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									Capital Improvement Program


    Post-Award Technical Assistance Call
                             July 7, 2009
                    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                                              2
                         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                                                         3
                           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
July 2009                                                        4
                CONGRATULATIONS!!!
            You have the Notice of Grant Award.
                     So…now what?!




July 2009                                         5
            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

July 2009                                                6
                 What it means?

    Grant conditions
    Grant specific terms
    Program terms
    Standard terms




July 2009                         7
                   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                                                8
                  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                                      9
                   Program Terms

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




July 2009                                          10
                  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                                  11
                   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                                                 12
            CIP Application Reviews
    Completeness
    Eligibility
    Allowable Costs
    Service Area Overlap
    Architectural/Engineering Reasonableness
    Federal Interest
    EHR Readiness
    Environmental Review
    Historic/Cultural Preservation
July 2009                                       13
            Equipment Only Projects: Conditions
                [IT/Equipment, HIT, and EHR]
    IT/Equipment and HIT
       – EID
    EHR Projects
       – EID
       – Readiness



July 2009                                         14
            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                                      15
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                                          16
   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
July 2009                                             17
            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                                          18
                    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

July 2009                                             19
  Condition: Environmental Information and
      Documentation Checklist (EID)
 Each project must have its own EID
 For IT/Equipment-only projects, if you (1)
  completed the project-specific EID, (2) attached
  this EID in the proper place in the CIP
  application, and (3) answered “No” to all
  questions, then you may proceed with your
  project (absent other conditions)
 For all other project types, HRSA will lift the
  condition based on review of the EID
July 2009                                        20
 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
July 2009                                                                  21
    Condition: SHPO/THPO Consultation
    Part of the Cultural Resource Assessment and Historical
     Preservation Review
    If a grantee proposed a construction project, it is authorized to
     contact their State Historic Preservation Office (SHPO) and/or
     Tribal Historic Preservation Office (THPO) to obtain either:
       – A letter indicating a finding of no adverse impact, or
       – A draft MOA between the SHPO/THPO, grantee and HRSA
          detailing a plan to reduce the adverse effects. Upon approval
          by HRSA, it will be signed by all parties.
    HRSA is reviewing alteration/repair/renovation projects to
     determine whether a SHPO/THPO consultation is necessary;
     if the consultation is necessary, HRSA will communicate this
     to the grantee.
July 2009                                                             22
    Condition: Notice of Federal Interest

    For ALL construction projects AND for alteration/
     repair/renovation projects with a net project cost
     (excluding equipment) greater than $500,000, the
     grantee must:
       – File a Notice of Federal Interest (NFI) with the
         appropriate jurisdictional records, and
       – Submit a notarized and recorded copy of the NFI to
         the Grants Management Specialist
    NFI must be filed prior to starting the construction
     or alteration/ repair/renovation project
July 2009                                                     23
             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

July 2009                                                   26
  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

July 2009                                              27
            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

July 2009                                                         28
            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                                        29
    Responding to Terms and Conditions
•     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

    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
                                                    30 days or July 27 (July 25 is a Saturday)
    Facility Owner
    Documentation of insurance policies             5 days of project completion

July 2009                                                                                        30
            Releasing Terms and Conditions

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




July 2009                                                  31
                 Draw Down of Funds

    IT/Equipment, HIT, and EHR-related projects
       – Grantee may begin drawing down funds unless
         questionable costs or other conditions exist
    Alteration/repair/renovation and construction projects
       – Grantee may draw down funds for planning costs (e.g.,
         environmental assessment, A&E permitting,
         SHPO/THPO consult)
       – Grantee may not draw down funds to pay for other costs
         until HRSA gives final approval to break ground/begin
         project
July 2009                                                        32
                           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




July 2009                                       37

								
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