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June 9, 2020 Webinar FAQs

These questions come from our June 9 Healthy Grants Web Series Workshop. We held sessions on Grants Policy Updates and HRSA’s Office of Regional Operations.

Grants Policy Update – Session FAQs

Regarding the 2020 audit to be completed in 2021, a physical asset inventory is required every two years. Will this be waived for the 2020 audit, to be completed in 2021, due to COVID-19 to minimize patient and staff exposure?

At this time, the Office of Management and Budget (OMB) has not waived the requirement to submit a physical asset inventory with submitted audits.

However, per guidance issued by the Office of Management and Budget (OMB) in OMB Memo M-20-11 (PDF - 1.3 MB) and OMB Memo M-20-17 (PDF - 5.4 MB), HRSA recipients with awards issued in response to COVID-19 may delay their submission of their upcoming Single Audits by up to 12 months.

OMB Memo M-20-17 was superseded on June 18, 2020, by OMB Memo-M-20-26 (PDF - 3.9 MB), but it does not change the extensions. HRSA recipients and subrecipients should maintain documentation of the reason for the delayed finding. Also note that recipients and subrecipients taking advantage of this extension would still qualify as a "low-risk auditee" under the criteria of 2 CFR § 200.520 (a), Criteria for a low-risk auditee.

If you do not have awards issued in response to COVID-19, but are affected by the loss of operational capacity due to COVID-19, you may delay your submission by a six-month extension. These additional flexibilities are provided by the Department of Health and Human Services (HHS).

Recipients and subrecipients must maintain documentation of the reason for the delayed filing. Organizations with questions about their ability to obtain extensions should email our Division of Financial Integrity at SARFollowup@hrsa.gov.

Is the threshold dollar amount based on an aggregated purchase amount, or amount per item? For example, if we purchase one iPad for $1,500 or 10 iPads for $15,000, would it qualify as micro purchase?

The micro-purchase threshold is set by the Federal Acquisition Regulation at 48 C.F.R. Subpart 2.1 (Definitions). As of Fiscal Year 2020, it is currently $10,000, except as otherwise stated in Subpart 2.1, and is periodically adjusted for inflation. Micro-purchases may be awarded without soliciting competitive quotations if the recipient considers the price to be reasonable. (45 CFR § 75.329).

This distribution of purchases among qualified suppliers can happen in one of two ways: at the time of the purchase or over several purchasing events. In the example above, you can purchase the iPads either from various suppliers at the same time (the total of the purchases cannot exceed $10,000), or choose one supplier for the purchase of the iPads and another supplier the next time iPads need to be purchased (each of the purchases cannot exceed $10,000).

If we have been awarded HRSA funding from the CARES Act, can we manage these funds from our usual bank account and create a different cost center, or do we need to house these funds in a separate bank account?

All recipients of Coronavirus Aid, Relief, and Economic Security Act (CARES Act) funds must comply with 45 C.F.R. § 75.302. Your accounting system must be able to account for each funding stream separately, even if you use the same bank account as your usual bank account.

Is there a separate salary limitation for physicians, or is it the same?

There is no separate salary limitation for physicians. The Legislative Mandates in the Appropriations Act include a salary rate limitation, capped at $197,300 for FY 2020, which is the Executive Level II of the Federal Executive Pay Scale (as published on the OPM website). For more information, see Grants Policy Bulletin: Legislative Mandates in Grants Management for FY2020 (PDF - 397 KB).

Does an organization need to have a separate departmental Conflict of Interest (COI) policy or can it use the organization’s COI policy (for example, at a University)?

You should follow your organization’s policy. If your organization has separate departmental policies, then you may have a separate conflict of interest policy. If you keep the same policies as the organization’s broader policies (such as at a University), then you do not need a separate departmental policy.

Paying a family member with grant funds is considered a conflict of interest. Correct?

Please see the HRSA Financial Conflict of Interest Policy (PDF - 330 KB). Examples below are taken from the HRSA COI policy.

A potential COI relative to Non-Federal Entity (NFE) procurement is presented in the following circumstances:

A NFE’s employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.

A potential COI is presented where the employee, officer, or agent of the NFE is involved in a particular matter involving specific parties and the employee, officer, or agent of the NFE knows (or should know) that:

The matter is likely to affect the financial interests of a member of an employee, officer, or agent of NFE’s household; or

One or more of the parties to the matter is or is represented by one of the following:

A person or organization with whom the employee, officer, or agent of the NFE has or seeks a business relationship;

A person who is a member of an employee, officer, or agent of the NFE’s household;

A person who is a relative with whom the employee, officer, or agent of the NFE has a close personal relationship;

A person or organization for whom the employee, officer, or agent of the NFE’s spouse, parent, or dependent child is serving or seeking to serve as an officer, director, trustee, general partner, agent, attorney, consultant, contractor, or employee.

How do we transition to a Unique Entity Identifier (UEI)?

All award recipients that are currently registered at www.SAM.gov will automatically get a Unique Entity Identifier (UEI) assigned to them. When you open your SAM account you should see the Data Universal Numbering System (DUNS) number and the UEI both in your profile. Eventually the DUNS number will be phased out and the UEI will be the only number, but for a while longer, you will see both numbers.

Who provides/how does our organization receive an UEI?

If you are currently registered in www.SAM.gov, you do not need to do anything. Being registered in SAM will automatically generate a UEI for your organization. Anyone who registers a new organization in SAM will automatically be assigned a new UEI.

How do we access FAPIIS?

Visit the Federal Awardee Performance and Integrity Information System (FAPIIS).

On this website, you can review information entered by the Federal Government or a pass-through entity about you as a recipient, and also offer comments or appeal the information entered. You must also disclose information about your organization regarding criminal, civil, and administrative proceeding, and/or affirm that there is no new information to provide.

Where does a grantee find information about their organization in FAPIIS?

Visit the Federal Awardee Performance and Integrity Information System (FAPIIS).

In the section “Search FAPIIS Records” at the top of the screen, you can search information about your organization by DUNS number, CAGE number, or Entity name.

 

Date Last Reviewed:  July 2020