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Access additional COVID-19 Frequently Asked Questions.
- Funding Purpose and Methodology
- Award Submission Requirement
- Maintaining Capacity and Personnel Support
- Minor Alteration and Renovation (A/R)
- Other Uses of Funds
Funding Purpose and Methodology
What are the purposes and allowed uses of American Rescue Plan funding for health centers (H8F)?
On Thursday, April 1, 2021, HRSA awarded more than $6.1 billion in funding provided by the American Rescue Plan Act (PDF) to 1,377 HRSA-funded health centers (activity code H8F). The purposes of the American Rescue Plan funding are to prevent, mitigate, and respond to coronavirus disease 2019 (COVID-19) and to enhance health care services and infrastructure. Consistent with these purposes, funding may support a wide range of in-scope activities, which may change as COVID-19 circumstances and related community, patient, and organizational needs evolve over the 2-year period of performance.
More information regarding the allowable uses of H8F funds is available on the H8F Activities and Allowable Uses of Funds webpage. For additional information, see the H8F technical assistance webpage.
How was the amount of H8F funding determined for each health center award recipient?
HRSA used the following distribution formula:
- Base value of $500,000, plus
- $125.00 per patient reported in the 2019 UDS, plus
- $250.00 per uninsured patient reported in the 2019 UDS.
Why was the H8F funding issued through a separate grant?
To support tracking of American Rescue Plan spending, awards were issued separately from a health center’s operational (H80) grant award with the activity code H8F. As is the case with fiscal year 2020 COVID-19 supplemental funding, health centers will need to separately track and account for their H8F activities supported through this funding.
To meet program requirements and correctly attribute costs to specific programs, HRSA award recipients must maintain appropriate records and cost documentation as required by 45 CFR §75.302 - Financial Management and Standards for Financial Management Systems, and 45 CFR §75.361 - Retention Requirement for Records, to substantiate the charging of any salaries and other project activities costs. For additional information on maintaining compliance with Health Center Program requirements (e.g., applicability of sliding fee policy, billing and collections) during the COVID-19 public health emergency, see the Health Center Program’s COVID-19 Frequently Asked Questions.
What is the period of performance for the use of the H8F funding?
H8F awards have a 2-year period of performance. Refer to the H8F notice of award for specific start and end dates. Funding is available for immediate use, and pre-award costs dating back to January 31, 2020 expended in alignment with the purposes of H8F funding are permitted.
Can a health center request a project period extension for the H8F award if more time is needed to complete approved activities?
HRSA awarded one-time H8F funding with a 2-year period of performance. If you need additional time (up to 12 months) to complete your approved project or program-related activities, you must submit a separate Extension Without Funds (no cost extension) prior approval request to HRSA. Extension requests must be made through HRSA's Electronic Handbooks (EHBs) prior to the H8F project period end date. You may not use this one-time extension to expend unused funds for new or additional project or program-related activities. All extension requests are subject to HRSA approval. Contact your Grants Management Specialist with questions.
What is the PIN to access H8F funding in the Payment Management System?
Health centers will use the same PIN they use to access their H80 grant funding through the Payment Management System (PMS). If you experience any issues accessing your H8F grant funding, please contact your PMS accountant, whom you can identify through Find Your PMS Liaison Accountant, and/or contact the assigned Grants Management Specialist identified in your H8F notice of award.
Are Health Center Program look-alikes eligible to receive American Rescue Plan funding?
Health Center Program look-alikes are eligible for funding under the American Rescue Plan – Funding for Look-Alikes (ARP-LAL) Notice of Funding Opportunity, which was issued on April 19, 2021. Applications are due by May 14, 2021. More information is available on the ARP-LAL technical assistance webpage.
Award Submission Requirement
Do health centers need to apply for H8F funding?
To expedite distribution of this critical funding, HRSA has made funds immediately available and will collect budget and activities/costs to be supported by the funding through the H8F award submission requirement in HRSA's EHBs.
How do health centers submit their H8F award submission requirement?
Health centers must submit H8F project information through a submission task in the H8F grant folder in HRSA’s EHBs. See the instructions to add your H8F grant folder to your EHBs portfolio. For COVID-19 funding awarded in fiscal year 2020, health centers submitted an activity overview as an attachment. For H8F, health centers will select activities from prepopulated options in the Work Plan section of the Project Overview form in the EHBs. See the H8F Award Submission Requirement Guidance for details.
Does the H8F award submission have to be approved by the health center’s Board of Directors prior to submission?
Yes. Your governing board is responsible for approving all applications related to your Health Center Program project, including the H8F award submission information.
Maintaining Capacity and Personnel Support
Can health centers use H8F funds to continue an activity that was paid for under previous federal awards (H80, H8C, H8D, H8E)?
As indicated in the H8F Award Submission Guidance, you may not use H8F funds for costs already paid for by H80, H8C, H8D, or H8E funding. However, H8F funds may support new costs to continue or expand activities initiated with your prior COVID award or other sources of funding that are ending or have recently ended.
You must monitor expenditures from all sources to ensure compliance with the individual funding requirements, and continue to adhere to the Uniform Administrative Requirements, federal cost principles, and audit requirements for HHS awards (45 CFR Part 75), and your organization’s policies. To meet program requirements and correctly attribute costs to specific programs, HRSA award recipients must maintain appropriate records and cost documentation as required by 45 CFR §75.302 – Financial Management and Standards for Financial Management Systems, and 45 CFR §75.361 – Retention Requirement for Records.
Is there a limit to the amount of funding that can be used for pre-award costs dating back to January 31, 2020?
There is not a limit to the amount of funds that may be used for pre-award costs, but they must be reasonable and justified in your H8F award submission. Provide a detailed description of the pre-award activities that align with the purpose of the funding in your budget narrative and in the work plan section of the Project Overview Form. You must ensure that your financial records reflect the transfer of these costs to the new award, consistent with your HRSA-approved budget.
Can health centers use H8F funds to cover revenue lost as a result of the COVID-19 public health emergency?
No. Federal award funds do not replace lost revenue (e.g., reimbursement for dental or primary care visits from public and private health insurance sources). However, health centers are permitted to increase their reliance on grant funds to cover fixed operational costs.
This increased reliance on grant funds is an allowable expenditure under H8F funds. Your health center may use H8F funds to cover allowable operational costs going back to January 31, 2020.
Your health center may also rebudget your H80 award as needed to cover allowable operational costs differently than originally proposed (e.g., move personnel originally budgeted under your H80 grant to your H8F grant), for obligations incurred since January 31, 2020. As a reminder, if you rebudget your H80 award for more than 25% or to a line item that previously had no federal funds, grant rules require you to submit a prior approval request to your Grants Management Specialist via HRSA’s EHBs.
Separate from Health Center Program funding, health centers may be eligible to be reimbursed or compensated for lost revenues through other federal or state programs. For information on other resources available during the COVID-19 public health emergency, see the Health Center Program’s COVID-19 Frequently Asked Questions.
Can health centers use H8F funds for hazard pay or a "pandemic premium"?
H8F funds may be used for hazard and premium pay if you have policies and procedures in place that cover this type of pay. Personnel who will be paid with grant funding must receive salary and benefits consistent with your health center's policies for paying salaries under unexpected or extraordinary circumstances from all funding sources, federal and non-federal. You must document that you are following your organizational policy for charging salaries during unexpected and extraordinary circumstances.
Can health centers use H8F funds for raises or bonuses for any health center personnel?
Yes. H8F funds can be used for raises and bonuses that align with your organization’s policies and procedures consistently applied across the organization. You must document that you are following your organizational personnel policies, including those for charging salaries during unexpected and extraordinary circumstances. You must also maintain appropriate records and cost documentation as required by 45 CFR § 75.302 – Financial Management and Standards for Financial Management Systems, and 45 CFR § 75.361 – Retention Requirement for Records.
For example, you would document that you have not been able to give raises or pandemic bonuses that were approved or part of existing policy due to a shortfall of funds. You would also show evidence that you could not pay out of other funding sources, and that the staff are working on activities that are in scope and allowed uses of H8F funds.
Minor Alteration and Renovation (A/R)
Is the maximum of $500,000 in H8F funds for minor A/R a per-site limit or a per-health center limit?
It is a per-health center limit. H8F funding for minor A/R activities is limited to a combined total of $500,000 per health center, across all sites. See the Other Requirements for Sites form (PDF - 201 KB) for instructions regarding minor A/R requirements.
Can health centers use H8F funds for minor A/R activities at temporary sites or sites that are intended to be brought into scope at a later date?
Temporary sites are not eligible for minor A/R unless they become permanent in-scope sites. You may include costs for activities to be performed at a site that will be brought into scope as a permanent site at a future date within the 2-year period of H8F funding. You may not perform proposed activities at this site until receiving HRSA approval to add the permanent site to scope. In your H8F award submission, you will indicate on the Project Overview Form that changes will be required to your Form 5B: Service Sites. For additional information, review the technical assistance materials on the Scope of Project webpage and related Considerations for Health Center Scope of Project and the COVID-19 Public Health Emergency. Contact the Program Official listed on your notice of award for guidance.
Can health centers use H8F funds for repaving a parking lot at an in-scope site?
Yes. Repaving of an existing parking lot at an in-scope site is an allowable minor A/R activity. However, you cannot expand the parking lot into previously unpaved or gravel areas (i.e., you cannot add to the existing square footage or perform site work that would cause new ground disturbance). See the Other Requirements for Sites Form (PDF - 201 KB) for instructions related to minor A/R requirements. New parking surfaces are not an allowable use of H8F funds.
Do the Davis-Bacon Act requirements apply to minor A/R activities using H8F funds?
No. The Davis-Bacon Act does not apply to this funding. However, you must follow state and local requirements for prevailing wages and fair labor policies.
Other Uses of Funds
Can health centers use H8F funds to conduct COVID-19 contact tracing?
H8F funds may be used for COVID-19 contact tracing of health center patients, provided such activities are within the health center’s scope of project. Contact tracing activities should follow CDC and other applicable public health guidance, and be coordinated as appropriate with federal, state, and local public health response efforts.
Health center contact tracing activities other than those described above, as well as activities performed on behalf of a third party, including on behalf of a federal, state, or local public health agency, would constitute another line of business outside the scope of the Health Center Program project. See the Health Center Program COVID-19 Frequently Asked Questions for additional information.
Can health centers use H8F funds to support antibody testing?
Yes. H8F funding may support a wide range of testing and testing-related in-scope activities that may change as COVID-19 needs and guidance evolve within your community.
The term "diagnostic test" generally refers to a molecular or antigen test, both of which can be used to diagnose infection with the SARS-CoV-2 virus. The terms "antibody test" or "serological test" generally refer to tests that detect antibodies to the SARS-CoV-2 virus. More information is available in the Food and Drug Administration’s FAQs on Testing for SARS-CoV-2 and in the Testing section of the Health Center Program’s COVID-19 Frequently Asked Questions.
Can health centers use H8F funds to rent space, including temporary structures?
H8F funds may be used to support rent of an approved site to perform in-scope activities, including temporary structures.
Can health centers use H8F funds for supplies necessary for health center personnel to participate in telehealth from their homes, such as tablets, phones, webcams, and speakers?
Yes. H8F funds may be used to purchase supplies necessary for health center personnel to use telehealth to perform in-scope services. For additional information, refer to COVID-19 Grantee Frequently Asked Questions.
Can health centers use H8F funds for enabling services?
Yes. H8F funds may be used to support, expand, or increase enabling services. This includes but is not limited to support for outreach, patient education, eligibility assistance to support insurance enrollment, translation, interpretation, and transportation that supports COVID-19 testing, treatment, and vaccination, as well as comprehensive primary care.
Can health centers use H8F funds for services not directly related to COVID-19?
As indicated in the American Rescue Plan, funds may be used to modify, enhance, and expand health care services and infrastructure. Therefore, H8F funds may be used to modify, enhance, and expand non-COVID-19 related health care services, including mental health, substance use disorder, dental, vision, pharmacy, and other in-scope services. This may include personnel and the purchase of supplies, equipment, and vehicles to support expanded services. All services must be within the health center’s approved scope of project and conducted on behalf of the health center. See the H8F Activities and Allowable Uses of Funds webpage.
Can health centers use H8F funds to support routine immunizations?
As indicated in the American Rescue Plan, funds may be used to modify, enhance, and expand health care services. Therefore, H8F funds may be used to support the provision of routine immunizations—including influenza vaccines—provided such activities are within the health center’s scope of project. Immunizations performed on behalf of the health center should be reflected as required services on a health center’s Form 5A: Services Provided. Health centers may also use H8F funds to provide outreach or education about immunizations. More information about the provision of routine immunizations is available in the Providing Care During Emergencies section of the Health Center Program’s COVID-19 Frequently Asked Questions.
Can health centers use H8F funds to support early childhood health activities, such as developmental screenings?
Yes. H8F funds may be used for costs related to enhancing early childhood health care, including personnel who may promote developmental health, providing developmental screening and interventions that align with in-scope services, and connecting families with other needed services. In your H8F Work Plan, you would write in such activities under the corresponding category, which will most likely be Maintaining and Increasing Capacity and/or Recovery and Stabilization. See the related examples on the H8F Activities and Allowable Uses of Funds webpage.
Can health centers use H8F funds for food for patients experiencing unemployment and/or homelessness?
H8F funding may not be used for food, unless the provision of food is specifically part of your health center’s treatment plan (e.g., special meals for diabetic patients), supported by written health center policies, and part of the health center’s scope of project.
Can health centers offer incentives to patients and staff for COVID-19 vaccination, and can they use H8F funds to pay for these expenditures?
Health centers may use non-grant funds and/or leverage partnerships with or donations from other community organizations or businesses to offer small rewards to individuals as an incentive for receiving the COVID-19 vaccine, such as a nominal gift card to a local business or store, food, a meal, or a free admission voucher to a local event or attraction.
Health centers may also use H8F grant funds to offer certain incentive items, as long as the specific associated costs are allowable under grants regulations (45 CFR 75) or other federal regulations. If a health center chooses to use H8F grant funds to pay for incentives for COVID-19 vaccination, certain limitations apply. Specifically, H8F funds may not be used for cash gift cards, food, or other costs prohibited under 45 CFR 75 or other federal regulations. Use of funds for incentive costs must be supported by written health center policies or procedures. If you choose to include incentive costs in your H8F budget, provide details on the types of incentives these costs will support and a justification regarding how such items will incentivize vaccination.
As a reminder, when developing H8F budgets and planning for expenditures of these award funds:
- The overall purposes of American Rescue Plan (H8F) funding are to prevent, mitigate, and respond to COVID-19 and to enhance health care services and infrastructure.
- Health centers, as with all award funds, must document that they are following their organizational policies and procedures and must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 – Financial Management and Standards for Financial Management Systems, and 45 CFR § 75.361 – Retention Requirement for Records, to substantiate the charging of any vaccine incentive costs.
It is also recommended that any health center considering incentives for vaccination (using either non-grant funds, in-kind contributions, or H8F funds) also review related information from the HHS Office of the Inspector General (OIG) regarding the offer or provision of cash, cash-equivalent, or in-kind incentives or rewards to federal health care program beneficiaries who receive COVID-19 vaccinations during the public health emergency. This and other information regarding administrative enforcement authorities, including the federal anti-kickback statute, is available from the HHS OIG. For specific inquiries, please contact OIGComplianceSuggestions@oig.hhs.gov.
In addition, health centers should be aware that the American Rescue Plan allows small and midsize employers, and certain governmental employers, to claim refundable tax credits that reimburse them for the cost of providing paid sick and family leave to their employees due to COVID-19, including leave taken by employees to receive or recover from COVID-19 vaccinations. These tax credits are available to eligible employers for wages paid for sick and family leave from Thursday, April 1, 2021, through Thursday, September 30, 2021.
Can health centers use H8F funds to provide child care for patients while they are waiting to be vaccinated by the health center?
Yes, H8F funds may be used for costs related to maintaining, enhancing, or increasing health center enabling services, including providing care for the children of parents/guardians who present for COVID-19 vaccination. However, please note that the provision of limited child care to facilitate access to health center services is distinct from daycare, which would constitute another line of business outside of the Health Center Program scope of project.
Can health centers use H8F funding for hotel/motel costs, housing, or other rental space for patients to quarantine or self-isolate?
No. H8F funds may not be used for temporary housing costs or long-term housing/lodging costs for patients who may require quarantine or isolation. Health centers may provide these services outside the Health Center Program scope of project as another line of business.
Can health centers use H8F funds for supplies such as tablets, phones, webcams, and biometric devices, and provide these to health center patients so that they may participate in telehealth, virtual care, or remote monitoring from their homes?
Yes. H8F funds may be used to purchase supplies necessary for use by health center patients to access in-scope services via telehealth or virtual care or to support such services via remote monitoring technology. Items may include health and wellness-related technology hardware and software, computer and mobile phone applications, and devices that support patient participation in virtual appointments, remote home monitoring, and engagement in care through telemedicine.
H8F funds may not be used to provide these items as incentives to individuals to induce them to select the health center as their provider. Additionally, you must ensure such purchases align with your organization's policies and procedures, and maintain appropriate records and cost documentation as required by 45 CFR §75.302.
As a reminder, health centers providing services via telehealth must assure that any services provided remotely are consistent with federal and state law, including HIPAA and applicable CMS requirements. For more information see:
- HIPAA flexibility for telehealth technology
- CMS telehealth information
- PAL 2020-01: Telehealth and Health Center Scope of Project (PDF - 176 KB)
HRSA encourages you to review the following guidance on the federal anti-kickback and physician self-referral law. In particular, you cannot provide incentives conditioned on an individual’s past or anticipated future use of services that are reimbursable in whole or in part by federal health care programs. For specific inquiries, please contact OIGComplianceSuggestions@oig.hhs.gov.
- Office of Inspector General Safe Harbor Regulations
- Final Rule: Safe Harbor for Federally Qualified Health Centers Arrangements Under the Anti-Kickback Statute (PDF - 103 KB)
- Office of Inspector General Fraud and Abuse Laws
Can health centers pool their H8F funds for shared costs for health center activities?
Yes. To maximize cost effectiveness, multiple health centers may choose to pool resources to support joint H8F activities. To do so, each participating health center must demonstrate that the shared activities are specific to their H8F project. Some examples include (but are not limited to):
- Outreach and education on COVID-19 testing and vaccination.
- Statewide marketing and awareness campaigns that focus on vaccination and getting people back into care.
- Paraprofessional education programs to address workforce shortages and staff burnout.
- A shared recruiter to build relationships with training and education programs.
- Health center leadership development program.
- Implementation of a legal services program.
- Development of a patient engagement and population health program.
Each health center must document that they are following their organizational financial policies and procedures, especially those regarding oversight of contractors and procurements, and be in compliance with the Procurement Standards in 45 CFR part 75, except those waived by OMB Memo 21-20 (PDF - 372 KB) regarding geographical preferences and contracting small and minority businesses, women’s business enterprises, and labor surplus area firms. Health centers must also maintain appropriate records and cost documentation as required by 45 CFR § 75.302– Financial Management and Standards for Financial Management Systems, and 45 CFR § 75.361 – Retention Requirement for Records.
How should health centers use H8F funds to support the needs of special populations (i.e., homeless individuals and family, migrant and seasonal agricultural workers, and/or residents of public housing)?
Within the required purposes described in HRSA’s H8F Award Submission Requirement Guidance, health centers have flexibility regarding how to use H8F funding as COVID-19 circumstances and related community, patient, and organizational needs evolve over the 2-year period of performance. HRSA encourages all health centers to consider how best to leverage H8F funding to meet the needs of their patients, including the unique needs of homeless individuals and families, migrant and seasonal agricultural workers, and individuals living in or near public housing, and to otherwise consider ways to leverage H8F funding to address:
- Equitable access to COVID-19 vaccination, testing, and treatment;
- Other current and anticipated COVID-19 and primary health care needs in the service area; and
- Population and social determinants of health that may impact access to care, contribute to poor health outcomes, and exacerbate health disparities.