Health Resources and Services Administration (HRSA) recently issued clarification on how fund are to be used from Coronavirus Preparedness and Response Supplemental Appropriations Act 2020 (COVID-19 H8C) and Coronavirus Aid, Relief, and Economic Security Act (CARES H8D).

Background

As noted in GHJ’s earlier blogs, on March 24, 2020, HSRA announced the relates of $100 million in fiscal year 2020 funding provided by COVID-19 H8C.

On April 8, 2020, HRSA announced the release of more than $1.3 billion in fiscal year 2020 funding provided by CARES H8D.

HRSA expedited the distribution of this funding, which allowed immediate access to the funding. Subsequently, HRSA will be collecting budgets and listings of activities and costs that supports how the funding will be used.

The purpose of both awards is to:

• Respond to the COVID-19 public health emergency; and
• Maintain or increase health center capacity.

Based on language in the CARES Act, both H8C and H8D awards may be used for current payment and reimbursement of costs incurred since Jan. 20, 2020, related to the detection of SARS-CoV-2 or the prevention, diagnosis and treatment of COVID-19, including maintaining or increasing health center capacity and staffing levels during the COVID-19 public health emergency.

New Clarifications on Fund Usage

HRSA has recently shared that COVID-19 H8C and CARES H8D funds may be used to purchase supplies necessary for health center personnel to use telehealth to perform in-scope services to prevent, prepare for and respond to coronavirus, including maintaining and increasing health center capacity.

OMB memorandum M-20-17 allows the flexibility to continue service during the COVID-19 public health emergency, including the use of grant funds to purchase appropriate technologies, in accordance with the individual funding announcement requirements, the Uniform Administrative Requirements, Federal Cost Principles and Audit Requirements for HHS Awards (45 CFR Part 75) and the health center’s policies.

Conversely, COVID-19 H8C, and CARES H8D funding may not be used for food for patients experiencing unemployment and/or homelessness, unless the provision of food is specifically part of a 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.

Lastly, as a COVID-19 prevention strategy, COVID-19 H8C and CARES H8D funding may be used for temporary housing costs for patients who must be isolated at a location that does not meet the definition of a site. Funds cannot be used for long-term housing/lodging costs beyond the isolation/treatment stage. Such costs must be supported by written health center policies.

Please note, it is important for Health Centers to maintain records and documentation to substantiate the charging of salaries and other project activities costs related to interruption of operations or services. Please see the HRSA site for additional guidance.

Please reach out to GHJ’s COVID-19 Response Team if you have any questions as the firm has an experienced team of consultants specializing in cash-flow projections, strategy and operations consulting and re-organizations. We are here to assist organizations to succeed in these very challenging times.