Defining Scope of Project & Policy for Requesting Changes, Process

V. PROCESS FOR CHANGE IN SCOPE OF PROJECT REQUESTS

All grantees considering a change in scope are encouraged to carefully review this PIN prior to initiating a request. In considering a change in scope, all grantees should review the proposal with their Board of Directors and consult with their Project Officer.

A. Mechanism to Submit Requests for Prior Approval

An electronic process through HRSA 's Electronic Handbook (EHB) has been developed for obtaining prior approval for the five types of change in scope of project requests requiring prior approval (see Change in Scope Requests that Require Prior Approval). The EHB is designed to streamline the grants administration process and enable grantees to communicate with HRSA and conduct activities electronically. The EHB can be accessed from anywhere on the Internet using a standard web browser, https://grants.hrsa.gov/webexternal. When a grantee initiates a change in scope request, the EHB will assign a tracking number. Grantees may create and submit a change in scope request in one session, or create and save part of a request, using the assigned tracking number to return as many times as necessary to complete the request before submitting it for HRSA review. 

B. Change in Scope Determinations and Timeline

Because of the importance of scope of project, it is expected that grantees will request prior approval at least 60 days in advance of their desired implementation date for changes in scope for service delivery sites and services provided. There may be circumstances where submitting a change in scope request early may not be possible; however, the goal is to minimize these occurrences through careful planning. Timely submission of a change in scope request is important to ensure Medicaid and Medicare FQHC reimbursement, FTCA coverage, and 340B Drug Pricing benefits for the specific site/service, as appropriate.

If additional information or clarification is needed, the Project Officer will notify the grantee of the deficiencies of the request through the EHB, and the grantee will be given 60 days to provide the additional information. If the requested information is not provided by the grantee by the end of 60 days, the change in scope request will be denied and the grantee will be notified of this decision through the EHB. If a request is denied, the grantee will have to submit a new request for prior approval in order to implement the change in scope.

Due to the varying complexity of requests, in some cases it may be necessary to extend the HRSA review period if additional analysis, such as an on-site consultation, is warranted. In those cases, the grantee will be notified through the EHB within the initial 60 day review period of the potential delays in processing the request.

HRSA will indicate the final decision within 60 days of a complete change in scope request in one of the following two ways:

    1) Notice of Grant Award (NGA) indicating approval; or

    2) an email through EHB indicating disapproval.

PIN 2009-03 changed the timelines for the determination of Change in Scope Requests and is available at Technical Revision to PIN 2008-01. 

C. Effective Date of Approval

The effective date of an approved change in scope will be no earlier than the date of receipt of a complete request for prior approval. In cases where a grantee is not able to determine the exact date by which a change in scope (i.e., adding a site or service) will be fully accomplished, grantees will be allowed up to 120 days following the date of the NGA indicating approval for the change in scope to implement the change (e.g., open the site or begin providing a new service). Therefore, grantees should carefully consider their ability to accomplish the requested change within this anticipated timeframe prior to submitting a request. If a grantee does not or is unable to implement the requested change in scope within 120 days of approval, the grantee must immediately notify the Project Officer in writing with an appropriate justification for the unanticipated delay and a detailed plan for completing the requested scope change. The BPHC will consider, on a case by case basis, exceptions to the 120 implementation requirement only if the grantee provides sufficient and compelling justification of the unique and unavoidable circumstances that will prevent the grantee from meeting this expectation.

As a reminder, all grantees should ensure that any application for Federal support documents the total scope of project and all activities added through an approved change in scope of project during the preceding budget period.

next: Additional Scope of Project Policy Issues

Date Last Reviewed:  August 2018