School-Based Health Center CapitalHRSA-13-140

Post-Award Technical Assistance Call

January 10, 2013

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

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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

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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

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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

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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.

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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?hF=grants_management 7

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

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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

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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.

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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

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

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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

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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

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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

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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.

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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.

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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.

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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/

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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/ 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

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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

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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

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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

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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/

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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

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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

EHB Help Resources

HRSA Electronic Handbooks: https://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.govFor assistance accessing EHB or with user names and passwordsDo 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.gov

For program specific help and system issues

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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/

Technical assistance materials will be posted at 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

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