FY 2022 OVC Frequently Asked Questions

Updated 12/13/2021

• General Information
• Budget
• Allowed Use of Funds
• Application Components
• Resources

Introduction

The OVC notice of funding opportunity is the primary guidance for your OVC application. Additional technical assistance resources are available on the OVC technical assistance webpage.

General Information

How can I access the OVC NOFO and application package?

Follow the instructions below:

• Go to grants.gov
• Search Grants using Opportunity Number HRSA-22-097
• Click the Opportunity Number link (HRSA-22-097)
• Click the Package tab (rightmost tab)
• Under Actions, click on Preview
  • Click the Download Instructions gray bar for the NOFO
  • Click the links to view the forms to be submitted in Grants.gov
• Click the APPLY button to use the Grants.gov Workspace to apply

(Added: 5/17/2021)

Can I apply if I have recently started to provide telehealth services?

Yes. However, applications that demonstrate a strong foundation of delivering high quality, patient-centered care via telehealth are likely to score higher through objective review. Applications will be reviewed based on demonstrated capacity to systematically design, implement, and evaluate ways to optimize the use of virtual care, which includes experience using virtual tools to increase access to comprehensive, patient-centered care and experience with health information technology (IT) interoperability and rapid cycle quality improvement to support success of the project.

(Added: 5/17/2021)

Will OVC funding continue beyond the two-year period of performance?

No. This is a one-time funding opportunity in which applicants may request up to a total of $2,000,000 to be used throughout a two-year period of performance.

(Added: 5/17/2021)

Budget

How should I present my OVC funding request on the budget form and budget narrative attachment?

All OVC funding will be awarded in FY 2022, so you will request the total funding needed (i.e., max of $2,000,000 over two years) on the SF-424A form. You will show how you plan to use the funding in each year of the two-year period of performance in the Budget Narrative (e.g., Year 1 budget $1,250,000 + Year 2 budget $750,000 = $2,000,000 total).

(Added: 5/17/2021)

How do I determine the appropriate proportions to distribute the budget across CHC, MHC, HCH, and PHPC funding sub-programs?

If your H80 award is funded through more than one sub-program/population type (Community Health Center = CHC, Migrant Health Center = MHC, Health Care for the Homeless = HCH, and/or Public Housing Primary Care = PHPC), you will need to distribute your budget proportionally. If you have questions about the appropriate sub-program amount, contact the OVC technical assistance team using the BPHC Contact Form. Select “Health Center” on Question screen, “Applications” for BPHC Category and "Optimizing Virtual Care (OVC)” for Sub-category.

(Added: 5/17/2021)

Should I include contractors on the Personnel Justification Table?

Yes. You must include on the Personnel Justification Table all direct hire and contractual personnel that you propose to support with OVC funding. The annualized salary and FTE must be included, along with the federal amount requested. For more information, see the sample Budget Narrative on the OVC technical assistance webpage.

(Added: 5/17/2021)

Allowed Use of Funds

Can health centers use OVC 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. OVC 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.

OVC 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
• Centers for Medicare & Medicaid Services 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

(Added: 12/13/2021)

Can I use OVC funding to increase full time equivalents (FTEs) of existing personnel?

OVC funding may be used to compensate personnel with a commensurate increase in FTE, in alignment with your existing written policies and procedures and 45 CFR §75.430. However, keep in mind that OVC awards are one-time funding, and salaries may not exceed 100 percent across all federal awards.

(Added: 5/17/2021)

Can I use OVC funding to reimburse my health center for revenue lost when a provider is participating in an OVC-supported activity, such as participation in learning collaborative meetings?

No. OVC funding may not be used to offset lost revenue or productivity. However, you may use OVC funding to support a substitute provider who provides temporary clinical services in the absent provider’s place.

(Added: 5/17/2021)

Can I use OVC funding for minor alteration and renovation (A/R) costs?

Yes. You may request no more than $500,000 for equipment purchases and minor A/R costs combined. An allowable minor A/R project must be a stand-alone project consisting of work in an existing site in scope required to modernize, improve, and/or reconfigure the interior arrangements or other physical characteristics of a facility that is necessary to implement or optimize the use of virtual care. For a minor A/R activity, the total federal and non-federal cost of the site-specific project must be less than $500,000, excluding the cost of moveable equipment. See the OVC technical assistance webpage for guidance on the required minor A/R forms and attachments.

(Added: 5/17/2021)

Are costs to ensure the security of data transmitted by Bluetooth and wireless-enabled devices allowed?

Yes. You are responsible to protect the confidentiality, integrity, and availability of personal health information, including safeguarding data from accidental and intentional disclosure. Detailed resources are available in the Office of the National Coordinator for Health Information Technology Health IT Playbook Chapter 7: Privacy & Security. You may use funds to support the safety of patient data, including servers, firewall protection software, and training for personnel and patients on topics such as proper use of devices and patient portals, security of passwords, and available data safety features.

(Added: 5/17/2021)

Are costs to support sufficient internet access for patients allowed?

You may use funds to support patients’ use of connected consumer medical devices, such as hot spots and facilitating the enrollment of individuals in the Federal Communication Commission’s (FCC) Lifeline and Emergency Broadband Benefit subsidy programs. If you choose to use funds for this purpose, you must provide detail in your budget narrative and maintain records describing how you determined the necessity of this cost.

(Added: 5/17/2021)

Are OVC awards subject to telecommunications and video service and equipment prohibitions?

Yes. Federal Register Notice (FRN) 85 FR 49506 prohibits you from procuring or contracting to procure certain telecommunications or video surveillance equipment or services produced by Huawei Technologies Company, ZTE Corporation, Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, and Dahua Technology Company, as well as their subsidiaries and affiliates. Additional information is provided in the FRN and will be included in the Notice of Award.

(Added: 5/17/2021)

Can I purchase or upgrade an Electronic Health Record (EHR) with OVC funding?

Yes. However, you cannot use funds for an EHR that is not certified by the Office of the National Coordinator for Health Information Technology (ONC). For more information, see the Certified Health IT Product List.

(Added: 5/17/2021)

Application Components

How do I complete the SF-424 submitted in Grants.gov?

See the Application for Federal Assistance (SF-424) form instructions. The table below includes information on how to respond to specific sections:

Application for Federal Assistance SF-424

Box Number	Question	Response
1	Type of Submission	Application
2	Type of Application	New
3	Date Received	Completed automatically in Grants.gov
4	Applicant Identifier	Enter your H80 number (not required)
5a, 5b	Federal Entity Identifier, Federal Award Identifier	Leave blank
12	Funding Opportunity Number	HRSA-22-097
14	Areas Affected by Project	Leave blank
15	Descriptive Title of Applicant’s project	“Optimizing Virtual Care”
16	Congressional Districts	Include the congressional district for your main site. The attachment is not required.
17	Proposed Project	The project period is March 1, 2022 to February 29, 2024
18	Estimated Funding ($)	Enter amount of OVC funding requested in a. Federal box (up to $2 million)
19	Is Application Subject to Review Under Executive Order 12372 Process?	Select a. if your state is included in the SPOC list (PDF - 332 KB) (PDF - 61 KB). If not, select b. Program is subject to E.O. 12372 but has not been selected by the State for review.

(Added: 5/17/2021)

If I have multiple sites, do I list them all on the Project/Performance Site locations form?

No. Only include the primary service site where your OVC project will be implemented on the Project/Performance Site Locations form in Grants.gov.

(Added: 5/17/2021)

On the Project Overview form, what visit data do I provide for 2020?

Include the number of face-to-face (in-person) clinic and virtual visits for all services included in your 2020 UDS report (i.e., for the entire 2020 calendar year). Your 2019 data will prepopulate based on your H80 grant number. Percentages will auto-calculate in EHBs.

(Added: 5/17/2021)

How do I determine if my OVC project will require a change in scope? Can I make changes to my scope of project through the OVC application?

The scope of project webpage provides technical assistance materials to help you evaluate your scope of project. If needed, you must request a change in scope (CIS) or scope adjustment outside of the OVC application. Contact your project officer for guidance in determining if a scope adjustment or formal CIS will be necessary.

(Added: 5/17/2021)

Can we provide telehealth services to a patient at a location that is not an in-scope service site?

Based on Health Center Program scope of project, you may provide services to a patient at a location that is not an in-scope service site if:

• The service being provided via telehealth is within the health center’s approved scope of project (recorded on Form 5A).
• The clinician delivering the service is a health center provider working on behalf of the health center; and
• The individual receiving the service is a health center patient.

You should consult with professional organizations, regulatory bodies, and private counsel to ensure that your written telehealth policies are compliant with standards of practice, Health Center Program requirements, and other federal, state and local requirements.

Review PAL 2020-01: Telehealth and Health Center Scope of Project (PDF - 176 KB) for more information. For questions about FTCA coverage, use the BPHC Contact Form or call for FTCA assistance at 877-464-4772.

(Added: 5/17/2021)

Do I need to complete an Equipment List form for each year that I request OVC funds to purchase equipment?

No. Include equipment on one form for the entire two-year period of performance.

(Added: 5/17/2021)

Why are both a work plan and logic model required?

The logic model and work plan go hand-in-hand to outline your OVC project. Your logic model should guide the development of the work plan that will include key action steps to reach your project goals. For each activity identified in your logic model, your work plan must include key action steps, person(s) responsible, and time frame. See the OVC technical assistance webpage for guidance on the required logic model and work plan components.

(Added: 5/17/2021)

Resources

Does the Health Insurance Portability and Accountability Act (HIPAA) apply to virtual care services?

Yes. Health centers are covered entities under HIPAA. You must take steps to ensure the privacy of patients and clinicians using virtual care technologies and the confidentiality of information transmitted electronically, in compliance with HIPAA and other federal and state privacy and confidentiality regulations. For more information, see the Telehealth Resource Center HIPAA and Telehealth Guide and the HHS Health Information Privacy webpage.

(Added: 5/17/2021)

Can health centers have a separate sliding fee discount schedule for services provided via telehealth that differs from that used for the same service(s) provided in person?

Health centers may not have a separate sliding fee discount schedule for telehealth. However, where the locally prevailing charges or the actual costs for services delivered via telehealth differ from those delivered in person, health centers may have different charges on a fee schedule. For example, if the cost of providing a primary health care visit through telehealth is less than an in person visit, the health center may establish a separate, lower charge for the telehealth primary care visit on the fee schedule. The health center would then apply their sliding fee discount schedule to the charge for the telehealth visit, which would be the same sliding fee discount schedule applied to an in-person primary care visit. For more information, see Health Center Program Billing and Collections requirements.

(Added: 5/17/2021)

What resources are available to help me with my application?

See the Additional Resources section of the OVC technical assistance webpage for links to several websites that offer technical assistance, tools, and other resources, including the CMS webpage From Coverage to Care telehealth resources. Contact information is also provided for program and budget questions, Grants.gov support, and EHBs technical issues.

(Added: 5/17/2021)

Are there resources available on state Medicaid coverage for telehealth services?

Medicaid coverage for telehealth services varies by state. The Center for Connected Health Policy (a National Telehealth Resource Center) has published a summary of state telehealth responses to COVID-19, including Medicaid coverage. For additional Medicaid information, please visit the Medicaid telemedicine webpage and the COVID-19 resources for state Medicaid and CHIP agencies.

(Added: 5/17/2021)

How should I use OVC funding to implement evidence-based strategies while also achieving innovation?

The innovations pursued with OVC funding should be founded on data-informed and evidence-based strategies. Your OVC activities should apply or adapt evidence-based strategies in new and innovative ways, such as to address the needs and access barriers of your patient populations, leverage your organization and community partners’ capacities, and expand digital health, patient engagement and clinical interventions. Additionally, innovations may support enhancing your current workflows, outreach plans, collaborations with partners, data collection and use, and clinical management to optimize your use of virtual care.

Your evidence-based strategies can focus on both telehealth and how you implement your strategies. For example, the Agency for Healthcare Research and Quality includes examples of evidence-based strategies and innovations in their Telehealth Resources and Tools and Resources for Practice Transformation and Quality Improvement. The National Consortium of Telehealth Resource Centers also provides evidence-based tools such as the Rural Telehealth Toolkit.

(Added: 7/9/2021)