Ryan White Program Income (Virtual)

January 30, 2023 to January 31, 2023

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.

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.

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
Available credit: 
  • 11.00 Certificate of Attendance
  • 12.80 CPE
    FTLF 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.
Course opens: 
Course expires: 
Event starts: 
01/30/2023 - 10:00am EST
Event ends: 
01/31/2023 - 4:30pm EST


FTLF Virtual Classroom
Monday, January 30 - Tuesday, January 31, 2023
*Agenda times are all ET and subject to change*

Day 1

Monday, January 30, 2023
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

Tuesday, January 31, 2023
10:00 a.m. - 5:00 p.m. ET
10:00 - 11:45 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.
11:45 a.m. - 12:00 p.m.Break
12:00 - 12:45 p.m.
Part 3: RWHAP Program Income Uses and Reporting (Continued)
12:45 - 1:45 p.m.Break
1:45 - 2:30 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.
2:30 - 3:15 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.
3:15 - 3:30 p.m.
3:30 - 5:00 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.


This live, interactive training will take place in FTLF's Virtual Classroom, hosted by Zoom.  Should you have any technical questions or would like more information, please contact us at learning@ftlf.com or 1-855-200-3822.


Jason, a Partner with the firm, 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]

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, Other Finance Department Staff
  • Advanced Preparation: None  
  • Program Level: All
  • Delivery Method: Group Internet Based

Feldesman Tucker Leifer Fidell 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).

Available Credit

  • 11.00 Certificate of Attendance
  • 12.80 CPE
    FTLF 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.


Please login or register to take this course.


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.


Early Registration
(Through November 30)
Regular Registration
(December 1 and later)

Group Discounts

Bring your team! Discounts are available for groups of three (3) or more individuals from the same organization. Please contact us to process your registration.

Groups of 3 - 6
Groups of 7 - 10
Groups of 11 - 15
Over 15 attendees
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Registration Instructions

Each registration must be in the name of the individual(s) who will attend. This allows FTLF to communicate important course information to the actual attendee(s), add training materials and handouts to the right account, and properly assign certificates of attendance or CPE credits. 

To register for this training:

  • For yourself: login to your account and register with your personal information
  • For someone else: login with the ATTENDEE’S login information or create an account for the ATTENDEE and register from the ATTENDEE's account
  • For a group: email Learning@ftlf.com to complete group registration

If you encounter problems or have questions Contact us.


We accept payment by PayPal, credit card, and check. Payment for any live training is due upon registration. If payment is not received in full prior to the start of the event, FTLF reserves the right to cancel your order and deny you entrance to the training.

Cancellation/Transfer Policy

All cancellation or transfer requests must be received in writing at learning@ftlf.com. Requests for refunds or transfers for in-person events will be granted according to the following schedule:

  • 30 or more days prior to the event, requests for a full refund or a transfer, minus a $75 administrative fee, will be granted.
  • Between 11 to 29 days prior to the event, requests for cancellations will be granted a 50% refund and requests for transfers will be granted, space permitting and subject to a transfer fee.
  • Within 10 days of the event start date, no requests for refunds or credits will be granted. At FTLF's discretion, late transfers may be granted, space permitting and subject to a transfer fee.

If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at learning@ftlf.com.


Yes, you can transfer to attend in-person, providing there is an open seat.  Any additional registration cost is due at the time of transfer.  All transfer requests must be submitted in writing.

If there are extenuating circumstances regarding your cancellation, please reach out to the FTLF Training Team directly at learning@ftlf.com.

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