In this section:
Primary Reviewer: Fiscal Expert
Secondary Reviewer: Governance/Administrative Expert
NOTE: If the health center has a subrecipient, the Governance/Administrative Expert is the Primary Reviewer of element “i” and the Fiscal Expert is the Secondary Reviewer of that element.
Authority: Section 330(k)(3)(I) and Section 330(q) of the Public Health Service (PHS) Act; 42 CFR 51c.113, 42 CFR 56.114, 42 CFR 51c.303(t), and 42 CFR 56.303(t); 2 CFR 200 Subpart D; and Section 1861(aa)(4)(A)(ii) and Section 1905(l)(2)(B)(ii) of the Social Security Act
Corresponds to Compliance Manual Chapter 12: Contracts and Subawards, including Contracts and Subawards Related Considerations
Documents the Health Center Provides
Contracts: Procurement and Monitoring
- Policies or procedures for purchasing, procurement, and contract management.
- A complete list of health center contracts that support the Health Center Program project, including contracts for health center clinical services or other goods and services (for example, tech support, janitorial, payroll). Specifically, include all active contracts and all contracts that had a period of performance that ended less than 3 years ago. In the list, include all of the following information for each contract:
- Whether the health center uses Health Center Program federal award funds to pay in whole or in part for the contract (not applicable to look-alikes);
- Contractor/contract organization;
- Value of the contract (if there is a federal share, state the federal share amount);
- Brief description of the goods or services provided;
- Period of performance/timeframe (for example, ongoing contractual relationship, specific duration);
- Whether the contract supports a Column II service delivery method; and
- Whether the contract supports substantive programmatic work.1
- Based on the list above of contracts that support the Health Center Program project:
- Five contracts AND related supporting procurement documentation for actions that use Health Center Program federal award funds. Choose the five contracts that use the largest amounts of Health Center Program federal award funds.
Notes:- Use the same sample of contracts/agreements for the review of both Contracts and Subawards and Conflict of Interest.
- The sampling methodologies for Contracts and Subawards are different from Required and Additional Health Services, Clinical Staffing, and Sliding Fee Discount Program, even though they may result in some overlap in the contracts/agreements reviewed.
- Sample of five contracts that do NOT use Health Center Program federal award funds. Choose the five contracts that use the largest amounts of non-Health Center Program funds.
- Note: Each contract/agreement must be current and executed by all parties (for example, a signed paper copy, electronically-signed documents, emails documenting acceptance).
- Five contracts AND related supporting procurement documentation for actions that use Health Center Program federal award funds. Choose the five contracts that use the largest amounts of Health Center Program federal award funds.
- From the contractors included in the sample of selected contracts, a total of two to three reports or records of the contractors’ health center-related activities. For example, monthly invoices or billing reports, data on patients served or visits provided.
- Documentation of HRSA approval for any contracts for the performance of substantive programmatic work (i.e., contracting with a single entity for the majority of health care providers) under the federal award.
Note: The health center determines if, as other lines of business, it enters into contracts where it performs a service on behalf of another organization. None of these activities may be included as part of the health center’s HRSA-approved scope of project or annual budget and the health center does not submit these contracts to HRSA for approval.
Subawards: Monitoring and Management
ONLY APPLICABLE FOR RECIPIENTS WITH AT LEAST ONE SUBRECIPIENT
NOT APPLICABLE TO LOOK-ALIKES
- Most recent annual audit and management letter.
- Policies or procedures for subrecipient monitoring.
- All subrecipient agreements (if updated since the last application submission to HRSA) that support the recipient’s HRSA-approved scope of project.
Note: Per 2 CFR 200.331, “All of the characteristics listed below [refer to 2 CFR 200.331(a) and (b)] may not be present in all cases, and some characteristics from both categories may be present at the same time. No single factor or any combination of factors is necessarily determinative. The pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract. In making this determination, the substance of the relationship is more important than the form of the agreement.” - Documentation of HRSA prior approval of subrecipient arrangements.
NOTE FOR SUBRECIPIENT MONITORING DOCUMENTATION: For a health center with five or fewer subrecipients, provide the following documentation from all subrecipients. For a health center with more than five subrecipients, provide the documentation from the five subrecipients that receive the largest amounts of Health Center Program subaward funds.
- Sample of financial and performance reports from within the current period of performance from the subrecipient, including the subrecipient’s annual audit.
- Documentation of subrecipient monitoring by the health center through audits, on-site reviews, and other means, that occurred during the current period of performance.
- If there have been subrecipient deficiencies identified by the health center through its monitoring process: Documentation ensuring that the subrecipient took corrective action.
- The following documentation used by the health center to confirm subrecipient compliance:
- Subrecipient articles of incorporation, bylaws (either for the subrecipient’s board or the co-applicant board of a public agency subrecipient), or other corporate documents (for example, co-applicant agreement);
- Subrecipient sliding fee discount program (SFDP) policy;
- If the subrecipient board-approved SFDP policy does not state a specific amount for each nominal charge or how each nominal charge is determined: Other documentation (for example, subrecipient board minutes, subrecipient reports) of subrecipient board involvement in setting the amount of each nominal charge;
- Current subrecipient board roster or completed Form 6A indicating current board member characteristics as follows: patient status, area of expertise, and if their percentage of income from the healthcare industry is greater than 10 percent;
- Subrecipient billing records from within the past 24 months to confirm the patient status of subrecipient board members; and
- Subrecipient analysis used to assess whether subrecipient patient board members, as a group, represent the individuals who are served by the health center.
Compliance Assessment
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Is this a Look-Alike Site Visit?
Response is either: Yes or No
Note: Because look-alikes do not receive federal funding under section 330 of the PHS Act, any requirements that relate to the use of Health Center Program federal award funds do not apply to look-alikes.
Contracts: Procurement and Monitoring
Select each element below for the corresponding text of the element, site visit team methodology, and site visit finding questions.
The health center has written procurement procedures that comply with federal procurement standards, including a process for ensuring that all procurement costs directly attributable to the federal award are allowable, consistent with federal cost principles.2
Site Visit Team Methodology
- Review the health center’s policies or procedures for purchasing, procurement, and contract management.
- Interview staff involved in contract procurement and monitoring.
Site Visit Findings
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Does the health center have policies or procedures for procurement?
Response is either: Yes or No
If No, an explanation is required.
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Do these policies or procedures, at a minimum, ensure that all procurements directly attributable to the federal award will:
- Be conducted using full and open competition; and
- Only include allowable costs, consistent with federal cost principles? For example, do the procedures contain relevant references or citations to 2 CFR 200 Subpart E: Cost Principles.
Notes:
- A citation to grants regulations at 2 CFR 200 Subpart E does not demonstrate compliance. To demonstrate compliance with the Health Center Program Compliance Manual Chapter 12: Contracts and Subawards, a health center's procurement procedures would include specific information consistent with the standards set forth in grants regulations at 2 CFR 200 Subpart E, as well as any other federal mandates or related requirements for all procurements related to the federal award.
- Reference to the specific citation of 2 CFR 200 Subpart E is not necessary.
Response is: Yes, No, or Not Applicable
If No, an explanation is required.
NOT APPLICABLE FOR LOOK-ALIKES
The health center has records for procurement actions paid for in whole or in part under the federal award that include the rationale for method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. This would include documentation related to noncompetitive procurements.
Site Visit Team Methodology
- Review the complete list of contracts.
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Review the five contracts that use the largest amounts of Health Center Program federal award funds AND the related supporting procurement documentation.
Notes:
- Use the same sample of contracts/agreements for the review of both Contracts and Subawards and Conflict of Interest.
- The sampling methodologies for Contracts and Subawards are different from Required and Additional Health Services, Clinical Staffing, and Sliding Fee Discount Program, even though they may result in some overlap in the contracts/agreements reviewed.
- Each contract/agreement for services must be current and executed by all parties (for example, a signed paper copy, electronically-signed documents, emails documenting acceptance).
Site Visit Findings
- Does the health center have any:
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4.1 Active contracts paid for in whole or in part with Health Center Program federal award funds?
Response is: Yes, No, or Not Applicable
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4.2 Contracts that had a period of performance which ended less than 3 years ago and that were paid for in whole or in part with Health Center Program federal award funds?
Response is: Yes, No, or Not Applicable
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Is there supporting documentation of the procurement process that addresses the following:
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5.1 Rationale for the procurement method?3
Response is: Yes, No, or Not Applicable
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5.2 Selection of contract type?
Response is: Yes, No, or Not Applicable
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5.3 Contractor selection or rejection?
Response is: Yes, No, or Not Applicable
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5.4 Basis for the contract price?
Response is: Yes, No, or Not Applicable
If No was selected for any of the above, an explanation is required.
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NOT APPLICABLE FOR LOOK-ALIKES
The health center retains final contracts and related procurement records, consistent with federal document maintenance requirements, for procurement actions paid for in whole or in part under the federal award.4
Site Visit Team Methodology
- Review the five contracts AND related supporting procurement documentation for actions that use Health Center Program federal award funds.
Notes:
- Use the same sample of contracts/agreements for the review of both Contracts and Subawards and Conflict of Interest.
- The sampling methodologies for Contracts and Subawards are different from Required and Additional Health Services, Clinical Staffing, and Sliding Fee Discount Program, even though they may result in some overlap in the contracts/agreements reviewed.
- Each contract/agreement for services must be current and executed by all parties (for example, a signed paper copy, electronically-signed documents, emails documenting acceptance).
Site Visit Findings
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Did the health center provide final executed contracts that were awarded within the past 3 years?
Response is: Yes, No, or Not Applicable
If No, an explanation is required.
The health center has access to contractor records and reports related to health center activities in order to ensure that all activities and reporting requirements are being carried out in accordance with the provisions and timelines of the related contract (for example, performance goals are achieved, Uniform Data System (UDS) data are submitted by appropriate deadlines, funds are used for authorized purposes).
Site Visit Team Methodology
- Review the two to three reports or records (for example, monthly invoices or billing reports, data run of patients served, visits provided) from the sample of selected contractors.
Site Visit Findings
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Does the health center have access to records and reports as necessary to oversee contractor performance?
Response is either: Yes or No
If No, an explanation is required.
If the health center has arrangements with a contractor to perform substantive programmatic work,5 the health center requested and received prior approval from HRSA as documented by:
- An approved competing continuation/renewal of designation application or other competitive application, which included such an arrangement; or
- An approved post-award request for such arrangements submitted within the period of performance (for example, change in scope).
Site Visit Team Methodology
- Review the complete list of contracts, including those that support substantive programmatic work.
- Interview key management or other staff involved in procurement or contract oversight.
- Review the health center’s documentation of HRSA’s approval of each contracting arrangement for substantive programmatic work.
Site Visit Findings
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Based on the list of contracts reviewed and interviews with staff, does this health center currently contract for substantive programmatic work because it contracts with a single entity for the majority of health care providers?
Response is either: Yes or No
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IF YES: Did the health center provide documentation of approval by HRSA (i.e., the arrangement was included in a HRSA-approved application or was approved by HRSA through a post-award request)?
Note: Only select “Not Applicable” if this is a Look-Alike Initial Designation Site Visit.
Response is: Yes, No, or Not Applicable
If No, an explanation is required.
The health center’s contracts that support the HRSA-approved scope of project include provisions that address the following:
- The specific activities or services to be performed or goods to be provided;
- Mechanisms for the health center to monitor contractor performance; and
- Requirements for the contractor to provide data necessary to meet the recipient’s applicable federal financial and programmatic reporting requirements, as well as provisions addressing record retention and access, audit, and property management.6
Site Visit Team Methodology
Review the contracts for Column II services from within the sample (both those that use and those that do not use Health Center Program federal award funds).
Notes:
- If the sample does not contain Column II contracts, review the remaining contracts in the sample.
- Do not review agreements related to Column III-only services.
- If a contract covers a mix of Column II and Column III services, only review the portion of the contract related to Column II services.
Review any documentation that supports health center monitoring of contractor performance (for example, health center policies or procedures for purchasing, procurement, and contract management).
Site Visit Findings
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Does the health center have one or more contracts to provide Column II services or contracts for other goods and services that support the Health Center Program project?
Response is either: Yes or No
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IF YES: Does the health center have contracts OR other documentation (for example, health center policies or procedures) stating how the health center will monitor contractor performance?
Response is either: Yes or No
Response is: Yes, No, or Not Applicable.
- IF YES: Based on the sample of contracts reviewed, do these contracts contain provisions that address the following areas:
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12.1 Specific activities or services performed or goods provided by the contractor?
Response is: Yes, No, or Not Applicable
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12.2 Requirements for contractor data reporting, including reporting frequency?
Response is: Yes, No, or Not Applicable
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12.3 Provisions for record retention and access, audit, and property management?7
Response is: Yes, No or Not Applicable
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If No was selected for any of the above, an explanation is required.
Subawards: Monitoring and Management
ELEMENT “G” THROUGH ELEMENT “J” ARE ONLY APPLICABLE FOR RECIPIENTS WITH AT LEAST ONE SUBRECIPIENT AND ARE NOT APPLICABLE TO LOOK-ALIKES.
Select each element below for the corresponding text of the element, site visit team methodology, and site visit finding questions.
If the health center has made a subaward,8 the health center requested and received prior approval from HRSA as documented by:
- An approved competing continuation/renewal of designation application or other competitive application, which included the subrecipient arrangement; or
- An approved post-award request for such subrecipient arrangements submitted within the period of performance (for example, change in scope).
Site Visit Team Methodology
- Review Form 8: Health Center Agreements.
- Review the most recent annual audit and management letter to determine if subrecipients were identified in the audit report, including the amount of the subawards.
- Review all subrecipient agreements that support the recipient’s HRSA-approved scope of project.
- Review the health center’s documentation of HRSA’s prior approval of each subrecipient arrangement.
Site Visit Findings
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Did the health center make any subawards (new or continuing) during the current period of performance?
Response is: Yes, No, or Not Applicable
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Did the health center provide documentation of prior approval by HRSA of the subrecipient arrangement (i.e., arrangement was included in the last HRSA-approved Service Area Competition (SAC) application or was approved by HRSA through a post-award request)?
Response is: Yes, No, or Not Applicable
If No, an explanation is required.
The health center’s subaward(s) that supports the HRSA-approved scope of project includes provisions that address the following:
- The specific portion of the HRSA-approved scope of project to be performed by the subrecipient;
- The applicability of all Health Center Program requirements to the subrecipient;
- The applicability to the subrecipient of any distinct statutory, regulatory, and policy requirements of other federal programs associated with their HRSA-approved scope of project;9
- Mechanisms for the health center to monitor subrecipient compliance and performance;
- Requirements for the subrecipient to provide data necessary to meet the health center’s applicable federal financial and programmatic reporting requirements, as well as provisions addressing record retention and access, audit, and property management;10 and
- Requirements that all costs paid for by the federal subaward are allowable consistent with federal cost principles.11
Site Visit Team Methodology
- Review all subrecipient agreements that support the HRSA-approved Health Center Program scope of project.
Note: Review the subrecipient agreement only for Health Center Program compliance.
Site Visit Findings
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Do all of the health center’s subrecipient agreements include provisions that address the following:
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15.1 The portion of the health center project (i.e., sites and services) carried out by the subrecipient and how?
Response is: Yes, No, or Not Applicable
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15.2 The applicability of all Health Center Program requirements to the subrecipient?
Response is: Yes, No, or Not Applicable
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15.3 The applicability of other distinct statutory, regulatory, and policy requirements of associated programs and benefits to the subrecipient? For example, requirements that apply if the subrecipient participates in the 340B Drug Pricing Program.
Response is: Yes, No, or Not Applicable
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15.4 Mechanisms for the health center to monitor subrecipient compliance and performance?
Response is: Yes, No, or Not Applicable
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15.5 Data the subrecipient must collect and report back to the recipient (for example, UDS data)?
Response is: Yes, No or Not Applicable
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15.6 Record retention and access, audit, and property management?
Response is: Yes, No, or Not Applicable
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15.7 Requirements that all costs paid for under the subaward are consistent with federal cost principles?
Response is: Yes, No, or Not Applicable
If No was selected for any of the above, an explanation is required.
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The health center monitors the activities of its subrecipient to ensure that the subaward is used for authorized purposes and that the subrecipient maintains compliance with all applicable requirements specified in the federal award (including those found in section 330 of the PHS Act, implementing program regulations and grants regulations in 2 CFR Part 200). Specifically, the health center’s monitoring of the subrecipient includes:
- Reviewing financial and performance reports required by the health center in order to ensure performance goals are achieved, UDS data are submitted by appropriate deadlines, and funds are used for authorized purposes;
- Ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the subaward that may be identified through audits, on-site reviews, and other means; and
- Issuing a management decision for audit findings pertaining to the subaward.12
Site Visit Team Methodology
- Review all subrecipient agreements that support the recipient’s HRSA-approved scope of project.
- Review the policies or procedures for subrecipient monitoring.
- Interview staff who provide oversight of subrecipient activities.
Note for the remaining methodology: For a health center with five or fewer subrecipients, review the documentation from all subrecipients. For a health center with more than five subrecipients, review the documentation from the five subrecipients that receive the largest amounts of Health Center Program subaward funds.
- Review the documentation from within the current period of performance of subrecipient monitoring by the health center. If there have been subrecipient deficiencies, review the documentation ensuring that the subrecipient took corrective action.
- Review the sample of financial and performance reports received from the subrecipient, including the subrecipient’s annual audit.
- Review the following documentation used by the health center to confirm subrecipient compliance:
- Subrecipient articles of incorporation, bylaws (either for the subrecipient’s board or the co-applicant board of a public agency subrecipient), or other corporate documents (for example, co-applicant agreement);
- Subrecipient sliding fee discount program (SFDP) policy;
- If the subrecipient board-approved SFDP policy does not state a specific amount of each nominal charge or how each nominal charge is determined, review other documentation (for example, subrecipient board minutes, subrecipient reports) of subrecipient board involvement in setting the amount of each nominal charge;
- Current subrecipient board roster or completed Form 6A indicating current board member characteristics as follows: patient status, area of expertise, and if their percentage of income from the health care industry is greater than 10 percent;
- Subrecipient billing records from within the past 24 months to confirm the patient status of subrecipient board members; and
- Subrecipient analysis used to assess whether patient board members, as a group, represent the individuals who are served by the health center.
Notes:
- Self-attestation by the subrecipient is not sufficient to confirm compliance.
- The health center recipient is responsible for ensuring that the subrecipient meets all the Health Center Program requirements applicable to the health center recipient’s federal award. For example: A health center recipient receives a 330(e) award and has a subrecipient that receives a 330(h) award directly from HRSA. The health center recipient would ensure the subrecipient meets all 330(e) requirements.
Site Visit Findings
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Does the health center have a process for monitoring the activities of the subrecipient during the current period of performance? Specifically, does the process ensure that the subrecipient maintains compliance with all Health Center Program requirements and all other applicable requirements specified in the federal award, including implementing any corrective actions?
Response is: Yes, No, or Not Applicable
If Yes OR No, an explanation is required describing the health center’s monitoring methods.
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Does the health center have a specific process for receiving and reviewing financial and performance reports (including the subrecipient’s annual audit) during each period of performance that addresses the following areas:
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17.1 Achievement of performance goals?
Response is: Yes, No, or Not Applicable
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17.2 Submission of UDS data by appropriate deadlines?
Response is: Yes, No, or Not Applicable
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17.3 Use of funds for authorized purposes?
Response is: Yes, No, or Not Applicable
If No was selected for any of the above, an explanation is required.
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Did the health center receive and review the following reports from the subrecipient during the current period of performance:
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18.1 Financial reports, including the subrecipient’s audit?
Response is: Yes, No, or Not Applicable
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18.2 Performance reports, including submission of data for the health center’s UDS reporting?
Response is: Yes, No, or Not Applicable
If No was selected for any of the above, an explanation is required, including specifying which reports the health center did not receive or review.
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Did the health center identify any deficiencies with the subrecipient’s financial or performance reporting during the current period of performance, including any deficiencies in the subrecipient’s annual audit?
Response is: Yes, No, or Not Applicable
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IF YES: Is there documentation that the health center ensured the subrecipient took timely corrective action on the identified deficiencies?
Response is: Yes, No, or Not Applicable
If No, an explanation is required specifying what deficiencies remain.
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Did the health center provide documentation demonstrating that each subrecipient is currently compliant with the following Board Composition requirements:
Note: Select “No” if the health center is unable to provide documentation that verifies that the subrecipient is in compliance OR if the documentation provided does not demonstrate subrecipient compliance.
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21.1 The subrecipient’s board is currently composed of at least 9 and no more than 25 members?
Response is: Yes, No, or Not Applicable
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21.2 At at least 51 percent of subrecipient board members are classified by the subrecipient as patients?
Note: Select “Not Applicable” only if the recipient has approved the subrecipient’s request for a waiver of patient majority board composition requirements. A waiver is only available if the health center recipient receives an award under section 330(g), 330(h) and/or 330(i) and does not receive an award under section 330(e).
Response is: Yes, No, or Not Applicable
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21.3 Each subrecipient patient board member has received at least one in-scope service at an in-scope service site within the past 24 months that generated a health center visit?
Note: Select “Not Applicable” only if the recipient has approved the subrecipient’s request for a waiver of patient majority board composition requirements. A waiver is only available if the health center recipient receives an award under section 330(g), 330(h) and/or 330(i) and does not receive an award under section 330(e).
Response is: Yes, No, or Not Applicable
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21.4 The subrecipient’s patient board members as a group are representative of the subrecipient’s patient population?
Note: Select “Not Applicable” only if the recipient has approved the subrecipient’s request for a waiver of patient majority board composition requirements. A waiver is only available if the health center recipient receives an award under section 330(g), 330(h) and/or 330(i) and does not receive an award under section 330(e).
Response is: Yes, No, or Not Applicable
If No OR Not Applicable is selected for any of the above, an explanation is required.
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Did the health center provide documentation demonstrating that each subrecipient is currently compliant with the following Board Authority requirements:
Note: Select “No” if the health center is unable to provide documentation that verifies that the subrecipient is in compliance OR if the documentation provided does not demonstrate subrecipient compliance.
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22.1 Holding monthly meetings?
Response is: Yes, No, or Not Applicable
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22.2 Approving the selection and termination or dismissal of the subrecipient’s Project Director/CEO?
Response is: Yes, No, or Not Applicable
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22.3 Approving the subrecipient’s health center project annual budget and applications?
Response is: Yes, No, or Not Applicable
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22.4 Approving the subrecipient’s health center services?
Response is: Yes, No, or Not Applicable
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22.5 Approving the location and hours of operation of the subrecipient’s health center sites?
Response is: Yes, No, or Not Applicable
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22.6 Evaluating the performance of the subrecipient’s health center project?
Response is: Yes, No, or Not Applicable
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22.7 Establishing or adopting policy related to the operations of the subrecipient’s health center project?
Response is: Yes, No, or Not Applicable
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22.8 Assuring the subrecipient operates in compliance with applicable federal, state, and local laws and regulations?
Response is: Yes, No, or Not Applicable
If No is selected for any of the above, an explanation is required.
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Did the health center provide documentation showing that each subrecipient’s Sliding Fee Discount Program (SFDP) policy includes language or provisions that address all of the following:
Note: Select “No” if the health center is unable to provide documentation that verifies that the subrecipient is in compliance OR if the documentation provided does not demonstrate subrecipient compliance.
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23.1 The policy applies uniformly to all patients?
Response is: Yes, No, or Not Applicable
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23.2 The definitions of income and family (or “household”)? For example, what the subrecipient includes or does not include in the definitions.
Response is: Yes, No, or Not Applicable
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23.3 The methods for assessing patient eligibility based only on income and family size?
Response is: Yes, No or Not Applicable
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23.4 The way each sliding fee discount schedule is structured to ensure charges are adjusted based on ability to pay? For example, the policy addresses that flat fee amounts differ across discount pay classes or that there is a graduated percent of charges for patients with incomes above 100 percent and at or below 200 percent of the Federal Poverty Guidelines (FPG).
Response is: Yes, No, or Not Applicable
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23.5 The setting of any nominal charges for patients with incomes at or below 100 percent of the FPG?
Note: Select “Not Applicable” if the subrecipient does not charge patients with incomes at or below 100 percent of the FPG.
Response is: Yes, No, or Not Applicable
If No was selected for any of the above, an explanation is required.
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Did the health center provide documentation showing that each subrecipient’s SFDP policy ensures that any charges for patients with incomes at or below 100 percent of the FPG are:
Notes:
- Select “No” if the health center is unable to provide documentation that verifies that the subrecipient is in compliance OR if the documentation provided does not demonstrate subrecipient compliance.
- Select “Not Applicable” if the health center does not charge patients with incomes at or below 100 percent of the FPG.
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24.1 A flat fee?
Response is: Yes, No, or Not Applicable
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24.2 Nominal from the perspective of patients with incomes at or below 100 percent of the FPG? For example, based on input from patient board members, patient surveys, advisory committees, or a review of Medicare and Medicaid co-pay amounts for patients with comparable incomes.
Response is: Yes, No, or Not Applicable
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24.3 Not based on the actual cost of the service?
Response is: Yes, No, or Not Applicable
If No was selected for any of the above, an explanation is required.
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Does the health center have a process that ensures the subrecipient resolves noncompliance with Health Center Program requirements?
Response is: Yes, No, or Not Applicable
If Yes OR No, an explanation is required.
- IF NO: Describe the deficiencies in the health center’s process.
- IF YES: Describe the health center’s process.
- IF THE HEALTH CENTER HAS IDENTIFIED SUBRECIPIENT NONCOMPLIANCE: Specify the requirements and how the health center has confirmed or will confirm subrecipient compliance.
The health center retains final subrecipient agreements and related records, consistent with federal document maintenance requirements.13
Site Visit Team Methodology
- Review all subrecipient agreements that support the recipient’s HRSA-approved scope of project.
- Review the documentation of subrecipient monitoring.
- Review the sample of financial and performance reports received from the subrecipient.
Site Visit Team Findings
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Does the health center have final executed subrecipient agreements that were awarded within the past 3 years as well as related financial and other performance records?
Response is: Yes, No, or Not Applicable
If No, an explanation is required.
Footnotes
1For the purposes of the Health Center Program, contracting for substantive programmatic work applies to contracting with a single entity for the majority of health care providers. The acquisition of supplies, material, equipment, or general support services is not considered programmatic work. Substantive programmatic work may be further defined within HRSA Notices of Funding Opportunity (NOFOs) and applications.
2. See 2 CFR 200.400 for HHS policy guide.
3. Procurements by non-competitive proposals are allowable only when:
- The aggregate amount of the procurement transaction does not exceed the micro-purchase threshold [refer to 2 CFR 200.320(a)(1)];
- The procurement transaction can only be fulfilled by a single source;
- The public exigency or emergency for the requirement will not permit a delay resulting from providing public notice of a competitive solicitation;
- The recipient or subrecipient requests in writing to use a noncompetitive procurement method, and the Federal agency [HRSA] or pass-through entity provides written approval; or
- After soliciting several sources, competition is determined inadequate.
4. Refer to 2 CFR 200.334 for HHS retention requirements for records.
5. For the purposes of the Health Center Program, contracting for substantive programmatic work applies to contracting with a single entity for the majority of health care providers. The acquisition of supplies, material, equipment, or general support services is not considered programmatic work. Substantive programmatic work may be further defined within HRSA Notices of Funding Opportunity (NOFOs) and applications.
6. For further guidance on these requirements, refer to the HHS Grants Policy Statement on Grants Policies & Regulations.
7. Specifically, the purpose of a subaward is to carry out a portion of the federal award and creates a federal assistance relationship with the subrecipient, while the purpose of a contract is to obtain goods or services for the health center’s own use and creates a procurement relationship with the contractor.
8. Property management may only be applicable in certain contracts, based on the types of the goods or services provided. Property is defined in 2 CFR 200 as either real property or personal property. Most contract provisions for “record retention and access” and “audit” likely will be applicable. For example, while property may not be relevant to the contract for an after-hours answering service or with a radiology practice, the health center would need to have access to patient records, calls and related information, including the ability to audit this information when needed, as part of its contract with these third-party organizations.
9. Subrecipients are generally eligible to receive Federally Qualified Health Center (FQHC) payment rates under Medicaid and Medicare, 340B Drug Pricing Program, and Federal Tort Claims Act (FTCA) coverage. However, such benefits are not automatically conferred and may require additional actions and approvals (for example, submission and approval of a subrecipient FTCA deeming application).
10. For further guidance on these requirements, refer to the HHS Grants Policy Statement on Grants Policies & Regulations.
11. Refer to 2 CFR 200 Subpart E: Cost Principles.
12. Per 2 CFR 200.521, the management decision [issued by the health center to the subrecipient] must clearly state whether or not the audit finding is sustained, the reasons for the decision, and the expected auditee action to repay disallowed costs, make financial adjustments, or take other action.
13 Refer to 2 CFR 200.334 for HHS retention requirements for records.