Ryan White Program Income
The Health Resources and Services Administration (“HRSA”) HIV/AIDS Bureaus (“HAB”) has issued a considerable amount of guidance regarding program income over the past two years. That guidance has addressed HAB treatment of “340B program income,” attribution of program income among federal projects when grantees have multiple funding streams, and permissible and impermissible uses of RWHAP program income. FTLF attorneys Jason Reddish and Scott Sheffler combine their experience in 340B, federal grant management, and cost allocation to detail and explain HAB’s issuances, and discuss strategies for navigating these requirements. One of the problems grantees face with HAB’s guidance is that, while conceptually straight forward, it can be very difficult to apply to complex health care operation. This two day dive into this critical issue will include practical application of these requirements to real world scenarios, and discussion of strategies for successfully managing, and properly expending, one’s program income.
Ryan White (RWHAP) grantee:
- Other Finance Department staff
- Understand what constitutes program income under a federal grant, including income related to 340B drugs.
- Understand the limitations applicable to RWHAP program income.
- Learn requirements for properly accounting for program income.
- Discuss strategies for expenditure of program income generated through RWHAP activities.
Wednesday, Sept. 19, 2018
8:30 am - 4:30 pm
|8:30 am - 9:00 am
|Registration & Continental Breakfast
|9:00 am - 9:15 am
|Welcome and Introductions
|9:15 am - 10:30 am
Part 1: Grants Management and RWHAP
Discuss the legal system and requirements underlying federal grant awards, in particular financial management, cost allowability, and cost allocation issues that impact federal grant expenditures. Issues include the concept of “scope of project,” and the role of the grant budget.
|10:30 am - 10:45 am
|10:45 am - 12:00 pm
Part 1: Grants Management and RWHAP (Continued)
Discuss and describe the four primary RWHAP “Parts” (A through D), including the structure of the program and key entities. We will also discuss other common federal funding streams impacting RWHAP recipient operations, such as STD and Section 330 funding.
|12:00 pm - 1:00 pm
Lunch provided by FTLF
|1:00 pm - 3:00 pm
Part 2: 340B Program
Discuss the 340B Program, limitations on eligibility, and coordination among federal funding streams that confer 340B eligibility.
|3:00 pm - 3:15 pm
|3:15 pm - 4:30 pm
Part 3: RWHAP Program Income Uses and Reporting
Discuss federal grant management concepts and requirements related to “program income,” HAB’s application of these requirements to 340B-related revenue, HAB’s interpretations and guidance regarding uses of program income, and strategies for using RWHAP program income.
Thursday, Sept. 20, 2018
8:30 am - 3:30 pm
|8:30 am - 9:00 am
|9:00 am - 10:30 am
Part 3: RWHAP Program Income Uses and Reporting (Cont. from Day 1)
|10:30 am - 10:45 am
|10:45 am - 11:15 am
Evaluate RWHAP budgeting issues through examination of a hypothetical RWHAP Part C Budget, including issues related to overlapping RWHAP Part C and Part A/B/D grant projects.
|11:15 am - 11:30 am
|11:30 am - 12:30 pm
Part 4: Program Income Attribution
Review HAB guidance on PI tracking and “attribution.” Discuss various concepts for PI attribution, and complications that can arise in differing scenarios as programs become more complex.
|12:30 pm - 1:30 pm
Lunch provided by FTLF
|1:30 pm - 2:00 pm
Los Angeles County Dept. of Public Health, DAB No. 2842 (2018)
Discuss recent Department of Health and Human Services Departmental Appeals Board (DAB) decision sustaining a Health Resources and Services Administration (HRSA) disallowance of approximately $5 million, where the primary underlying issue was inadequate cost allocation methodologies of a large RWHAP Part A subrecipient.
|2:00 pm - 3:30 pm
Program Income Attribution Exercise
Participants will be asked to outline their current organizations and apply the principles we have discussed over the preceding day-and-a-half to attribution of program income. Groups will discuss their proposed approaches and how they addressed challenges faced by their particular circumstances.
Hyatt Place Washington DC/Georgetown/West End
The Wink - Washington, DC
Kimpton Hotel Palomar DC
The St. Gregory Hotel - Dupont Circle
Kimpton Hotel Madera
The Embassy Row Hotel
The Dupont Circle Hotel
Hilton Garden Inn - Washington DC/Georgetown Area
Embassy Suites - Georgetown
As of June 2023, Jason Reddish is no longer with the firm.
Jason focuses his practice on the federal 340B drug discount program and the complex legal and compliance issues facing safety net providers, pharmacies, and other 340B program stakeholders. Jason began his career representing pharmaceutical manufacturers before finding his passion helping 340B program covered entities, including disproportionate share hospitals, Federally Qualified Health Centers, Ryan White HIV/AIDS clinics, and other grantees navigate the 340B program. [Full Bio]
A Partner with the firm in the Federal Grants and Health Law practice groups, Scott advises clients on matters of federal grant law, government contract law, and health care law. Scott assists clients with the myriad requirements that apply upon acceptance of federal grant funding, including the administrative requirements and cost principles established in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the Office of Management and Budget (OMB) Circulars that preceded the Uniform Guidance, and program-specific statutory and regulatory funding conditions. [Full Bio]
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