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Health Center Capital Development. Post-Award Technical Assistance Call October 21, 2010. Objectives. Describe the Capital Development (CD) awards Discuss critical compliance requirements Review the terms and conditions of the CD Notice of Grant Awards (NGA)

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Health Center Capital Development


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health center capital development

Health Center Capital Development

Post-Award Technical Assistance Call

October 21, 2010

objectives
Objectives
  • Describe the Capital Development (CD) awards
  • Discuss critical compliance requirements
  • Review the terms and conditions of the CD Notice of Grant Awards (NGA)
  • Explain the process for CD post-award submission and review
cd overview
CD Overview
  • On October 8, HRSA awarded $727 million in CD awards to 143 health center grantees
  • The funded applications includes 189 projects:
    • 142 new/expanded health center sites (construction projects)
    • 47 improved/upgraded health center sites (alteration/renovation projects)
types of cd projects
Types of CD Projects

Health centers proposed the following types of CD 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 does not increase square footage of the existing structure.

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).

October 2010

4

general requirements
General Requirements
  • New grant number: C8A
  • Separate PMS sub-account: ACA-FIP-V
  • Funds must be accounted for and reported separately (from section 330 funds and from ARRA funds)
    • Applicants must not co-mingle or pool other Federal, State, or local funds
    • If other sources of funding exists, CD funds should be drawn down proportionately to approved total costs
  • Quarterly reports – starting January 1, 2011
review of cd applications
Review of CD Applications
  • CD proposals were subject to internal and technical reviews (as applicable):
    • Completeness
    • Eligibility
    • Service Area Overlap
    • Architectural & Engineering Reasonableness
    • Allowable/Unallowable Costs Analysis
    • Environmental Review and Compliance
    • Historic Preservation & Cultural Resources
ineligible cd costs
Ineligible CD Costs
  • Costs incurred prior to March 23, 2010
  • Any costs related to a Capital Improvement Program (CIP) project awarded under HRSA-09-224
    • CD awards must not be used to replace any funds that have been awarded for a CIP project
    • As a reminder, the proposed CD project must be separate and distinct projects from activities funded under the CIP grant.
  • Operating costs (e.g., funding direct services, clinical full-time equivalents, rent, mortgage payments, refinanced credit facilities)
  • Land or facility purchase costs are not allowable uses of CD grant funding. Eligible projects may contain land/facility purchase costs as part of the total budget; however, individual project budgets must show sufficient resources other than CD funding to cover those expenses.
equipment purchases
Equipment Purchases
  • Equipmentmay only be purchased in conjunction with an approved CD alteration/renovation or construction project
  • 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
federal interest
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 Interest
        • Disposition of Federal Interest will be addressed on a case by case basis in accordance with 45 CFR 74.32 or 92.31.
leasehold improvements
Leasehold Improvements

Lease Agreement Or Deed is needed:

For all Construction and A/R/R over $500K (total project cost less equipment)

Applicant must: 

Provide a Statement of Agreement from the facility owner.

October 2010

10

leasehold improvements11
Leasehold Improvements

What to include: 

Approval of the scope of the CD project.

Agreement to provide the applicant with reasonable control of the project site.

Agreement to file an NFI in the land records of the local jurisdiction before the project begins.

October 2010

11

leasehold improvements12
Leasehold Improvements

Please note—for projects that are A/R/R and $500K or less: 

The applicant must certify that the existing lease gives the applicant reasonable control of the project site;

Is consistent with the scope of the CD project; and

Is in compliance with all terms and conditions affecting the Federal interest.

Definition of “reasonable control” for the purpose of the CD grant

Is considered the ability to implement the project and realize the benefits of the project without unnecessary demands to the grantee organization.

October 2010

12

environmental and historic preservation requirements
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 CD 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/capital
procurement rules
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/capital
  • ALL goods and services equal orgreater 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
use of cd space
Use of CD Space
  • Grantees must use CD 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
  • CD 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
other policy requirements
Other Policy Requirements
  • CD 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 (2006 edition) (as applicable)
    • AIA Guidelines for Design and Construction of Hospital and Health Care Facilities (2006 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
starting projects
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 preparatory work such as:
    • Site plans, architectural and engineering schematics, environmental and historic preservation requirements, etc.
understanding the nga
Understanding the NGA
  • Project/budget period for the CD = 10/01/10 through 9/30/12
  • CD activity code = C8A
  • Recipients need to keep in mind—There is no ongoing support of CD grant activities after the end of the 2-year project/budget period
  • Contact the assigned C8A Project Officer
    • For additional details and clarification on resolving conditions
    • To request additional time to submit post-award submissions
resolving conditions on cd awards
Resolving Conditions on CD Awards
  • Grant Conditions & Program Conditions
  • Submissions can be uploaded to each corresponding condition within the Electronic Handbook (EHB)
  • Revised NGAs will not be issued until all applicable conditions have been met for each CD project
condition deliverables and due dates22
Condition Deliverables and Due Dates

If an extension to a submission deadline is needed:

Please discuss with your assigned C8A 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 construction timeline

October 2010

22

nga terms
NGA Terms
  • Grant-specific terms
  • Program terms
  • Standard terms
  • Reporting requirements
proposed new sites
Proposed New Sites
  • HRSA has processed the new site requests proposed through CD applications
    • Approved site address is listed in the NGA
    • Please review your NGA to find out if additional site information is needed and verify that information indicated is correct
  • Grantees are reminded that they are required to verify that the new site is operational within 60 days of the project completion (verification is done within the site verification module in the H80 Grant folder in EHB)”
term special consideration
Term: Special Consideration
  • HRSA may take action to withdraw the approval and funds for the approved CD 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 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 CD project is not separate and distinct from a CIP project; grantee does not resolve concerns to the satisfaction of HRSA)
next steps and timelines
Next Steps and Timelines
  • Responding to terms/conditions
  • Releasing terms/conditions
  • Draw down of funds

Recipients can proceed with preliminary CD 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)

roles c8a project officer
Roles—C8A Project Officer
  • Monitor conditions
  • Review of revised budgets, schematics, concept /site plans, and construction timelines
  • Assist with pre-implementation
  • Ongoing monitoring and technical assistance
  • Closeout
roles c8a grants management specialist
Roles—C8A 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
cd reporting
CD Reporting
  • Project status updates (starting January 1, 2011)
    • Earned value management
      • Actual versus projected project budget information
      • Actual versus projected project schedule
    • Overview of current status for project(s)
    • Photos of project progress
  • Federal Financial Report (FFR) – annual submission
cd monitoring required
CD Monitoring—Required
  • The following documentation must be submitted during the course of the project
    • Project Implementation Certification (90 days from award issue date)
    • Final Design Certification (120 days from award issue date)
    • Bonding Coverage Certification (120 days from award issue date)
    • Construction Contract Information (120 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/capital
cd monitoring as necessary
CD 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
cd closeout report
CD Closeout Report
  • Closeout documentation is required within 30 days of the completion of the CD 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
c8a grant handbook
C8A Grant Handbook
  • A new grant handbook for the C8A/CD grant has been created in the grantee’s portfolio in EHB
  • The project director needs to ensure he/she has added the CD grant to the portfolio and that the correct grantee staff are assigned to roles and functions in the C8A 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
electronic document submissions in ehb
Electronic Document Submissions in EHB
  • For CD, 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
cd post award technical assistance
CD Post-Award Technical Assistance
  • Technical assistance materials will be posted at http://bphc.hrsa.gov/capital
    • TA call presentation materials and transcripts
    • Submission templates
    • Frequently asked questions
    • National Environmental Policy Act / Environmental Assessments
    • National Historic Preservation Act Section 106
    • Procurement
    • Federal Interest