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  6. Frequently Asked Questions for Fiscal Year 2022 CPF/CDS Recipients

Frequently Asked Questions for Fiscal Year 2022 CPF/CDS Recipients

General questions

How do we access the program guidance?

In April 2022, we provided each organization with guidance for your project via e-mail as determined in the FY 2022 Consolidated Appropriations Act (P.L. 117-103).

To ensure we can review and award the funds timely, please apply under the announcement distributed to you. If you need assistance, please contact our CPF/CDS Team.

How do I access the Technical Assistance Webinar recording held on April 7, 2022?

View the April 7 recording

How do I submit an application?

HRSA requires all applicants responding to these program guidances to apply electronically through grants.gov. Please reference the guidance sent to your organization in early April. This guidance is specific to your project as determined in the FY 2022 Consolidated Appropriations Act (P.L. 117-103) and provides additional information on completing and submitting your application.

Administrative

Where can I find guidance on how my project will need to comply with the requirements of The National Environmental Policy Act of 1969 (NEPA) and section 106 of the National Historic Preservation Act (NHPA)?

Information related to requirements and resources associated with NEPA and section 106 of NHPA can be found on BPHC's Environmental and Historic Preservation Technical Assistance page. Additionally, HRSA uses an environmental consultant that will proactively reach out to organizations after they receive their CDS award. HRSA's environmental consultant will assist with the specific requirements and processes to ensure timely compliance with both NEPA and NHPA.

Should we submit a Construction (HRSA-22-134) or Non-construction (HRSA-22-135) application?

Please apply under the guidance you received from HRSA. Not applying under the correct guidance (i.e., HRSA-22-134-Construction vs. HRSA-22-135-Non-construction) will delay the process and may require a resubmission under the correct guidance.

If you have any questions on which application guidance your organization should use, please contact CDSProgram@hrsa.gov.

Applicable to Construction and Non-construction projects: Is a transfer of the award to another organization allowable?

Transfers of CPF/CDS awards to other organizations are not allowed. You must apply under the name specified in the Fiscal Year 2022 Consolidated Appropriations Act.

Are HRSA-22-134 and HRSA-22-135 subject to “Review By State Under Executive Order 12372?”

No, these application guidances are not subject to Executive Order 12372.

Applicable to Construction and Non-construction projects: What is the difference between the Budget Narrative (iv) and Attachment 1: Budget Justification? Do I need to submit both?

You will need to submit both the Budget Narrative and Budget Justification with the application. The Budget Justification Narrative should be a written description of all the line-items included on the Budget Justification table. You will need to provide the Budget Justification in a table format, and it should present line-by-line, the project costs described in the Budget Narrative. Please be sure to describe all costs listed within the SF-424C budget in the budget narrative.

I have a Construction project. What is the required documentation for each type of Construction project?

A list of what is required for each project type follows.

Moveable Equipment only:

  • SF-424C Construction Forms
  • Itemized Equipment List

Design only:

  • SF-424C Construction Forms
  • Review/documented approval from the State Historic Preservation Officer/Tribal Historic Preservation Officer
  • Completion of an Environmental Information and Documentation (EID) Checklist
  • Adhere to Federal design and Construction requirements

New Construction or Renovation with or without Equipment:

  • SF-424C Construction Forms
  • Itemized Equipment List
  • Review/documented approval from the State Historic Preservation Officer/Tribal Historic Preservation Officer
  • Completion of an Environmental Information and Documentation (EID) Checklist
  • Provide Title/Lease documentation
  • Adhere to Federal design and Construction requirements
  • Schematic drawings
  • Notice of Federal Interest (NFI) (if applicable)

What is the application deadline? The guidances indicate a later due date than what is posted at Grants.gov.

You may begin your application now. We encourage CPF/CDS recipients to submit completed applications early in the application period to ensure the timely review and receipt of funds.

The application deadlines for these projects is as follows:

  • Non-construction (HRSA-22-135) applications are due beginning May 2, 2022 through June 1, 2022.
  • Construction (HRSA-22-134) applications are due beginning May 5, 2022 through June 6, 2022.

I no longer need a DUNS to apply?

Correct. As of April 4, 2022, the Federal Government no longer uses a data universal numbering system or DUNS. The Unique Entity Identifier (UEI) has replaced the DUNS.

How do I find my Unique Entity Identifier (UEI)?

If you already have an active SAM.gov registration, a UEI has automatically been assigned to your organization. Log in to your SAM.gov account to find your UEI.

If you do not have a UEI and need to obtain one, please visit SAM.gov and select “Get Started” on their home page.

Why is a middle name or initial required on the key contacts form?

This helps decipher whether or not an individual is excluded in SAM.gov from receiving federal contracts, certain subcontracts, and certain types of federal financial and non-financial assistance and benefits.

Who should I include on the key contact form?

The requirement is listed on pages 39 and 40 of the SF-424 application guide (PDF - 688 KB), and some examples of key personnel are Authorizing Official, Chief Executive Officer, Chief Operating Officer, Chief Medical Officer, and Chief Financial Officer.

Funding

Applicable to Construction and Non-construction projects: Our organization has already started work on our project. Do we need to provide the full scope of our project, including the activities we have completed?

Yes. Please provide information on the entire project, even if the activities have occurred, or are proposed to occur prior to award. HRSA will still need to assess activities completed prior to award through the pre-award prior approval request. Approval is not guaranteed, and grantees incur pre-award costs at their own risk.

Are indirect costs allowable for Construction projects?

Indirect costs are not allowable for HRSA-22-134 Construction projects. Administrative costs should be a minimal part of the project budget and not involve indirect costs. A construction contract whether it be the form of a General Contractor or Project Manager would have what is called “General Conditions.” This includes the contractor’s indirect costs in form of overhead and profit.

Can indirect cost rate be used for Non-construction applicants?

Yes, if your organization has a federally approved negotiated indirect cost rate agreement, you can use that indirect rate on this application. If your organization does not have a federally approved negotiated indirect cost rate agreement and would like to use indirect cost rate, you can use the 10% de minims rate. If your organization currently has a federally approved negotiated indirect cost rate agreement, your organization cannot use the 10% de minims rate.

I have a Construction project. Are copies of quotes needed? And will HRSA require proof of payment by the applicant for the equipment purchases using the CPF/CDS funding?

It is not necessary to submit actual copies of the quotes with the application. However, it is recommended that you obtain at least three quotes to show there is a degree of fair competition. Proof of payment is not required for the application, but HRSA asks that recipients keep the information for reporting on the SF-428 Equipment form.

Applicable to Construction and Non-construction projects: Once awarded, is there flexibility to change budget line items?

Yes, there is flexibility in making changes or adjustments to the budget. If adjustments need to be made to the budget after the award is made, you can re-budget funds within the approved categories if it is under 25% of the Federal approved budget. If re-budgeting is more significant and involves changes to the physical project scope and/or proposes to move funds into a category that was not previously approved, a prior approval request must be submitted.

I have a Construction project. Can we include and use the funding for equipment items with a unit cost that is less than $5,000?

Equipment items with a unit cost less than $5,000 can be considered as allowable equipment items, if consistent with the definition of Equipment noted in HRSA-22-134:
Equipment – tangible personal property or moveable equipment are non-expendable equipment items, with a useful life of more than one year that can be readily shifted from place to place without requiring a change in the utilities or structural characteristics of the facility.

I have a Construction project. Do I need to identify the full cost and scope of our project even if the CPF/CDS funding will only cover a portion of the project cost?

Yes. The SF-424C budget form must identify the full cost of the project to be supported with the CPF/CDS funding. You must also identify in your Budget Justification/Budget Narrative, the other sources of funding, as well as the status of those funds needed to support the total project cost.

Is an equipment-only request considered a "Non-construction Project?”

No, equipment-only projects are considered a Construction project. Congress appropriated funding in the FY 2022 Consolidated Appropriations Act (P.L. 117-103) for community funded/congressionally directed spending projects that relate to the construction and renovation (including equipment) of health care and other facilities.

You may submit applications for Construction projects for:

  • Construction and Modernization projects with or without equipment
  • “Design-Only” (planning portion of a Construction project)
  • Equipment only
  • Other construction and renovation related activities

How are the funds disbursed? Do we receive funds up front or are we reimbursed?

The funds are administered in the form of a grant. Funds will be disbursed in full, up front, and funds will be drawn down as costs are incurred.

Are these projects subject to Davis-Bacon wage requirements?

There was no specific language in the Consolidated Appropriations Act, 2022 (P.L. 117-103) directing the Congressionally Directed Spending funding to be subjected to the provisions of Davis-Bacon. However, state and local prevailing wage requirements would still need to be complied with in the implementation of project activities.

Can the funds be spent any time during the fiscal year for which we are requesting the funding? For instance, if we are going to request from a member in congress for FY 2023, can we make the acquisition at the start of FY 2023/October 1, 2022, then submit receipts to HRSA if the funding is approved by congress when the FY 2023 appropriations are signed into law?

Funding under HRSA-22-134 and HRSA-22-135 can only be used for the purpose and amount identified in the Consolidated Appropriations Act, 2022 (P.L. 117-103).

How long is the period of performance for my project?

For HRSA-22-134, Construction, the guidance notes that there is a three-year period of performance for the Community Project Funding/Congressionally Directed Spending (CPF/CDS) projects. Your organization will have 36 months from the award start date to spend the Construction funding.

For HRSA-22-135, Non-construction, the guidance notes that there is a one-year period of performance for the CPF/CDS projects. Your organization will have 12 months from the award start date to spend the Non-construction funding.

Applicable to Construction and Non-construction projects: Our organization plans to begin working on our project and purchasing equipment prior to the award start date. Is this allowable?

We understand there may be circumstances where organizations may need to incur project costs prior to their award start date. Once the organization applies and receives their new award, recipients of Construction projects will be able to submit a pre-award prior approval request to HRSA for review of any costs incurred up to 90 days prior to the enactment of the Consolidated Appropriations Act (P.L. 117-103 (before March 15, 2022).

Approval is not guaranteed, and grantees incur pre-award costs at their own risk. Additional information related to pre-award costs can be found on page 17 of the Construction guidance (HRSA-22-134).

For Non-construction projects, pre-award costs incurred up to 90 days prior to the award start date must seek prior approval from HRSA once award has been made. Approval is not guaranteed, and grantees incur pre-award costs at their own risk.

Please contact CDSProgram@hrsa.gov with any additional questions.

We received a CPF/CDS award for a Construction project. If we begin construction now, what happens if HRSA requests an Environmental Assessment or other documentation? Would we still be eligible to receive HRSA CPF/CDS funds for work performed prior to receiving an NOA?

All environmental requirements, including environmental assessments, must be met prior to the initiation of physical construction work (i.e., site work/grading, new structures, demolition).

The CPF/CDS funds for construction activities are typically restricted for limited pre-construction activities, such as expenses for completing architectural and engineering plans, meeting licensing and permitting requirements, historic preservation consultation with the State Historic Preservation Office/Tribal Historic Preservation Office, and/or preparing the Environmental Assessment.

Pre-award costs are incurred at the organization’s risk and award condition(s) must be approved and lifted from the Notice of Award prior to initiating any physical site preparation, demolition, alteration and renovation, or construction related to the project.

Please contact CDSProgram@hrsa.gov with any additional questions.

We have not yet located a site for the Construction project. How do we need to address the questions regarding site location?

Please include information in your application that the site is still in the process of being secured. HRSA will add a condition in your Notice of Award for your organization to provide that documentation when available.

Does Build America, Buy America (BABA) apply to CPF/CDS awards?

No. BABA requirements will not be applied to FY22 and FY23 CPF/CDS awards.

Post-Award (Construction and Non-Construction)

We have completed our initial submission into the HRSA Electronic Handbooks (EHBs) for a condition of award. What are the next steps?

Once post award condition submissions are reviewed and approved by HRSA, you will receive a new Notice of Award (NoA) noting that conditions have been lifted. If any changes are needed to your project, a prior approval (PA) request must be submitted into the EHBs, and HRSA may take a maximum of 30 days to review. If additional information is needed, we will notify you and the submission or PA request will be returned in the EHBs to allow for the revision. The final decision will result in a new NoA.

If our costs come in lower than anticipated in our submitted budget, can we use the remaining funds to purchase similar equipment that will be used for similar purposes to what was in our budget narrative?

These situations will be addressed case by case. Additional equipment purchases that were not included in the grant application will require HRSA approval. This approval is done through submission of a prior approval request for re-budgeting in the HRSA Electronic Handbooks. Please contact your Program Official and Grants Management Specialist regarding the use of remaining funds to ensure costs are allowable and within approved scope of project.

Do we need to request payment prior to purchasing the equipment or can we request payment as reimbursement for the purchase of budgeted equipment?

Payments for equipment should be requested as a reimbursement so that the amount drawn down from the Payment Management System aligns with the exact amount billed and expensed.  This also applies to reimbursement for other items such as construction building supplies, where exact costs may not be known until purchased.

Can you provide clarification on the process for drawing down funds within the Payment Management System (PMS)?

Once registered in PMS, you may make a payment request as often as needed (i.e., daily, weekly, monthly, or bi-monthly). However, in accordance with Department of Treasury regulations, federal cash must be drawn solely to accommodate immediate needs on an “as needed” basis only and must not be held in excess of three working days. For more information, please visit the PMS User Guide.

I am not sure what documents to submit or do not have all the documents necessary to respond to my condition of award. Is it okay to submit a partial response or re-submit what was provided in my application into the HRSA Electronic Handbooks (EHBs)?

HRSA is unable to review and make a final determination without receiving all required documents associated with the condition of award. Submissions that provide partial responses or the same documentation as provided in the application will be returned via the HRSA EHBs. Please contact your Program Official and Grants Management Specialist for more information regarding the documents necessary for submission.

What if our organization cannot submit the required documents by the condition due date?

If your organization is unable to meet a condition of award due date, please submit an extension request through the HRSA Electronic Handbooks (EHBs). For further assistance, please contact the HRSA Call Center at 877-Go4-HRSA (877-464-4772).

Who should I contact if I am having trouble registering or navigating in the HRSA Electronic Handbooks (EHBs)?

For assistance with the HRSA EHBs, please contact the HRSA Call Center at 877-Go4-HRSA (877-464-4772).

I have been contacted by the HRSA environmental reviewer to determine if other environmental or historic preservation compliance reviews are required for the proposed project. Once the final determination is made, what are my next steps?

Once the determination has been made, the HRSA environmental reviewer will share what documentation is required for submission into the HRSA EHBs related to your condition. The documentation must be completed and submitted to HRSA for review and approval.

Date Last Reviewed: