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School-Based Health Center Capital HRSA-13-140 Post-Award Technical Assistance Call January 10, 2013
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Objectives Describe the School-Based Health Center Capital Program (SBHCC) awards Discuss critical compliance requirements Review the terms and conditions of the SBHCC Notice of Award (NoA) Explain the process for SBHCC post-award submission and review 2
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SBHCC Overview On December 12th, HRSA awarded $78 million in SBHCC awards to 197 grantees The funded applications include 263 projects for new/expanded school-based health center sites (construction projects), improved/upgraded school-based health center sites, and equipment-only projects 3
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General Requirements Separate PMS sub-account: C12CS#####AC Funds must be accounted for and reported separately (from section 330 funds and from other HRSA grant funds) –If there are non-federal sources of project funding, SBHCC funds must be drawn down proportionately to total project costs 4
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Ineligible SBHCC Costs Costs incurred prior to 90 days before the award date Operating costs (e.g., funding direct services, clinical full-time equivalents, rent, mortgage payments, refinanced credit facilities) Salary of applicant’s staff and consultant fees that are not related to the administration of the technical aspects of the proposed project Indirect costs such as general department operations and maintenance Expendable office, medical, and laboratory supplies Educational supplies Mobile vans for purposes other than service delivery Electronic Health Records software and licenses Costs not associated with the requested award 5
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Understanding the NoA Project/budget period for the SBHCC: December 1, 2012 through November 30, 2014 SBHCC activity code: C12 SBHCC grants are one-time funds. There is no ongoing support of SBHCC grant activities after the end of the 2- year project/budget period. 6
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C12 Grant Handbook A grant handbook for the C12 grant has been created in the grantee’s portfolio in EHB The project director needs to ensure he/she has added the SBHCC grant to the portfolio and that the correct grantee staff are assigned to roles and functions in the C12 Grant Handbook The following EHB Help Resource can guide you through these processes: –https://grants.hrsa.gov/webexternal/help/hlpPage.asp?h F=grants_managementhttps://grants.hrsa.gov/webexternal/help/hlpPage.asp?h F=grants_management 7
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Roles - C12 Project Officer Monitor conditions Review revised budgets, schematics, concept /site plans, and construction timelines Assist with pre-implementation Ongoing monitoring and technical assistance Closeout 8
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Roles - C12 Grants Management Specialist Review revised budgets, Federal Interest, lease documentation Process prior approval requests Approve Project Director changes Ongoing monitoring and technical assistance Closeout 9
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Starting Projects Grantees must carefully review all terms and conditions of the NoA Grantees must respond to conditions and HRSA must issue a revised NoA that clearly approves the project and lifts conditions before ground can be broken on a project Prior to receiving final HRSA approval, grantees may only incur costs related to preparatory work such as: –Site plans, architectural and engineering schematics, environmental and historic preservation requirements, etc. 10
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Resolving Conditions on SBHCC Awards Grant Conditions & Program Conditions –Submissions can be uploaded to each corresponding condition within the Electronic Handbook (EHB) –Revised NoAs will not be issued until all applicable conditions have been met for each SBHCC project 11
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Electronic Document Submissions in EHB SBHCC grantees must submit all documents required as a condition of award on the NoA directly to EHB HRSA Program or Grants Office Personnel may also request other information through EHB By default, the Project Director will have access to all reports and submissions All other users must be given privileges to view, edit, or submit by the Project Director or other user with the ability to Administer User Privileges in the Grant Handbook 12
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Condition Deliverables and Due Dates If an extension to a submission deadline is needed: –Please discuss with your assigned C12 Project Officer and/or Grants Management Specialist –Sufficient justification will be needed when requesting an extension Describe the impact of the extension on the overall project timeline 13
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Proposed New Sites for H80 Grantees H80 grantees are reminded that if they would like a SBHC site added to their scope, a Change In Scope request must be submitted to the H80 project officer 14
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Equipment Purchases Equipment must be used at the approved project site Equipment tracking, insurance and maintenance 45 CFR Parts 74.31, 74.34, Part 92.32, and Department of Health and Human Services (DHHS) Grants Policy Statement II-66 15
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Federal Interest The Federal government always retains interest in property constructed, acquired, or improved with Federal funds –For ALL construction and property acquisition projects, applicants must file a Notice of Federal Interest (NFI) –For alteration/renovation projects, Federal Interest exists for the useful life attributable to the alteration/renovations funded under this grant Grantees are required to file a NFI for projects with allowable costs more than $500,000 (excluding moveable equipment) Grantees are not required to file a NFI for alteration/renovation projects with total project costs less than $500,000, excluding moveable equipment costs –Federal Interest still exists –Must maintain documentation regarding protection of all Federal Interest –Disposition of Federal Interest will be addressed on a case by case basis in accordance with 45 CFR 74.32 or 92.31. 16
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Federal Interest – Leased Property Lessors must agree in writing to the proposed project and to subordinate its interest to those of the Federal government. The lessor must agree to include in the lease agreement clauses that indicate the continued rights of the recipient/Federal Government in the event that the lessor of record changes. Grantees must maintain documentation to include communications between the lessor and the lessee related to protecting such interest, in accordance with the standard award terms and conditions. 17
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Leasehold Improvements While leasehold improvements are allowed under the SBHCC funding opportunity, please note: –HRSA will determine if the term of the lease is long enough for the full value of the grant-supported improvements to benefit the grant activity. HRSA will take into account the purpose and duration of the grant, the expected life of the facility, and the use of the facility for grant-supported purposes. –Funds may not be used to pay lease costs. 18
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Environmental and Historic Preservation Requirements An Environmental Assessment (EA) in conformance with the requirements of the National Environmental Policy Act (NEPA) is a concise public document that provides sufficient evidence and analysis for determining whether HRSA should issue a Finding of No Significant Environmental Impact (FONSI) for proposed SBHCC projects The National Historic Preservation Act (NHPA) is intended to protect and preserve historical and archeological sites within the US; HRSA grant funding that is used for construction and alteration/renovation projects is subject to the requirements under Section 106 of the NHPA While some applicants submitted a draft EA and Section 106 consultation letter from the State Historic Preservation Officer, additional information may still be required; please carefully review your NGA Technical assistance on these two topics is available at http://bphc.hrsa.gov/policiesregulations/capital/ http://bphc.hrsa.gov/policiesregulations/capital/ 19
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Procurement Rules Grantees are reminded to comply with procurement regulations that apply to Federal grantees –Technical assistance on this topic is available at http://bphc.hrsa.gov/policiesregulations/capital/ http://bphc.hrsa.gov/policiesregulations/capital/ ALL goods and services equal or greater than $100,000 must be competitively bid The simplified acquisition threshold applies to work < $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 20
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Use of SBHCC Space Grantees must use SBHCC funding to renovate/construct the space that will be utilized directly by the school-based health center site to support operations consistent with the SBHCC Program SBHCC funds may not be used to support space which will be utilized and/or rented by other entities Utilizing Federally supported space for profit (e.g., charging rent for space renovated or constructed) is an unallowable use of Federal funds. Use of the space for mortgage/financing, or change in use of space (leasing, sale, etc.) must have prior approval from HRSA 21
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Other Policy Requirements SBHCC projects must be compliant with the following: –Uniform Relocation Assistance, 45 CFR Part 15 –ADA Accessibility Guidelines for Building and Facilities (28 CFR Part 36) –NFPA 101 Life Safety Code (2000 edition) (as applicable) –AIA Guidelines for Design and Construction of Hospital and Health Care Facilities (2009 edition) (as applicable) –Real Property insurance, maintenance, disposition, and Federal Interest, 45 CFR Part 74.31-.37, and 92.31 and DHHS Grants Policy Statement 22
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SBHCC Reporting Project status updates (starting April 1, 2013) –Project completion status (percent complete) –Actual versus projected budget information – uses of SBHCC grant funds –Project Implementation Certification –Bonding/Insurance Coverage Certification (as applicable) –Construction Schedule Federal Financial Report (FFR) – annual submission 23
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SBHCC Monitoring—Required The following documentation must be submitted during the course of the project –Project Implementation Certification (120 days from award issue date) –Final Design Certification (180 days from award issue date) –Bonding Coverage Certification (180 days from award issue date) –Construction Contract Information (180 days from award issue date) a copy of the selected contract, certified by the hired architect the formal recommendation of award a statement of determination that the selected contractor is not on the US General Services Administration Lists of Parties Excluded from Federal Procurement or Non-Procurement Programs (debarred list) if the contract is awarded to any qualified bidder other than the lowest bidder, provide proper documentation for your decision a copy of the award letter(s) Templates can be found at http://bphc.hrsa.gov/policiesregulations/capital/http://bphc.hrsa.gov/policiesregulations/capital/ 24
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SBHCC Monitoring (as necessary) Additional documentation may be requested to verify the status of the project: –Milestone chart/construction schedule –Field observation reports –Application and certificate for payment (AIA G702) –Specific documentation (such as permits and invoices) as necessary 25
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SBHCC Closeout Report Closeout documentation is required within 30 days of the completion of the SBHCC project The closeout documentation consists of the following items: –Photos of the completed project –Final budget Information –Project Completion Certification A certificate of occupancy A certificate of substantial completion Property insurance Tangible Personal Property Report (SF-428) 26
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EHB Help Resources HRSA Electronic Handbooks: https://grants.hrsa.gov/webexternal/home.asphttps://grants.hrsa.gov/webexternal/home.asp Call the HRSA Call Center at 877-Go4-HRSA/877-464-4772; 301-998-7373 (9:00 AM to 5:30 PM ET M-F) Email: callcenter@hrsa.govcallcenter@hrsa.gov For assistance accessing EHB or with user names and passwords Do not use this for program questions Call the BPHC Help Line at 1-877-974-BPHC (8:30 AM to 5:30 PM ET M-F) Email: bphchelpline@hrsa.govbphchelpline@hrsa.gov For program specific help and system issues 27
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CD Post-Award Technical Assistance TA call presentation materials and transcripts will be available at http://www.hrsa.gov/grants/apply/assistance/sbhcc/ http://www.hrsa.gov/grants/apply/assistance/sbhcc/ Technical assistance materials will be posted at http://bphc.hrsa.gov/policiesregulations/capital/ http://bphc.hrsa.gov/policiesregulations/capital/ Submission templates –Frequently asked questions –National Environmental Policy Act / Environmental Assessments –National Historic Preservation Act Section 106 –Procurement –Federal Interest 28
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