart E establishes principles for determining the allowable costs incurred by non-Federal entities under Federal awards.
Administrative Requirements
Subparts B through D set forth the uniform administrative requirements for grant and cooperative agreements, including the requirements for HHS awarding agency management of Federal grant programs before the Federal award has been made, and the requirements HHS awarding agencies may impose on non-Federal entities in the Federal award.
Audit Requirements
Subpart F sets forth standards for obtaining consistency and uniformity among Federal agencies for the audit of non-Federal entities expending Federal awards.
The HHS Uniform Administrative Requirements supersedes, streamlines, and combines 8 OMB circulars into a single document. Again, it is a consolidation of information rather than “new” or “revised” information. The HHS UAR replaces 45 CFR part 74, which codified the grants rules for non-profits, and 45 CFR part 92
Now you only have to track the requirements contained in one document, 45 CFR 75, instead of 8.
NOTE:
45 CFR 75 You may heard about the Super Circular or Title 2 of the Code of Federal Regulations Part 200 – Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. HHS, like many other Federal agencies, made modifications and clarifications to this guidance, and implemented it as regulation at 45 CFR Part 75 - Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards.

49. Cost Principles Allowable §75.403 Allocable §75.405 Reasonable §75.404
Conformance with limitations and exclusions contained in the terms and conditions of award
Allocable §75.405
Goods or services are chargeable or assignable to a specific grant, function, department, or other component (i.e., cost objective) in accordance with the relative benefits received or other equitable relationship.
Allocable to grant if
incurred to advance work under grant,
benefits both grant and other work of organization, or
is necessary to overall operation of the organization and is assignable (at least in part) to the grant.
Reasonable §75.404
In its nature or amount, cost does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost.
HHS GPS p77, II-25
Cost principles are used to formulate budgets, allocate financial resources and make appropriate charges to the grant. The cost principles will help you determine- allowability, allocability and reasonableness.
Allowability
The costs must be reasonable.
The costs must be given consistent treatment through application of those generally accepted accounting principles appropriate to the circumstances.
The costs must conform to any limitations or exclusions set forth in the federal award and 45cfr75 Subpart E
Allocability
process of assigning a cost, or a group of costs, to one or more cost objectives, in reasonable and realistic proportion to the benefit provided.
To determine allocability, ask:
Are the costs allocated on a consistent basis?
Is the method of allocating costs sound?
Is the cost allocation clearly documented?
Reasonableness
in its nature and amount, it does not exceed that which would be incurred by a prudent person in the conduct of competitive business. Objective individuals would agree that a cost is appropriate.
To determine if a cost is reasonable, ask:
Is it necessary for performance of the award?
Does it advance the scope of work?
Is it consistent with established institutional policies and practices?
Would it withstand external review by a prudent individual?

50. Post Federal Awards Requirements – Financial Management Systems
45 CFR Financial management and standards for financial management systems
Identify and track funds received and expended
Provide accurate, current, and complete financial results
Compare actual expenditures with budgets
Have adequate documentation to support expenditures
Have adequate internal controls, including establishing and maintaining written procedures (§75.303)
Have adequate subrecipient monitoring and management (§ )
FROM DFI
45 CFR 75 establishes post federal award requirements for all HHS awards, and sections 302 and 303 discuss financial management and standards for financial management systems, and internal controls that should be in place during and even before receiving a federal award. In general, a financial management system is the broad web of the methodologies, procedures, and software that your organization uses to track and monitor its income, expenses, and assets and compliance with federal and local fiscal requirements. Systems such as your accounting system, labor system, procurement system, and others make up your overall financial management system.
States are required to expend and account for their federal awards in accordance with state laws and procedures for expending and accounting for the state’s own funds. At a minimum, all financial management systems for non-federal entity must be able to perform the functions listed on the slide. In addition, part of adequate subrecipient monitoring requires ensuring that subrecipients have adequate financial management systems related to their subawards, as well.

51. Post Federal Awards Requirements – Financial Management Systems
RWHAP Part B recipients must establish standards, policies, procedures and systems at recipient and subrecipient levels for:
Financial Policies and Procedures
Recipient and subrecipient documentation requirements
Processes and timeframes for payment/reimbursement
Processes to track all funds using general accounting practices, including income and expenses pertaining to the RWHAP Part B Program
Processes to track expenditures by each component of the RWHAP B X07 Award (Part B base, RWHAP ADAP base, RWHAPADAP supplemental, Emerging Community, MAI)
Processes to track expenditures by category – administration, clinical quality management, core and support services
These things are outlined in NMS

52. Uniform Administrative Requirements 45 CFR Part 75 Independent Audit Requirements
Audit Requirements are set forth in 45 CFR Part 75, Subpart F
Applies to recipients and subrecipients of RWHAP funds
All recipients and subrecipients that expend more than $750,000 per year in federal grants receive an audit annually
FROM DFI
The Audit Requirement ensures that recipients of a certain size under go regular fiscal auditing of major programs. Starting in 2015, updates to the Uniform Administrative Requirements increased the audit threshold to $750,000. Recipients that meet the threshold must hire an external auditor to review major programs and are generally required to have a Single Audit performed in accordance with Generally Accepted Government Auditing Standards. Findings require a state response showing how the finding will be resolved. The completed audit is submitted through a Federal Clearinghouse and distributed to all agencies that distribute grants to that recipient. HRSA Project Officers regularly review those audit findings and will discuss with recipients how they may be resolving audit findings.

53. Fiscal Requirements Property Standards Fraud, Waste, Abuse

54. Property Standards 45 CFR 75.316–323 - Property Standards
Uniform standards for management and disposition of property furnished by HRSA or charged to an HRSA award
Provisions are include for items such as insurance coverage, real property, equipment, intangible property, and property trust relationships.
Certain reports related to property are required for applicable recipients.
For property questions, HRSA has a dedicated mailbox at available to all recipients.
HHS and HRSA have specific property standards for all grants, outlined in 45 CFR through The purpose of property standards is to govern management and disposition of property furnished by HRSA or whose cost was charged directly to a project supported by a HRSA award. Recipients may use their own organizational property management standards and procedures so long as they meet the requirements of this section and their award terms and conditions. The standards outline requirements around real property, equipment, supplies, intangible property and copyrights, and other types of property. They include requirements around insurance coverage; title, use, and disposition; property trust relationships; and other areas. There are certain actions related to property that recipients must formally report to HRSA, such as notice of federal interest filings, property status reports, and tangible property forms. HRSA has provided user guides for those forms and workshop technical assistance presentations on the HRSA Manage Your Grants website, available 24/7.

55. Fraud, Waste, Abuse
45 CFR , Mandatory Disclosures, notes that recipients or applicants must disclose, in a timely manner and in writing, all violations of federal criminal law potentially effecting the HRSA award.
For suspected or identified fraud, waste, abuse, or mismanagement related to a HRSA award, HHS Office of Inspector General, call HHS-TIPS ( ) or submit through the mail or electronically at
All organizations are at risk for fraud, and health care organizations may be at heightened risk. For all federal awards, recipients and even applications must disclose all violations of federal criminal law that could effect the HRSA award. Fraud, waste, or abuse could happen at any point during an award’s life cycle. To understand the difference, fraud is a deliberate deception to secure an unfair gain. Waste is the unnecessary incurrence of costs as a result of inefficient practices, systems or controls. And abuse is the intentional misuse of authority, position, funds or resources for personal gain.
RWHAP funds can only be used to meet critical program needs if they are not misused, and ensuring that requires vigilance from everyone. The HHS OIG Hotline Operations accepts tips and complaints from all sources about potential fraud, waste, abuse, and mismanagement in HRSA and all HHS programs. In addition, HRSA provides oversight, guidance, and technical assistance to help recipients ensure grant dollars are spent appropriately and waste, fraud and abuse are prevented and detected. If you have questions or concerns related to fraud, waste, abuse or other mismanagement, please reach out to your Project Officer for connection to proper resources.

56. Questions

57. IV. Federal Financial Reports and Penalties
YEMISI STARTS HERE

58. RWHAP Part B Interim FFR – 75% Obligation
Used solely to report on compliance with RWHAP Part B 75% obligation requirement
Must be submitted annually through the Electronic Handbooks (EHB) due date is 150 days after receipt of final award
Used to report on obligations up to 120 days after receipt of final award
The Reporting Requirements section of the NoA states specific due date
The interim FFR must be submitted 150 day after the final award is issued. We used this report to ensure compliance with the 75% obligation requirements. The report will provide us an summary of your obligation up to 120 days after the final award was issued. Which means you will have 30 days to prepare your interim FFR. It is very important that you submit this report ON TIME. THE DUE DATE WILL BE ON YOUR NOA IN THE REPORTING REQUIREMENT SECTION.
45 CFR 75.2 (Subpart A, Definitions) : Obligations, when used in connection with a non-Federal entity's utilization of funds under a Federal award, obligations means orders placed for property and services, contracts and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period.
Unliquidated obligations means, for financial reports prepared on a cash basis, obligations incurred by the non-Federal entity that have not been paid (liquidated). For reports prepared on an accrual expenditure basis, these are obligations incurred by the non-Federal entity for which an expenditure has not been recorded.
Unobligated balance means the amount of funds authorized under a Federal award that the non-Federal entity has not obligated. The amount is computed by subtracting the cumulative amount of the non-Federal entity's unliquidated obligations and expenditures of funds under the Federal award from the cumulative amount of the funds that the Federal awarding agency or pass-through entity authorized the non-Federal entity to obligate.

59. RWHAP Part B Interim FFR – 75% Obligation
45 CFR 75.2 (Subpart A, Definitions): Obligations, when used in connection with a non-Federal entity's utilization of funds under a Federal award, obligations means orders placed for property and services, contracts and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period.
45 CFR 75.2 (Subpart A, Definitions) : Obligations, when used in connection with a non-Federal entity's utilization of funds under a Federal award, obligations means orders placed for property and services, contracts and subawards made, and similar transactions during a given period that require payment by the non-Federal entity during the same or a future period.
Unliquidated obligations means, for financial reports prepared on a cash basis, obligations incurred by the non-Federal entity that have not been paid (liquidated). For reports prepared on an accrual expenditure basis, these are obligations incurred by the non-Federal entity for which an expenditure has not been recorded.
Unobligated balance means the amount of funds authorized under a Federal award that the non-Federal entity has not obligated. The amount is computed by subtracting the cumulative amount of the non-Federal entity's unliquidated obligations and expenditures of funds under the Federal award from the cumulative amount of the funds that the Federal awarding agency or pass-through entity authorized the non-Federal entity to obligate.

60. Part B Interim FFR in EHBs 75% Obligation
On the interim FFR line F captures the unliquidated obligations provided by the recipient.
When determining the 75% obligation penalty, the amount expended plus the amount obligated and unliquidated are considered.
This line can be used on the Interim FFR
(not the final FFR)

61. 75% Obligation Penalty
Per legislation, recipients shall obligate 75% of their RWHAP Part B Base award within 120 days of receipt or receive 2 penalties:
Reduction in current year award
Not eligible for RWHAP ADAP Supplemental
Reduction in current year award
Not eligible for ADAP Supplemental (not to be confused with X08 Part B Supplemental)
Note that ADAP supplemental is a funding stream within X07
The NCC instruction or NOFO describes the criteria for X07
If 75% of RWHAP Part B Base funds are not obligated in time, the unobligated amount is de-obligated from the recipient and added to the RWHAP Part B Supplemental (X08) pool.
States/territories must meet at least one of the following criteria, as reported by the state/territory on the most recent ADAP Data Report (ADR):
1) Financial requirement of Federal Poverty Level (FPL) = or < 200 percent;
2) Limited formulary compositions of all core classes of antiretroviral medications;
3) Waiting list, capped enrollment, or capped expenditures; and/or
4) An unanticipated increase of eligible individuals with HIV.
Even if a state/territory meets one of the eligibility criteria listed above, it will be deemed ineligible if the state/territory did not obligate 75 percent of the previous FY RWHAP Part B award within 120 days of the budget period start date. The 75 percent obligation must be reported on the previous FY Interim Federal Financial Report (FFR) submitted within 150 days of the budget period start date.
As mentioned before if the funds are not obligated within 120 days, the amount will be de-obligated and added to the X08 part B supplemental pool for the current fiscal year award.

62. Annual/Final FFR
Must be submitted annually through the EHBs; due date aligned with PMS quarterly due date
Used to report on annual expenditures, annual unobligated balances (UOB) by funding source, match amounts, and rebates
The Reporting Requirements section of the NoA states specific due date

63. Annual/Final FFR – In EHBs Transactions Section
10d. – Populated from EHBs- this is the total authorized amount and includes any carryover funds
Note that unlike the interim FFR line F cannot be filled in for the final FFR. If line f has funds in it, the GMS will return the FFR.
10f. – This line cannot be used on the annual FFR

64. RWHAP ADAP Supplemental Match
Match Requirements
State Match
Base and ADAP components of award
Section 2617(d)(1) of the PHS Act
For states/territories with >=1% of HIV cases nationally in last two fiscal years
Begins at
$1 for every $5 in federal funds.
Increases to
$1 in $2 federal funds.
RWHAP ADAP Supplemental Match
Section 2618(a)(2)(F)(ii)(III) of the PHS Act
For states/territories eligible and awarded ADAP Supplemental Funding
$1 for every $4 federal in funds (25% of award)
Can request a waiver if State Match requirement is met
Payment of match requirement authorizes expenditure of award
To determine the State Match Requirement, the following are considered: Part B Base, ADAP Base and EC.
matching funds are required from States with more than one percent of the total HIV cases reported to the CDC during the previous two FYs
The match begins at $1 in non-federal funds for every $5 in federal funds and increases to $1 in non-federal funds for every $2 in federal funds in later years
To determine the ADAP Supplemental Match requirement ADAP is considered
State/Territory is eligible for a waiver from the match requirement for ADAP Supplemental funding if it also has a State match requirement for the RWHAP Part B Formula/ADAP Base funding, and it meets that match requirement.
State Match begins at $1 in non-federal funds for every $5 in federal funds and increases to $1 in non-federal funds for every $2
in federal funds in later years (Section 2617(d)(1) of the PHS Act).
The ADAP Supplemental Grants require a State match of 25 percent (i.e., $1 for
each $4 of federal funds provided), unless a waiver is requested and approved
(Section 2618(a)(2)(F)(ii)(III) of the PHS Act). A State/Territory is eligible for a
waiver from the match requirement for ADAP Supplemental funding if it also has a
State match requirement for the RWHAP Part B Formula/ADAP Base funding, and
it meets that match requirement.
Verbally acknowledge that there is an MOE requirement

65. Annual/Final FFR In EHBs Match Requirement
Amount entered in the first column was provided in the Interim FFR (not required), second column is where the final match amount is entered. The 3rd column is the total of the two.
Cost sharing/matching requires completion of
10j. (ADAP Supplemental/ State Match)

66. Match Penalty
If HRSA HAB discovers after the close of a grant budget period that a recipient has not met its match requirement on the Base and ADAP component of the award, the recipient must pay back improperly obligated funds under those components of the award.
HRSA OFAM Division of Financial Integrity (DFI) will recoup the funds.
In order to use federal funds awarded, Matching is required to allow use of federal funds
HRSA will recoup funds that are unlawfully obligated because they were not properly matched.
NOTE: Per OGC, There are other enforcement mechanisms that are possible, depending on when the missing match is discovered. HRSA can
Prior to award, voluntarily lower the amount awarded to meet the amount that the state can match
During/post award, the recipient can return funds to HRSA that it will not be able to match

67. Match Requirement – On Notice of Award (NOA)
Match Summary
State Match $________
ADAP Supplemental Match $_____________
Total Match Requirement $___________
The amounts of state and ADAP Supplemental Match can be found on the face page of the Notice of Award
The total match requirement is required in the recipient share section of the FFR. The breakdown between state match and ADAP supplemental match must be listed in the comment section of the FFR. The total match amount will be found on the first page of the NOA.
The match requirement is listed in the Remarks section of the FFR

68. UOB Requirement
RWHAP Part B recipient are required to submit an estimate of their projected unobligated balance for the current grant year and an estimated carryover request.
Estimated carryover request must include the intended use of fund.
IF AN ESTIMATED UOB AND CARRYOVER REQUEST ARE NOT SUBMITTED, NO CARRYOVER WILL BE PERMITTED, with the exception of MAI
RWHAP Part B recipient are required to obligate 75% of their award within 120 days of receiving their final award
RWHAP Part B recipient are required to spend 95% (no more than 5% UOB) of their Base and RWHAP ADAP award by the end of the budget year.

69. UOB Penalty
If UOB exceeds 5%, the recipient’s future year Part B Base and ADAP Base awards are reduced by the amount of UOB less approved carryover.
When recipient has UOB because it expended ADAP Base rebate dollars before grant dollars (as required), it may request that the amount of UOB be reduced by the amount of expended rebates. 
UOB incurred as a result of expending rebates does not incur a penalty.
Any amount of UOB not request and/or approved for carryover is subject to offset on current year award
UOB penalties are determined by combining Base and ADAP UOB and calculating that as a percentage of
their Base and ADAP award. However, it is possible for a grant recipient to have a UOB penalty but only
be penalized in one funding stream. If a grant recipient incurs a penalty but doesn’t have UOB in one of
the funding streams (i.e. Base or ADAP) then that particular award is not impacted. The penalty is only
incurred on the award for which the UOB exists.
NOTE: Per OGC, when recipients expend rebates first and there is a UOB over 5 percent, the statute allows a waiver of the penalties, so long as that UOB is the result of expending rebates.

70. Annual/Final FFR In EHBs – UOB
These amounts will auto- populate based on the awarded amounts reflected on the Notice(s) of Award (including carryover)
(Can include new money and carry over)
The amounts in these 2 columns are base on the amounts reported by the recipient when the FFR is filled out
(Will include UOB from previously approved carry over)
The first column (federal fund authorized) will prepopulate from the NOA. The unexpended Carryover are funds carried over from the previous fiscal year into the current fiscal year that has not been spent. The current year column are funds that are unobligated and broken down into categories.
The rebate section should be used to break down the rebates received by the recipients.
These amounts are the unobligated balances of any funds previously carried over (and not expended), and not the amount of funds the recipient plans to carry over!

71. Annual/Final FFR - Rebate Section
Must be reported by all recipients who generate rebates
Specific to the budget period
Expended Rebates
Amount of rebates to be used to reduce UOB
Unexpended Rebates
Cumulative
Total Rebates available
Expended rebates reported here are used to determine UOB penalty.
Note: Information on rebates received during the grant period (this is the budget period), rebates expended during the grant period (this is the budget period), and any remaining balance (cumulative) must also be provided in the “Comments” section

72. Annual/Final FFR In EHBs – Rebates
Amount of rebates received and requested amount to be used for UOB reduction, if any

73. Annual/Final FFR - Rebate Section
If a recipient has an unobligated balance greater than 5% directly due to the receipt and expenditure of rebate funds, they must inform HRSA of this in order to not be penalized. This information is reported in the “Comments” section as follows:
“The state of XXX is requesting that $____ of the unobligated balance be reduced by $___ of the obligated rebates funds and that such amount be carried forward to the next budget year”.
The reduction request cannot be more than the amount of UOB

74. FFR Review and Reconciliation
The GMS FFR review consists of determining the accuracy and completeness of reported information
This is done through a comparison of awarded amounts, expenditures, and financial reconciliation
Financial reconciliation is the comparison of the data reported on the FFR, the data reported to the Payment Management System, and the amount of funds actually drawn from the account

75. Carryover Request & Approval Process
Submitted with the FFR (July 30th) or 30 days after (August 30)
Funds can only be used for core and support services within the same sub-category
Request must include:
Why the recipient was unable to expend the funds
Service categories the funds will be used for
Number of clients and units
New, Existing or Continuing service
Must be able to spend by the end of the grant year
Carryover Prior Approvals now include a system check to ensure that carryover amounts do not exceed available UOB by sub-category (FRML, ADAP, ADAP_SUPP, etc.)
Prior approvals can be submitted with the FFR, but cannot be reviewed until the FFR is approved.
Approval Process in EHB starts with Program and ends with DGMO
Project Officer  Branch Chief  Deputy/Director  GMS
(in previous years carry over could be requested regardless of what balance remained in each category.

76. Annual/Final FFR – Carryover Request
This represents the total UOB from all sources, and may include some amounts that are not eligible for carryover.
When requesting a carryover, be sure to select YES. Having an UOB does not serve as a request for carryover. After selecting yes, submit a prior approval request and a tracking number will appear in this section along with the status of the request.
If a Prior Approval for carryover was submitted for this budget period, the PA tracking number will appear here.

77. Questions

78. V. Key Resources

79. Important Resources
HRSA Resource Page - Manage Your Grant
Uniform Administrative Requirements (45 CFR 75)
Collection of policies, reports, tip sheets, trainings and other resources
HIV/AIDS FFR Guide (for H89 & X07 UOB)
Ryan White HIV/AIDS Program Recipient Resources recipient-resources
RWHAP Legislation
Policy Clarification Notices and Program Letters
National Monitoring Standards – Program, Fiscal, Universal
RWHAP Part B and ADAP Manuals
The National Monitoring Standards
Reviews requirements across key authorities used for compliance, oversight, and expectations
Assists recipients in meeting federal requirements for program and fiscal management, monitoring, and reporting

80. E-mail: Alitwinowicz@hrsa.gov Senior Program Advisor
Contact Information
Division of State HIV/AIDS Programs (DSHAP) HIV/AIDS Bureau (HAB) Health Resources and Services Administration (HRSA) Web: hab.hrsa.gov
RENE CLOSES OUT HERE
Amy Griffin
Alice Litwinowicz
Project Officer
Senior Policy Advisor
Phone:
Phone:
Yemisi Odusanya
Rene Sterling
Senior Program Advisor
Deputy Director
Phone:
Phone:

81. To learn more about our agency, visit
Connect with HRSA
To learn more about our agency, visit
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82. ADDITIONAL SLIDES

83. Fiscal Requirements State Match & Maintenance of Effort

84. HRSA RWHAP Core Medical Services
AIDS Drug Assistance Program Treatments
Hospice
Medical Case Management, including Treatment Adherence Services
AIDS Pharmaceutical Assistance
Early Intervention Services (EIS)
Medical Nutrition Therapy
Health Insurance Premiums and Cost Sharing Assistance for Low-Income Individuals
Mental Health Services
Oral Health Care
Outpatient Ambulatory Health Services
Home and Community-Based Health Services
Substance Abuse Outpatient Care
Home Health Care
This is the list of core medical services including the ADAP allowable in the RWHAP.
At the bottom of the page is a link to PCN 16#02. This is the PCN where HAB defines what is allowable in all service categories. If you have not visited it recently, please do so. We recently released revisions.
Policy Clarification Notice (PCN) #16-02: RWHAP Services: Eligible Individuals and Allowable Uses of Funds

85. HRSA RWHAP Support Services
Child Care Services
Other Professional Services
Emergency Financial Assistance
Outreach Services
Food Bank/Home Delivered Meals
Psychosocial Support Services
Referral for Health Care and Support Services
Health Education/Risk Reduction
Housing
Rehabilitation Services
Linguistic Services
Respite Care
Medical Transportation
Substance Abuse Services (residential)
Non-Medical Case Management Services
This slide lists the allowable support services.
Policy Clarification Notice (PCN) #16-02: RWHAP Services: Eligible Individuals and Allowable Uses of Funds

86. Match Requirements
Ensures states/territories make available non-federal contributions to match the RWHAP Part B (X07) funding received (not expended)
Listed on Notice of Award
Requirement can be met through non-federal cash, donations (public or private in-kind resources), or rebates
Must be documented and verifiable in recipient records
Match must be reported on the Federal Financial Report (FFR)
Reporting State Matching Funds (X07, if applicable)
Items 10i (Total Recipient Share Required) and 10j (Recipient Share of Expenditure) of the SF-425 document that the required state match for the grant has been met (i.e., the requirement is met when the sum of 10i and 10j equals the required state match amount). If a state has both a state match and ADAP Supplemental match, the recipient must specify in the Remarks section how the match reported in lines 10i and 10j meets each of the required match amounts.

87. RWHAP ADAP Supplemental Match
Match Requirements
State Match
Section 2617(d)(1) of the PHS Act
For states/territories with >1% of HIV cases nationally in last two fiscal years
Begins at
$1 for every $5 in federal funds.
Increases to
$1 in $2 federal funds.
RWHAP ADAP Supplemental Match
Section 2618(a)(2)(F)(ii)(III) of the PHS Act
For states/territories eligible and awarded ADAP Supplemental Funding
$1 for every $4 federal in funds (25% of award)
Can request a waiver if met State Match requirement
To determine the State Match Requirement, the following are considered: Part B Base, ADAP Base and EC.
matching funds are required from States with more than one percent of the total HIV cases reported to the CDC during the previous two FYs
The match begins at $1 in non-federal funds for every $5 in federal funds and increases to $1 in non-federal funds for every $2 in federal funds in later years
To determine the ADAP Supplemental Match requirement ADAP is considered
State/Territory is eligible for a waiver from the match requirement for ADAP Supplemental funding if it also has a State match requirement for the RWHAP Part B Formula/ADAP Base funding, and it meets that match requirement.

88. Maintenance of Effort (MOE)
Section 2617(b)(7)(E) of the PHS Act requires states/territories to maintain HIV-related activities at a level that is equal to not less than the level of such expenditures by the State for the 1-year period preceding the fiscal year for which the State is applying to receive a grant.
MOE documented in
Full grant application submitted year 1 of each 5-year project period
Non-Competing Continuation (NCC) Progress Report submitted years 2-5 of each project period
The RWHAP legislation requires that the state maintain their financial contribution at the same level from year to year. The same state contributed funds may be used to meet the MOE and the State Match requirement.