Ryan White Program Income

Washington, DC US
June 12, 2024 to June 13, 2024
Federal Grant Training Membership subscribers receive a 15% discount on the training fee. For more information, contact us.

The Health Resources and Services Administration (HRSA) HIV/AIDS Bureau (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
  • Permissible and impermissible uses of RWHAP program income

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.

Firm partner Scott Sheffler and guest speaker Jason Reddish 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.

Target Audience

Ryan White (RWHAP) grantee:

  • CEOs
  • CFOs
  • Other Finance Department Staff

Learning Objectives

After this training, you will be able to:

  • Identify what constitutes program income under a federal grant, including income related to 340B drugs.
  • Describe the limitations applicable to RWHAP program income.
  • Understand the requirements for properly accounting for program income.
  • Discuss strategies for expenditure of program income generated through RWHAP activities.
Course summary
Course opens: 
Course expires: 
Event starts: 
06/12/2024 - 10:00am EDT
Event ends: 
06/13/2024 - 5:30pm EDT


Virtual Classroom or Washington, DC
Wednesday, June 12, 2024 - Thursday, June 13, 2024
*All times in ET and are subject to change*

Day 1

Wednesday, June 12
10:00 a.m. - 5:30 p.m. ET
10:00 - 10:30 a.m.Welcome and Overview
10:30 - 11:45 a.m.
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.
11:45 a.m. - 12:00 p.m.Break
12:00 - 1:00 p.m.
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.
1:00 - 2:00 p.m.
2:00 - 3:30 p.m.
Part 2: 340B Program
Discuss the 340B Program, limitations on eligibility, and coordination among federal funding streams that confer 340B eligibility.
3:30 - 3:45 p.m.Break
3:45 - 5:30 p.m.Part 2: 340B Program (Continued)

Day 2

Thursday, June 14
10:00 a.m. - 5:00 p.m. ET
10:00 - 11:30 a.m.
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.
11:30 - 11:45 a.m.Break
11:45 a.m. - 12:30 p.m.
Part 3: RWHAP Program Income Uses and Reporting (Continued)
12:30 - 1:30 p.m.Break
1:30 - 2:00 p.m.
Budget Exercise
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.
2:00 - 3:00 p.m.
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.
3:00 - 3:15 p.m.
3:15 - 4:45 p.m.
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.
4:45 - 5:00 p.m.Q&A and Wrap-Up
Feldesman Training Solutions Center
1129 20th Street NW
Suite 300
Washington, DC 20036
United States
+1 (855) 200-3822

We have preferred rates with the following hotels (located within 0.3 mi). Use the links to book direct (Hilton and Hyatt don't require adding an additional code): 

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Scott Sheffler

Scott Sheffler is a Partner with the firm in the Federal Grants and Health Care practice groups. He 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]

Jason Reddish

Jason Reddish is a Principal at Powers Pyles Sutter & Verville PC where he specializes in the federal 340B drug discount program and the intricate legal and compliance matters encountered by safety net providers, pharmacies, and other stakeholders involved in the 340B program. 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.

Participants can earn up to 12.80 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.


  • Prerequisites: None 
  • Target Audience: Ryan White (RWHAP) grantee: CEO, CFO and other finance department staff
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based/Group-Live

Feldesman Leifer LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).

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Training is Not Recorded

This training will not be recorded for later viewing, as we would like attendees to be comfortable and candid, sharing their experiences and asking scenario-based questions. The discourse between the attorneys and participants is a valued part of each training.

Registration Fees

In-Person Registration
Early Registration
(Through March 25)
Regular Registration
(March 26 and later)
Virtual Registration
Early Registration
(Through March 25)
Regular Registration
(March 26 and later) 

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