Capital Improvement Program

Post-Award Technical Assistance Call

July 7, 2009

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Objectives

Describe the outcome of the Capital Improvement Program (CIP) application submissions

Review the terms and conditions of the CIP Notice of Grant Awards (NGA)

Explain the review process for CIP applications

July 2009 3

CIP Awards

On June 29, HRSA awarded $851.5 million in CIP awards

The eligible project types were:

– Alteration/repair/renovation

– Construction (new site or expansion of existing site)

– IT/equipment-only purchase (single site or multi-site)

– HIT-only purchase (non-EHR equipment)

– Certified EHR-related purchase

July 2009 4

CIP Stats

1,123 health centers applied for funding to support 2,614 projects, including:

– 411 new or expanded health center sites (construction projects)

– 1,153 improved/upgraded health center sites (alteration/repair/renovation projects)

– 490 health centers with new equipment

– 176 health centers with new HIT projects

– 384 health centers with new/enhanced certified EHRs

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CONGRATULATIONS!!!

You have the Notice of Grant Award.

So…now what?!

July 2009 6

Understanding the NGA

NGAs were issued on 06/25/09 Project/budget period for the CIP is from

06/29/09 through 06/28/11 CIP activity code = C81 Recipients need to keep in mind—There

is no ongoing support of CIP grant activities after the end of the 2-year project/budget period

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What it means?

Grant conditions Grant specific terms Program terms Standard terms

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Grant Conditions

Notice of Federal Interest SHPO/THPO Consultation Environmental Information and Documentation

(EID) Checklist Environmental Assessment Letter of Consent/Statement of Agreement from

the Facility Owner EHR Readiness Checklist

July 2009 9

Grant Specific Terms

Pre-award costs Budget-specific/Project-specific issues

– Incorrect categorization– Questionable costs

Draw down restrictions Subordination of Federal Interest Insurance coverage and policies HIT technical assistance

July 2009 10

Program Terms

Timeline for obligation of CIP funds Staff points of contact Change in Scope (CIS) add new site

requests

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Standard Terms

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

July 2009 12

NGA Contacts

Division of Grants Management Operations (DGMO) Contact

One Bureau of Primary Health Care (BPHC) staff person will serve as the focal point for all CIP activity

Grantee-specific CIP Program Contacts will be finalized soon

July 2009 13

CIP Application Reviews

Completeness Eligibility Allowable Costs Service Area Overlap Architectural/Engineering Reasonableness Federal Interest EHR Readiness Environmental Review Historic/Cultural Preservation

Equipment Only Projects: Conditions [IT/Equipment, HIT, and EHR]

IT/Equipment and HIT

– EID EHR Projects

– EID

– Readiness

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Equipment Only Projects: Terms[IT/Equipment, HIT, and EHR]

Pre-award costs Budget-specific/Project-specific issues

– Incorrect categorization

– Questionable costs Draw down restrictions HIT Technical Assistance

July 2009 16

Alteration/Repair/Renovation: Conditions

Environmental Information and Documentation (EID) Checklist

Environmental Assessment SHPO/THPO Consultation Notice of Federal Interest Letter of Consent/Statement of

Agreement from the Facility Owner

July 2009 17

Alteration/Repair/Renovation: Terms

Pre-award costs Budget-specific/Project-specific issues

– Incorrect categorization– Questionable costs

Draw down restrictions Subordination of Federal Interest Insurance coverage and policies

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Construction: Conditions

Environmental Information and Documentation (EID) Checklist

Environmental Assessment SHPO/THPO Consultation Notice of Federal Interest Letter of Consent/Statement of

Agreement from the Facility Owner

July 2009 19

Construction: Terms Pre-award costs Budget-specific/Project-specific issues

– Incorrect categorization– Questionable costs

Draw down restrictions Subordination of Federal Interest Insurance coverage and policies

Condition: Environmental Information and Documentation

Checklist (EID) Each project must have its own EID For IT/Equipment-only projects, if you (1)

completed the project-specific EID, (2) attached this EID in the proper place in the CIP application, and (3) answered “No” to all questions, then you may proceed with your project (absent other conditions)

For all other project types, HRSA will lift the condition based on review of the EID

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July 2009 21

Condition: Environmental Assessment

What projects require an EA?– All construction projects

– Some alteration/renovation projects—upon review of the EID and application information, HRSA will communicate to the grantee if an EA is required

These projects must undergo a National Environmental Policy Act (NEPA) Environmental Assessment (EA).  A Phase 1 Environmental Site Assessment (ESA) is NOT the same as a NEPA EA.– A Phase 1 ESA addresses only a small part of what is

required for an overall NEPA EA and will not fully meet the requirements of a NEPA EA.

More information is available at http://bphc.hrsa.gov/recovery/faqdraftassessment.htm

Condition: SHPO/THPO Consultation

Part of the Cultural Resource Assessment and Historical Preservation Review

If a grantee proposed a construction project, it is authorized to contact their State Historic Preservation Office (SHPO) and/or Tribal Historic Preservation Office (THPO) to obtain either:– A letter indicating a finding of no adverse impact, or– A draft MOA between the SHPO/THPO, grantee and

HRSA detailing a plan to reduce the adverse effects. Upon approval by HRSA, it will be signed by all parties.

HRSA is reviewing alteration/repair/renovation projects to determine whether a SHPO/THPO consultation is necessary; if the consultation is necessary, HRSA will communicate this to the grantee.

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Condition: Notice of Federal Interest

For ALL construction projects AND for alteration/ repair/renovation projects with a net project cost (excluding equipment) greater than $500,000, the grantee must:– File a Notice of Federal Interest (NFI) with the

appropriate jurisdictional records, and– Submit a notarized and recorded copy of the NFI

to the Grants Management Specialist NFI must be filed prior to starting the

construction or alteration/ repair/renovation project

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Condition: Letter of Consent For a leasehold improvement project that is:

– A construction project, or– An alteration/repair/renovation project with a net cost, excluding

equipment, of greater than $500,000 The grantee must provide HRSA with a signed Letter of

Consent/Statement of Agreement from the facility owner demonstrating that the owner:– Approves of the scope of the CIP project– Agrees to provide the grantee health center reasonable control of

the project site for at least 10 years– Agrees to file an NFI in the land records of the local jurisdiction when

the project begins If a grantee provided the Letter of Consent/Statement of Agreement

within CIP its application, HRSA will still review for completeness A template of the Letter of Consent/Statement of Agreement is

available at http://bphc.hrsa.gov July 2009 24

Term: Questionable Costs

A Grants Management Specialist will contact you to discuss any questionable costs

Once questionable cost issues are discussed, clarified, and resolved, the condition will be lifted

July 2009 25

Term: Incorrect Categorization A Project Officer will contact the grantee to

discuss project types that appear to be incorrectly categorized (IT/equipment-only but should be EHR-related, alteration/repair/renovation but should be construction, etc.)

Once the correct project type is established, the grantee may need to submit additional required information, per the CIP guidance

New terms and conditions may apply Projects may not begin until incorrect

categorization issues have been resolved

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July 2009 27

Program Term: Change in Scope to Add New Sites

HRSA is currently processing all new site requests, including new sites proposed through– CIP application– Normal CIS requests linked to a CIP project

HRSA will notify grantees if site is approved within 60 days

Verification within 60 days of the project completion

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Special Topic—Procurement Rules

All goods and services > $100,000 needs to be competitively bid

Simplified acquisition threshold applies to good and services < $100,000– Recipients should keep in mind that they still

need to get more than one quote (not bids) for the work to determine that the costs are reasonable, and the threshold shall not be broken down into several purchases or artificially reduced to smaller quantities to permit negotiations under simplified acquisition procedures

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Next Steps and Timelines

Responding to terms/conditions Releasing terms/conditions Draw down of funds

Recipients can proceed with preliminary CIP work but will need to wait to break

ground until the applications have been cleared through the various reviews

July 2009 30

Responding to Terms and Conditions

Deliverable Submit Within

Resolving budget issues 30 days or July 27 (July 25 is a Saturday)

EID 30 days or July 27 (July 25 is a Saturday)

EA 60 days or August 24

Notarized and recorded copy of the NFI 30 days or July 27 (July 25 is a Saturday)

SHPO finding of no adverse impact 60 days or August 24

Letter of Consent/Statement of Agreement from Facility Owner

30 days or July 27 (July 25 is a Saturday)

Documentation of insurance policies 5 days of project completion

• All deliverables will be submitted via the Electronic Handbook (EHB) system into the official CIP grant file—HRSA will provide instructions on the submission process shortly

Releasing Terms and Conditions

Terms and conditions will be released on a project-by-project basis

– Once all conditions for a specific project are met, a revised NGA will be issued that will authorize the grantee to begin that project

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Draw Down of Funds

IT/Equipment, HIT, and EHR-related projects

– Grantee may begin drawing down funds unless questionable costs or other conditions exist

Alteration/repair/renovation and construction projects

– Grantee may draw down funds for planning costs (e.g., environmental assessment, A&E permitting, SHPO/THPO consult)

– Grantee may not draw down funds to pay for other costs until HRSA gives final approval to break ground/begin project

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Timelines For IT/Equipment-only, HIT, and EHR-related

projects:– HRSA anticipates resolving conditions and issues

within 3 weeks For alteration/repair/renovation and

construction projects: – HRSA anticipates resolving all conditions and

other issues in 8 to 12 weeks– If application is missing key information, grantee

has not submitted required documentation, and/or additional issues are identified during reviews, process could be significantly longer

July 2009 33

Tracking and Reporting

CIP funds must be maintained and tracked separately from any other Federal, State, or local funds, including other Health Center Program or Recovery Act grants

Grantees will report on CIP funds beginning October 10, for both Health Center Program and Recovery Act measures

July 2009 34

Change in Scope of CIP Project

HRSA realizes that grantees may wish to change their original CIP proposal based on emerging information about the immediate needs of the communities they serve and/or on unforeseen circumstances.

HRSA will work with grantees to make and document minor programmatic or budgetary changes within their application that do not significantly affect the outcome of the project

July 2009 35

Change in Scope of CIP Project (cont.)

For changes that may significantly impact the originally proposed outcome:Any proposed changes must result in a project that remains consistent with the intent of the CIP.Grantees may not request a CIP award amount above the originally requested amount.The grantee must submit the change request in writing to HRSA. Based on an evaluation of the information provided by the grantee in its request, HRSA will review and determine whether the request for a change in CIP scope of project will be approved. July 2009 36

Resources and Contact Information

Please refer to the technical assistance materials available online at http://bphc.hrsa.gov/recovery

Send questions to bphcrecovery@hrsa.gov

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