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ForwardRyan White Program Income (In-Person)
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.
Agenda
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. | Break |
| 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 13 | 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. | Break |
| 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 |
Travel
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):
- Hilton Garden Inn - Washington DC / Georgetown (2201 M St. NW)
- Hyatt Place Washington DC/Georgetown/West End (2121 M St. NW)
- AC Hotel by Washington DC Downtown ENTER CORP/PROMO CODE e2736 (1112 19th St. NW)
Other options (located within 0.4 mi):
- Yours Truly DC Hotel – Vignette Collection by IHG (1143 New Hampshire Ave. NW)
- The St. Gregory Hotel Dupont Circle (2033 M St. NW)
- West End Washington DC, Tapestry Collection by Hilton (1121 New Hampshire Ave. NW)
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.
ADDITIONAL INFORMATION
- Prerequisites: None
- Target Audience: Ryan White (RWHAP) grantee: CEO, CFO and other finance department staff
- Advanced Preparation: None
- Program Level: All
- Delivery Method: 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).
Available Credit
- 12.80 Certificate of Attendance
Price
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:
Early Registration(Through March 25) | Regular Registration(March 26 and later) |
| $1,799 | $1,999 |
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 |
| 10% off | 15% off | 20% off | Call us! |
Registration Instructions
Each registration must be in the name of the individual(s) who will attend. This allows us 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 training@feldesman.com to complete group registration
If you encounter problems or have questions contact us.
Payment Policy
We accept the following forms of payment: American Express, Mastercard, Visa, ACH, PayPal, electronic check, and check. For information about the methods of payment we accept, please review our Payment FAQs.
Refunds/Cancellations
Review our Cancellation Policies.
Can I transfer from in-person to the virtual classroom?
You can transfer from attending in-person to virtually according to the following schedule:
- Within 45 days of the event start date, transfers from in-person to virtually will be subject to a transfer fee.
- Within 14 days of the event start date, no transfers from in-person to virtual will be permitted.
Please note that no refunds of the price difference, if any, will be given. All cancellation or transfer requests must be received in writing at training@feldesman.com.