If you have a question that is not addressed by these FAQs, by the ARP-NH notice of funding opportunity (NOFO), or on the ARP-NH technical assistance webpage, please submit it through the BPHC Contact Form:
- Choose the Requester Type – click on Applicant.
- Choose the Question Type – click on Health Center.
- Choose the BPHC Category – click on Applications.
- Choose the BPHC Sub Category – click on Native Hawaiian Health Care Improvement Act (NHHCIA).
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
- Minor Alteration and Renovation (A/R)
- Application Components
- Reporting Requirements
Funding Purpose and Methodology
What are the purpose and allowed uses of ARP-NH funding?
On Friday, August 13, HRSA awarded $20 million in one-time grant funding to current NHHCIA award recipients. The purpose of the ARP-NH funding is to respond to and mitigate the spread of 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.
Who was eligible to apply for ARP-NH funding?
Only Papa Ola Lokahi (POL) and Native Hawaiian Health Care Systems (NHHCS) certified by POL could apply. Eligible organizations are listed on Table 1 of the NOFO, available on the ARP-NH technical assistance webpage.
Why was ARP-NH funding issued through separate grants?
To support tracking of coronavirus-related spending throughout the government, supplemental awards were issued separately from a Native Hawaiian Health Care Improvement Act (NHHCIA) award recipient’s (H1C) grant award, with the new activity code H2C. ARP-NH award recipients will need to separately track and account for their H2C activities supported through this funding.
What is the period of performance for the use of ARP-NH funding?
The period of performance is 2 years for these one-time supplemental awards, from August 1, 2021, through July 31, 2023. Pre-award costs are permitted to support coronavirus-related expenses dating back to January 31, 2020.
Has the NHHCIA non-federal match requirement been waived for the ARP-NH funding opportunity?
Yes, the NHHCIA matching requirement that typically applies to NHHCS is waived for ARP-NH funding.
How can ARP-NH award recipients access this funding?
Funds will be available for draw down in the Payment Management System as of the start date of the period of performance: September 1, 2021. On or after that date, recipients can go into the Payment Management System to add this new award (H2C) and to draw down funds from the account number to recompense any expenditures or in advance of immediate expenditures.
Allowed Uses of Funds
Can ARP-NH funds be used to support early childhood health activities, such as developmental screenings?
Yes. ARP-NH 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. Refer to the ARP-NH Activities Plan Example, available on the ARP-NH technical assistance webpage, for example uses of funds. Early childhood health activities are included in the ARP-NH Activities Plan Example under Other Activities.
Can NHHCS offer incentives to patients and staff for COVID-19 vaccination, and can they use H2C funds to pay for these expenditures?
NHHCS 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.
NHHCS may also use H2C 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 NHHCS chooses to use H2C grant funds to pay for incentives for COVID-19 vaccination, certain limitations apply. Specifically, H2C 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 NHHCS policies or procedures. If you choose to include incentive costs in your H2C 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 H2C budgets and planning for expenditures of these funds:
- The overall purposes of American Rescue Plan (H2C) funding are to prevent, mitigate, and respond to COVID-19 and to enhance health care services and infrastructure.
- NHHCS, 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 NHHCS considering incentives for vaccination (using either non-grant funds, in-kind contributions, or H2C 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, NHHCS 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 NHHCS use H2C funds to provide child care for patients while they are waiting to be vaccinated by the NHHCS?
Yes, H2C funds may be used for costs related to maintaining, enhancing, or increasing enabling/facilitating services, including providing limited care for the children of parents/guardians who present for COVID-19 vaccination.
Minor Alteration and Renovation (A/R)
Is the $500,000 minor A/R threshold limited to one site?
You may use up to $500,000 in ARP-NH funding for minor A/R projects that align with the purpose of this funding. Minor A/R may occur at one or more sites in your H1C scope of project, but the $500,000 minor A/R threshold is for all in-scope site-specific projects (not per site).
Can minor A/R activities be proposed post-award?
If you plan to use funding for minor A/R projects, you needed to request minor A/R funding in your ARP-NH application. Minor A/R forms underwent HRSA review, and if information was missing or unclear, HRSA conditioned awards to obtain additional information, based on review of the following documents included in the application:
- Minor A/R project budget justification;
- Other Requirements for Sites form;
- The Environmental Information and Documentation (EID) checklist; and
- Floor plans/schematics (your emergency exit diagram may be sufficient).
If you lease a facility proposed for a minor A/R project, you also needed to provide a landlord letter of consent. Refer to the minor A/R resources available on the ARP-NH technical assistance webpage for guidance and example forms.
What types of minor A/R projects are appropriate for the ARP-NH funding?
Examples of minor A/R projects include repaving an existing parking lot, purchasing and installing a new HVAC system, or converting a current storage space into an exam room. See more examples in the Infrastructure: Minor Alteration/Renovation (A/R), Mobile Units, and Vehicles section of the ARP-NH Activities Plan Example on the ARP-NH technical assistance webpage.
The NOFO indicates that ARP-NH funds may not be used for activities that meet the definition of construction. What are examples of those unallowable construction costs?
Unallowable construction activities include but are not limited to those that:
- Increase the size of a building;
- Construct new buildings or structures;
- Install pre-fabricated buildings;
- Pave new parking lots; or
- Cause significant ground disturbance.
See the ARP-NH NOFO (HRSA-21-116) for additional details regarding unallowable construction activities. For further questions regarding allowable construction costs, contact the technical assistance team through the BPHC Contact Form.
Would the cost of a mobile unit be part of the minor A/R threshold of $500,000?
A mobile unit is considered equipment, not minor A/R, so it would not count toward the $500,000 limit on federal minor A/R costs.
Can an ARP-NH applicant use its own staff to undertake minor A/R work instead of a contractor?
The preferred method for accomplishing minor A/R projects is to solicit proposals through a competitive bid process consistent with 45 CFR §75.326 – §75.333. However, you may consider using their own work force (force account) if you can demonstrate that it would be cost effective and that qualified personnel are available to accomplish the work. You will need to provide the following information to HRSA for review:
- Justification for accomplishing the construction work by force account rather than by contract;
- Estimate of force account costs based on expected work hours, hourly rates, and non-salary costs;
- Estimate of contract construction costs based on typical items of work, quantities of work, and estimated unit prices;
- Summary cost comparison between using force account and contract construction;
- Names and qualifications of personnel to be used on the force account;
- Your statement concerning personnel capability to perform the various tasks of design, supervision, inspections, and testing as required for the intended project work;
- Your statement on the availability of personnel to integrate the project into their normal workload; and
- Schedule identifying critical tasks and dates for when each task will be completed.
Additional information related to force account labor is available from BPHC.
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 National Environmental Policy Act (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 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.
For sample minor A/R documents, see the ARP-NH technical assistance webpage.
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 NEPA to fully understand the information requested and to ensure accurate responses.
Is minor A/R allowed at a site that is leased?
Yes. Leasehold improvements are allowed. However, ARP-NH 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 at a leased facility, you must submit a signed Landlord Letter of Consent (LLOC) from the facility owner. See a sample LLOC on the ARP-NH technical assistance webpage.
Will a Notice of Federal Interest (NFI) be required for minor A/R projects completed with ARP-NH funds?
An NFI is not required for minor A/R projects, although federal interest exists for the useful life attributable to the minor A/R funded under ARP-NH. For information regarding federal interest, see the Federal Interest in Real Property FAQs (PDF - 500 KB).
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. All eligible applications submitted to Grants.gov needed to include the standard Grants.gov forms, plus:
- Attachment 1: ARP-NH Activities Plan or Work Plan;
- Attachment 2: Project Narrative; and
- Attachment 3: Budget Narrative.
Additional attachments were as applicable. For instructions and sample documents, see the ARP-NH technical assistance webpage.
If minor A/R was proposed, what documentation needed to be submitted?
When proposing to use ARP-NH 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;
- EID checklist;
- Schematics and/or floor plans;
- Property information; and
- Signed LLOC, if applicable.
What was included in the minor A/R project budget justification?
A budget justification was required for each site-specific minor A/R project. The budget justification needed to provide a detailed breakout and description of each cost element in the minor A/R budget, and provide sufficient narrative detail to explain each cost. If there are additional sources of funding, the document needed to clearly identify which costs will be covered by ARP-NH funding. A sample A/R budget justification, including a list of unallowable project costs, is available on the ARP-NH technical assistance webpage.
What are the reporting requirements for ARP-NH award recipients?
All award recipients will provide quarterly progress reports in HRSA’s Electronic Handbooks that will describe the status of activities and use of funds. Submissions related to minor A/R activities may be included, as applicable.
Additionally, the annual data reporting requirement for NHHCS will be updated to ensure reporting on, at a minimum, the following metrics:
- Number of COVID-19 vaccinations completed, including by race and ethnicity;
- Number of COVID-19 tests, including by race and ethnicity;
- Number of patients screened for social determinants of health;
- Number of NHHCS patients/visits, including those receiving COVID-19 treatment;
- Number and type of virtual care visits;
- Number of enabling services patients; and
- Number of new mobile units.