facility investment program hrsa-10-029 post-award technical assistance call december 16, 2009

December 2009 1

Facility Investment ProgramHRSA-10-029

Post-Award Technical Assistance Call

December 16, 2009

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Objectives

Describe the outcome of the Facility Investment Program (FIP) applications

Discuss critical compliance requirements Review the terms and conditions of the FIP

Notice of Grant Awards (NGA) Explain the process for FIP post-award

submission and review


FIP Stats

On December 9, HRSA awarded $508.5 million in FIP awards to 85 health center grantees

The funded applications includes 108 projects are proposed at– 80 or new/expanded health center sites (construction projects)– 28 improved/upgraded health center sites

(alteration/renovation projects) The breakdown of the number of projects per funded

application– 1 project = 65– 2 projects = 17– 3 projects = 3


ARRA General Requirements

New grant number: C80 Separate PMS sub-account: ARRAFIP-C80-10 Funds must be accounted for and reported

separately (from section 330 funds and from other ARRA funds)– Applicants must not co-mingle or pool Federal, State,

or local funds– If other sources of funding exists, FIP funds should be

drawn down proportionately to approved total costs Quarterly reports


Review of FIP Applications

The Division of Independent Review managed the objective reviews by an Objective Review Committee (ORC)

FIP proposals were subject to internal and technical reviews (as applicable):– Completeness– Eligibility– Service Area Overlap– Architectural & Engineering Reasonableness– Federal Interest– Environmental Review– Historic & Cultural Preservation


Types of FIP Projects

Health centers proposed up to three of the following types of FIP projects

– Alteration/renovation: includes work required to modernize, improve, and/or change the interior arrangements or other physical characteristics of an existing facility or install equipment. This type of project should not increase square footage.

– Construction (new site or expansion of existing site): includes—(i) adding a new structure to an existing site that increases the total square footage of the facility; and (ii) permanently affixing structure (e.g., modular units, prefabricated buildings) to real property (i.e., land).


Ineligible FIP Costs

Costs incurred prior to February 17, 2009

Any costs related to a Capital Improvement Program (CIP) project awarded under HRSA-09-224. FIP awards must not be used to replace any funds that have been awarded for a CIP project. As a reminder, the proposed FIP project must be separate and distinct projects from what was funded under the CIP initiative

Operating costs (e.g., funding direct services, clinical full-time equivalents, rent, mortgage payments, refinanced credit facilities)

Land or facility purchase costs are not eligible uses of FIP grant funding. Eligible projects may contain land/facility purchase costs; however, individual project budgets must show sufficient resources other than FIP funding to cover those expenses.

Per section 1604 of the Recovery Act: None of the funds appropriated or otherwise made available under the Recovery Act may be used by any State or local government, or any private entity, for any casino or other gambling establishment, aquarium, zoo, golf course, or swimming pool

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Equipment Purchases

Equipment should only be purchased in conjunction with an approved FIP alteration/renovation or construction project

Equipment must be used at the approved project site

Grantees should have provided a detailed equipment list to identify the equipment to be purchased with the FIP project; final equipment list is required

Equipment must be maintained, tracked, and disposed of in accordance with 45 CFR Parts 74.34 and 92.32

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Federal Interest

The Federal government always retains interest in property constructed, acquired, or improved with Federal funds– For ALL construction 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 InterestDecember 2009 9


Leasehold Improvements

If the project site is leased and it is:– A construction project, or– An alteration/renovation project with a net project cost (total project cost

less moveable equipment costs) greater than $500,000; The grantee must provide a signed Statement of Agreement from the facility

owner (either with the application or in response to NGA condition) that addresses the following components:

– Approval of the scope of the FIP project.– Agreement to provide the applicant health center reasonable control of the

project site for at least 10 years.– Agreement to file an NFI in the land records of the local jurisdiction before

the project begins. For all leased property, the requested FIP project amount can not exceed 25

percent of the fair market value (FMV) of the property or 50 percent of the remaining lease, unless the remaining lease is for 30 years or longer. – Additional property value/lease documentation may be requested as a

condition on the NGA.

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Environmental and Historic Preservation Requirements

An Environmental Assessment (EA) under 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 FIP 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 Section 106 review

While some applicants submitted draft EAs 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/recovery/fip/

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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/recovery/fip/

ALL goods and services greater than $100,000 must be competitively bid

Remember to include ARRA specific terms on contract bid and award documents.

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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Wage Determination

All health centers receiving funding through ARRA are required to comply with the Davis-Bacon Act

Davis-Bacon and Related Acts (DBRA) requires all contractors and subcontractors performing on federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) to pay their laborers and mechanics not less than the prevailing wage rates and fringe benefits for corresponding classes of laborers and mechanics employed on similar projects in the area

Prevailing wage rates and fringe benefits are determined by the Secretary of Labor for inclusion in covered contracts

Technical assistance on this topic is available at http://bphc.hrsa.gov/recovery/fip/

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Use of FIP Space

Grantees must use FIP funding to renovate/construct the space that will be utilized directly by the health center to support health center operations consistent with the 330 program*

FIP funds may not be used to support space which will be utilized and/or rented by other entities*

Utilizing Federal funds to augment appropriations (e.g., charging rent for space constructed with Recovery Act funds) is an ineligible 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

*If other sources of funding are contributing to the project, then the proportion of the space supported with non-FIP funds may be rented to other entities or support non-330 activities (e.g., if 30% of the total project is supported by non-FIP funds, then 30% of the space may be rented out)

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Other Policy Requirements

FIP projects must:

– Be compliant with Americans with Disabilities Act (ADA) and other accessibility requirements

– Be compliant with all applicable Federal, State, and local codes and ordinances for the type of facility proposed AND

– Have the necessary permits in place before the renovation/construction is undertaken

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Starting Projects

Grantees must carefully review all terms and conditions of the NGA

Grantees must respond to conditions and HRSA must issue a revised NGA 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 preparation/preliminary work – Site plans, architectural and engineering

schematics, environmental and historic preservation requirements, etc.

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Understanding the NGA

Project/budget period for the FIP = 12/09/09 through 12/08/11

FIP activity code = C80 Recipients need to keep in mind—There is no

ongoing support of FIP grant activities after the end of the 2-year project/budget period

Contact the assigned Project Officer – For additional details and clarification on resolving

conditions– To request additional time to submit post-award

deliverables


Resolving Conditions on FIP Awards

HRSA has posted a document available online at http://bphc.hrsa.gov/recovery/fip/ to assist grantees with resolving conditions on FIP awards

The submissions functionality with the Electronic Handbook (EHB) is active—individual deliverables can be uploaded to each corresponding condition

Revised NGAs will not be issued until all applicable conditions have been met for each FIP project

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Condition Deliverables and Due Dates

Deliverable Due Date

Schematic drawings January 8, 2010

Revised budget January 8, 2010

Revised equipment list January 8, 2010

Capitalization statement January 8, 2010

Site / concept plan January 8, 2010

EID checklist January 8, 2010

NFI Before FIP work begins

Lessor statement of agreement January 8, 2010

Lease / property documentation January 8, 2010

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Condition Deliverables and Due Dates

Environmental Assessment ConditionsDeliverable Due Date

Consult with Project Officer regarding submitted environmental assessment January 8, 2010

Environmental assessment required March 9, 2010

Historic Preservation ConditionsDeliverable Due Date

Consult with Project Officer to determine if SHPO / THPO is required January 8, 2010

SHPO / THPO consultation February 7, 2010

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NGA Terms

Grant-specific terms Program terms (including Recovery Act terms) Standard terms Reporting Requirements


Proposed New Sites

HRSA has processed most of the new site requests proposed through FIP applications

– Approved site address is listed in the NGA

– Please review your NGA to find out if additional site information is needed

Grantees are reminded that they are required to verify the new site is operational within 60 days of the project completion

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HRSA may take action to withdraw the approval and funds for the approved FIP project(s)– the identification of previously undocumented environmental or

historic preservation issues that lead the HRSA to conclude a construction project cannot be carried out;

– the conclusion that the project cannot be completed as proposed (e.g., information submitted through the required ARRA reporting indicates that the grantee's progress is sufficiently noncompliant with the approved scope, costs or timeline presented in the application and that completion as proposed will not be possible); or

– the conclusion that the grantee is noncompliant with a requirement of the application guidance (e.g., the FIP project is not separate and distinct from a CIP project; grantee does not resolve concerns to the satisfaction of HRSA)

Term: Special Consideration


Next Steps and Timelines

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

Recipients can proceed with preliminary FIP work but must wait to break ground until the project

has been cleared by HRSA (preliminary work includes site plans, architectural and

engineering schematics, environmental and historic preservation requirements)

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Roles—C80 Project Officer

Monitor conditions Review of revised schematics and concept / site

plans Assist with pre-implementation Ongoing monitoring and technical assistance Closeout

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Roles—C80 Grants Management Specialist

Review revised budgets, capitalization threshold, Federal Interest, lease documentation

Process prior approval requests Approve Project Director changes Ongoing monitoring and technical assistance Closeout


FIP Reporting

Health Center Quarterly Report (HCQR) and Section 1512 report for FIP is due January 10– TA resources are available at http://bphc.hrsa.gov/recovery/hcqr/

Impact of FIP funding– Number of new/improved sites– Projected number of health center jobs created and retained– Projected number of construction-related jobs created – Project completion status (percent complete)– Actual versus projected budget information—uses of FIP grant

funds– Earned value management (for grants over $1 million)

Financial Status Report (FSR)

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FIP Monitoring—Required

The following documentation must be submitted during the course of the project– Pre-certification letter (30 days from date A/E services are secured)– Certification of final design letter (30 days from date design documents are

completed)– Bonding and insurance coverage certification (30 days from scheduled

contract award date)– Contract information (30 days from contract award 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

U.S. 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)

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FIP Monitoring (as necessary)

Additional documentation may be requested to verify the status of the project:

– Photos of current status

– 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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FIP Closeout Report

A closeout report is required within 90 days of the completion of the FIP project

The closeout report must include the following items:– Photos of the completed project, including “before”

photos – A final budget– A final equipment list– A certificate of occupancy– A certificate of substantial completion– Property insurance– Earned value management (for grants over $1 million)

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C80 Grant Handbook

A new grant handbook for the C80/FIP grant has been created in the grantee’s portfolio in EHB

The project director needs to ensure he/she has added the FIP grant to the portfolio and that the correct grantee staff are assigned to roles and functions in the C80 Grant Handbook

The following EHB Help Resource can guide you through these processes:– https://grants.hrsa.gov/webexternal/help/

hlpPage.asp?hF=grants_management#HowToAdd

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Electronic Document Submissions in EHB

For FIP, grantees should submit all documents required as a condition of award on the NGA directly to EHB

HRSA Program or Grants Office Personnel may also request other information through the EHBs

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

A presentation on EHB 2.0, including specific details on electronic submissions, is available at http://bphc.hrsa.gov/recovery/fip

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Grantee EHB Roles and Responsibilities

The Project Director (PD), whose name appears on the Notice of Grant Award (NGA), is responsible for managing access to non-financial reports for a grant

Other roles and privileges: https://grants.hrsa.gov/webexternal/help/hlpPage.asp?hF=grant_handbook_administer#


EHB Help Resources

Resource Type Purpose

https://grants.hrsa.gov/webexternal/home.asp Website HRSA Electronic Handbooks URL

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: [email protected]

Phone and/orEmail

For assistance accessing EHB or with user names and passwords

Do not use this for program questions

Call the BPHC Help Desk at

1-301-443-7356(8:30 AM to 5:30 PM ET M-F)

Email: [email protected]

Phone and/orEmail

For program specific help and system issues

Program help by phone or email


FIP Post-Award Technical Assistance

Technical assistance materials will be posted at http://bphc.hrsa.gov/recovery/fip/ – TA call presentation materials and transcripts– Frequently asked questions– Sample budget justification– Draft Environmental Assessment guidance– Section 106 delegation and consultation– Procurement– Wage determination requirements– Federal Interest

facility investment program hrsa-10-029 post-award technical assistance call december 16, 2009

Documents

fip funds

fip funding

fip awards

review of fip applications

fip stats

proposed fip project

ineligible fip costs

review slide