If you have a question that is not addressed by these FAQs, by the ARP-LAL notice of funding opportunity (NOFO), or on the ARP-LAL technical assistance webpage, please submit it through the BPHC Contact Form. Select “Applicant" for Requestor Type, “Coronavirus Inquiries (COVID-19)" as the Health Center Program Questions, and then select “Look-Alike COVID-19 Funding” for BPHC Category.
For general COVID-19 information, including additional related FAQs, see the Health Center Program COVID-19 Frequently Asked Questions.
- Funding Purpose and Methodology
- Allowed Uses of Funds
- Maintaining Capacity and Personnel Support
- Minor Alteration and Renovation (A/R)
- Application Components
Funding Purpose and Methodology
What American Rescue Plan funding has HRSA awarded to support Health Center Program look-alikes in responding to the COVID-19 public health emergency?
On Thursday, July 15, HRSA released nearly $144 million in funding provided by the American Rescue Plan Act of 2021 (PDF) to support 102 Health Center Program look-alikes to respond to and mitigate the spread of COVID-19. More information is available on the ARP-LAL technical assistance webpage.
What are the purpose and allowed uses of ARP-LAL funding?
The purpose of the ARP-LAL funding is to enable Health Center Program look-alikes to prevent, mitigate, and respond to COVID-19 and to enhance health care services and infrastructure. Consistent with this purpose, funding may support a wide range of in-scope activities that may change as COVID-19 circumstances and related community, patient, and organizational needs evolve over the 2-year period of performance.
How was the amount of ARP-LAL funding determined for each look-alike?
HRSA used the following formula:
- Base value of $500,000, plus
- $125 per patient reported in the 2019 Uniform Data System (UDS), plus
- $250 per uninsured patient reported in the 2019 UDS.
Look-alikes that did not report 2019 UDS data had the base value of $500,000 as their funding request ceiling amount.
Could a recently designated Health Center Program look-alike apply for ARP-LAL funding?
Only look-alikes that were designated as of April 1, 2021, were eligible to apply for ARP-LAL funding.
What is the period of performance for the use of the ARP-LAL funding?
ARP-LAL funding awards have a 2-year period of performance (July 1, 2021, to June 30, 2023). Funding will be available for immediate use, and pre-award costs dating back to January 31, 2020, expended in alignment with the purpose of ARP-LAL funding, are permitted.
What was the rationale for requiring look-alikes to submit an application before receiving ARP-LAL funding?
Many look-alikes have not previously received federal funding, including a number of current look-alikes that did not apply to receive Look-Alikes: Expanding Capacity for Coronavirus Testing (LAL-ECT) funding or were not eligible to apply for LAL-ECT funding because they were designated after the LAL-ECT NOFO was released. Additionally, the ARP-LAL awards are larger and more complex than the LAL-ECT funding (for example, they include the ability to conduct minor alteration/renovation (A/R) projects). As a result of these factors, HRSA determined that the submission of applications for funding would be required prior to the awarding of grant funding. However, please note that ARP-LAL funding may be used for expenses dating back to January 31, 2020.
Could look-alikes apply for less than their maximum amount of funding?
Yes. Eligible look-alikes were able to apply for less funding than the maximum available to them if they chose. However, they were encouraged to think critically about needs within their service area and organization that align with the purpose of ARP-LAL funding over the next two years when determining their funding request.
Was the ARP-LAL funding opportunity competitive?
Yes, ARP-LAL was a competitive funding opportunity. However, HRSA made available enough funding to provide ARP-LAL awards to all active look-alikes designated by April 1, 2021. The list of look-alikes eligible to apply for this funding, along with the maximum amount of funding each look-alike could request, is available on the ARP-LAL technical assistance webpage.
Applications needed to be submitted in Grants.gov by the deadline of May 14, 2021, at 11:59 p.m. ET, and they needed to be complete, responsive to the funding requirements and purpose of the ARP-LAL funding, and to request no more than the look-alike’s maximum funding amount.
Were there factors that could prevent an application from being funded?
Organizations that were not a current look-alike designated on or before April 1, 2021 were not eligible for ARP-LAL funding. Additionally, HRSA performed a risk assessment consistent with the language included in the NOFO prior to awarding funds and determined whether an award could be made and/or if special conditions were required.
Allowed Uses of Funds
What types of COVID-19 related activities can ARP-LAL funding be used for?
ARP-LAL funding must be used for the purposes described in the ARP-LAL NOFO and the ARP-LAL Activities Plan. See the example of uses in the ARP-LAL Activities Plan on the ARP-LAL technical assistance webpage.
Are ARP-LAL funds limited to supporting only COVID-19 related activities?
ARP-LAL funding, provided by the American Rescue Plan Act of 2021, is intended to support look-alikes to respond to and mitigate the spread of COVID-19, and to enhance health care services and infrastructure. Look-alikes may use funds for any or all of the following categories (see Appendix A: ARP-LAL Activities Plan in the ARP-LAL NOFO and the sample ARP-LAL Activities Plan on the ARP-LAL technical assistance webpage for a complete list):
- COVID-19 Vaccination Capacity
- COVID-19 Response and Treatment Capacity
- Maintaining and Increasing Capacity
- Recovery and Stabilization
Can ARP-LAL funds be used to continue an activity started with LAL-ECT funding received last year?
ARP-LAL funds may not be used for activity costs already paid for by prior COVID-19 LAL-ECT funding, or other resources. However, ARP-LAL funding may support new costs to continue or expand activities initiated with your LAL-ECT award.
Can ARP-LAL funds be used to cover costs for COVID-19 testing from prior months that were not reimbursed through other programs or insurance?
ARP-LAL funding can be used for pre-award costs that support non-reimbursed expenses related to COVID-19 activities to address the COVID-19 public health emergency dating back to January 31, 2020. If you received LAL ECT (L1C) funding, continue to use that funding for the COVID-19 testing capacity purpose for which it was awarded. ARP-LAL funds may not be used for costs already paid for by L1C funding.
Can ARP-LAL funds be used for expenses dating back to January 31, 2020, if the look-alike was not designated at that time?
No. You cannot budget to use ARP-LAL funding for costs your organization incurred prior to your look-alike designation. If you were designated after January 31, 2020, funds can be used for related past costs from the time of your look-alike designation through June 30, 2023. Ensure that all past costs are clearly documented in the budget narrative and activities plan.
Since ARP-LAL funds only support in-scope activities, how can a Health Center Program look-alike determine whether a scope adjustment or change in scope is required to ensure their scope of project accurately reflects their ARP-LAL activities?
ARP-LAL funding must be used for in-scope services and sites. You must receive any necessary scope adjustment and change in scope approvals before implementing a new service, service delivery method, or site in support of your ARP-LAL project. Review the Scope of Project requirements, including information on Form 5A: Services Provided, Form 5B: Service Sites, and Form 5C: Other Activities/Locations to ensure your scope of project accounts for approved activities provided directly by the health center, through a formal written contract/agreement, or through a referral arrangement. For additional information on service delivery and temporary sites, refer to the Health Center Program COVID-19 Frequently Asked Questions. Contact the Program Contact listed on your L2C notice of award for guidance.
Can ARP-LAL funds be used to rent space, including temporary structures?
ARP-LAL funds may be used to support rent of an approved site to perform in-scope activities, including temporary structures. Refer to the Health Center Program COVID-19 Frequently Asked Questions for more information about temporary sites.
Can ARP-LAL funds be used for supplies necessary for health center personnel to participate in telehealth from their homes, such as tablets, phones, webcams, and speakers?
APR-LAL 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 the Health Center Program COVID-19 Frequently Asked Questions.
Can ARP-LAL funds be used to pay for a large equipment purchase, like a mobile unit?
Yes, ARP-LAL funds can be used to purchase mobile units. Note there is a distinction between moveable and non-moveable equipment, and the total allowable cost of $500,000 for minor A/R activities does not include moveable equipment purchases.
Can ARP-LAL funds be used to conduct COVID-19 contact tracing?
ARP-LAL 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, which would not be eligible for ARP-LAL funding. Refer to the Health Center Program COVID-19 Frequently Asked Questions for additional information.
Can ARP-LAL funds be used to support antibody testing?
Yes. ARP-LAL funding may support a wide range of testing and testing-related in-scope activities, which 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 ARP-LAL funds be used for enabling services?
Yes. ARP-LAL funds may be used to 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 ARP-LAL funds be used 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, ARP-LAL 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 ARP-LAL Activities Plan on the ARP-LAL technical assistance webpage.
Can ARP-LAL funds be used to support routine immunizations?
As indicated in the American Rescue Plan, funds may be used to modify, enhance, and expand health care services. Therefore, ARP-LAL 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 the health center’s Form 5A: Services Provided. Health centers may also use ARP-LAL 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 COVID-19 Frequently Asked Questions.
Can ARP-LAL funds be used to support early childhood health activities, such as developmental screenings?
Yes. ARP-LAL 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 ARP-LAL Activities Plan, you would write in such activities under “Other” in the corresponding category, which will most likely be Maintaining and Increasing Capacity and/or Recovery and Stabilization.
Can ARP-LAL funds be used for food for patients experiencing unemployment and/or homelessness?
ARP-LAL 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.
If a look-alike uses ARP-LAL funds for vaccine activities, can they still participate in the Health Center COVID-19 Vaccine Program?
Yes. ARP-LAL funds can be used to support activities that include, but are not limited to: vaccine ordering, distribution to administration sites, inventory management, and other activities necessary for participation in the Health Center COVID-19 Vaccine Program and/or the CDC COVID-19 Vaccination Program. Health centers interested in participating in the Health Center COVID-19 Vaccine Program must log into the Vaccine Program Online Community to submit the Conditions of Participation agreement and Readiness Assessment.
Can health centers offer incentives to patients and staff for COVID-19 vaccination, and can they use ARP-LAL 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 ARP-LAL 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 ARP-LAL grant funds to pay for incentives for COVID-19 vaccination, certain limitations apply. Specifically, ARP-LAL 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 ARP-LAL 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 planning for expenditures of ARP-LAL award funds:
- The overall purposes of American Rescue Plan (ARP-LAL) 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 ARP-LAL 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 ARP-LAL funds be used to provide child care for patients while they are waiting to be vaccinated by the health center?
Yes, ARP-LAL 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 ARP-LAL funds be used to purchase 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. ARP-LAL 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.
ARP-LAL 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
Maintaining Capacity and Personnel Support
Can ARP-LAL funds be used 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 ARP-LAL funds. Your health center may use ARP-LAL funds to cover allowable operational costs going back to January 31, 2020.
For additional information on other available resources during the COVID-19 public health emergency, refer to the Health Center Program COVID-19 Frequently Asked Questions.
Can ARP-LAL funds be used for hazard pay or a “pandemic premium”?
ARP-LAL funds may be used for hazard and premium pay only for personnel involved in COVID-19 in-scope activities, and only if you have policies and procedures in place that cover this type of hazard or premium 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.
If you do not have such policies in place, you should immediately develop and officially adopt them. You must document that you are following your organizational policy for charging salaries during unexpected and extraordinary circumstances. For additional information, refer to the Health Center Program COVID-19 Frequently Asked Questions.
In addition to ARP-LAL funding, can a Health Center Program look-alike access loans, reimbursement, and other funding sources that are available through other COVID-19 relief programs?
There are no specific funding prohibitions regarding health centers accessing loans and other economic relief programs. However, you must demonstrate distinct use (i.e., by budgeting and documenting expenditures) of funds consistent with the applicable law. You may not use ARP-LAL funds for costs that are reimbursed or compensated by other federal or state programs or resources (e.g., HRSA COVID-19 Uninsured Program, CARES Act Provider Relief Fund, Health Center COVID-19 Vaccine Program, unemployment compensation). In applying for and accepting these loans or funding, review the programs’ particular requirements to determine their eligibility, adhere to any conditions and terms, and consult with the relevant organization or agency making the loans or grants for further guidance. In addition, you must monitor expenditures from all sources to ensure compliance with the individual funding requirements, as well as with any requirements of loan agreements, and adhere to the Uniform Administrative Requirements, federal cost principles, 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, you 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 related to interruption of operations or services. For additional information on maintaining compliance with Health Center Program requirements (e.g., applicability of sliding fee, billing and collections) during the COVID-19 public health emergency, see the Health Center Program COVID-19 Frequently Asked Questions.
Minor Alteration and Renovation (A/R)
What was the maximum amount of funding that could be requested for minor A/R?
Look-alikes were able to request no more than $500,000 in funding for minor A/R expenses in total during the project period.
What types of minor A/R projects are appropriate for the ARP-LAL funding?
Minor A/R and/or equipment purchases relevant to the approved ARP-LAL activities are allowed. See more information in ARP-LAL Activities Plan on the ARP-LAL technical assistance webpage.
Can ARP-LAL funds be used to pay an architect who is a direct employee of the health center?
The preferred method for selecting an architect is to solicit for competitive bids and select the lowest responsive and responsible bid. However, some organizations may wish to accomplish this using their own work force (force account). Further information is available on the HRSA website (PDF - 26 KB)
Who should complete and sign the Environmental Information and Documentation (EID) checklist?
The authorizing official (AO) should complete and the sign the EID checklist. You are encouraged to seek consultation from a qualified professional with experience with the National Environmental Policy Act (NEPA) to fully understand the information requested and to ensure accurate responses.
What are the environmental and historic preservation requirements for minor A/R?
Information on environmental and historic preservation compliance requirements is available on the HRSA website. Although minor A/R projects typically do not require preparation of a full Environmental Assessment under the NEPA, you may need to comply with other requirements, as applicable:
- If the project involves exterior work (e.g., windows, signage) or work on a building that is over 50 years old, the project may require State Historic Preservation Office consultation under Section 106 of the NEPA.
- Buildings constructed prior to 1985 may require submission of a hazmat study and abatement plan.
- If the site is located in a coastal state, the project may require compliance with the Coastal Zone Management Act.
- If the project is in a 100 or 500-year floodplain, it may require compliance with E.O. 11988, Floodplain Management.
Is minor A/R allowed at a site that is leased?
Yes. Leasehold improvements are allowed. However, ARP-LAL funds cannot be used to address facility needs that are part of the terms of the lease (i.e., the obligation of the lessor). For minor A/R for a leased facility, you must provide a signed Landlord Letter of Consent (LLOC) from the facility owner in the Other Requirements for Sites form. See a sample LLOC on the ARP-LAL technical assistance webpage.
Is minor A/R allowed at a site that is not in scope?
No. ARP-LAL funds may only be used for sites included in your look-alike scope of project.
Can ARP-LAL funds be used for minor A/R at a site that is not currently in-scope, but is planned to be added?
You may only use up to $500,000 in ARP-LAL funds for minor A/R activities at one or more currently in-scope sites (noted on your scope of project Form 5B). You may not perform minor A/R activities at a new site until receiving HRSA approval of your change in scope request to add the site to scope. For additional information on the change in scope process, 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, or contact the Program Contact on your L2C notice of award.
Will a Notice of Federal Interest (NFI) be required for minor A/R projects completed with ARP-LAL funds?
An NFI is not required for allowable minor A/R projects, although federal interest exists for the useful life attributable to the A/R funded under this award. For information regarding federal interest, see the Federal Interest in Real Property FAQs (PDF - 500 KB).
What is included in the minor A/R project budget justification?
A budget justification is required for each site-specific minor A/R project. The budget justification must provide a detailed breakout and description of each cost element in the budget, and provide sufficient narrative detail to explain each cost. If there are additional sources of funding, clearly identify which costs will be covered by ARP-LAL funding. A sample A/R budget justification, including a list of unallowable project costs, is available on the ARP-LAL technical assistance webpage.
What were the required application components for this funding opportunity?
Application requirements and instructions are available in the NOFO and in Section 4 of HRSA’s SF-424 Application Guide (PDF - 663 KB). All eligible applications submitted to Grants.gov needed to include the standard Grants.gov forms, plus:
- Attachment 1: ARP-LAL Activities Plan
- Attachment 2: Project Narrative
- Attachment 3: Budget Narrative
For instructions and sample documents, see the ARP-LAL technical assistance webpage.
If minor A/R was proposed, what documentation needed to be submitted?
When proposing to use ARP-LAL funds for minor A/R, the following documents needed to be submitted as Attachment 5: Minor A/R Information:
- Other Requirements for Sites Form
- Minor A/R Project Budget Justification
- Environmental Information and Documentation Checklist
- Schematics and/or Floor Plans
- Property information
- Signed Landlord Letter of Consent, if applicable
For sample documents, see the ARP-LAL technical assistance webpage.