Public Comments - Office of Federal Assistance Management (OFAM)

RFI section E.1

Alabama Department of Public Health, Montgomery, AL

Creating a staff budget distribution chart, indicating the percentage of time each staff member will spend on each goal over the grant period is burdensome, as natural staff attrition, newly hired staff, and changing duties within the organization invariably makes this an exercise in futility, as it can become obsolete even prior to the grant being awarded. It is sufficient to indicate how many staff will be funded by the grant, and the total percentage of their salary the grant funds. Gantt Charts may be useful for internal project management, but are burdensome as a component of a grant application for the reason stated regarding a staff budget distribution chart. This level of detail seems unnecessary when routine grant reporting is typically provided for the PCO grant in annual increments.

ALTURA Centers for Health, Tulare, CA

For competing grants such as a New Access Point, it would be nice to have a minimum of 3 months from the date the RFP is released to the time the application is due in the EHB. The current 2 month timeframe is tight to form collaborations and gather letters of support, get quotes for equipment and supplies, work with a contractor to estimate renovation costs, or purchase land.

AT Still University, Kirksville, MO

Keep: ~2-month lead times. This extended period of development has greatly reduced stress and burden compared to prior 30-day cycles and has better facilitated the preparation of more competitive, evidence-based proposals.

Keep: Streamlined funding preferences/priorities. Compared with the extended application development timelines, greater specificity has also reduced stress for applicants.

Keep: Improved specificity and clarity of application instructions, particularly with regard to section requirements, examples (work plans and logic models), and citation suggestions.

Stop: Limiting applications on specific offerings (i.e., predoctoral training, etc.) to 1 per EIN. For institutions that operate geographically distinct schools, serving vastly different workforce pipeline targets, this greatly limits innovation and impact on underserved populations.

Start: Allowing more than 1 application per EIN. Instead consider limiting to 1 geographically distinct school. Hence, when a university system has 1 EIN, it will then be possible for both dental and/or medical schools to fairly compete for their respective opportunities to earn an award.

Bi-State Primary Care Association, Montpelier, VT

Bi-State and the VT and NH FQHCs strongly suggest that the Bureau reconsider utilizing five year project periods. We and our VT and NH FQHCs know that HRSA recognizes that the Service Area Competition process requires substantial time and effort from entire management teams. Our preference would be to decrease the frequency of these applications from three years to five years both for FQHCs and for PCAs, as had been the practice in the 2000s. If that is impossible, our secondary suggestion would be to reduce the application requirements (e.g., shorten the narrative).

California Primary Care Association (CPCA), Sacramento, CA

The two-step application process (Grants.gov and HRSA EHB) is extremely burdensome. Unless validation from Grants.gov is complete, applicants are not able to work on their EHB application. The project abstract, which is required to be uploaded in Grants.gov prior to the health center application in the EHB, is much easier to write at the completion of the application, not at the beginning. Occasionally the HRSA EHB process is more complex or actually requires information not readily apparent from the NOFO; resulting in an unexpected amount of work at the end of the application process or even a decision not to submit an application after all the preliminary work and validation via Grants.gov is done.

To ease this process, we recommend the following:

  1. We recommend that the first step of the process, via Grants.gov, require only a letter of intent before the applicant is able to begin the application in the EHB.
  2. CPCA recommends that the Grants.gov project abstract not be used for review by Congress. Project abstracts should be submitted in the HRSA EHB as a final step in the application, and that full and complete abstract should be the one actually used for review by Congress.
  3. Because there are times that the HRSA EHB process requires more information or complexity than is available in the NOFO, we recommend that HRSA link a version of the EHB application to the grants.gov NOFO guidance so health centers have the whole picture, prior to beginning the application.

Community Clinic Association of Los Angeles County (CCALAC), Los Angeles, CA

The two-step application process (Grants.gov and HRSA EHB) is extremely burdensome. Unless validation from Grants.gov is complete, applicants are not able to work on their EHB application. The project abstract, which is required to be uploaded in Grants.gov prior to the health center application in the EHB, is much easier to write at the completion of the application, not at the beginning. Occasionally the HR.SA EHB process is more complex or requires information not readily apparent from the funding opportunity notice (NOFO), resulting in an unexpected amount of work at the end of the application process.

To ease this process, we recommend the following:

  • The first step of the process, via Grants.gov, should only require a letter of intent (not the project abstract) before the applicant is able to begin the application in the HRSA EHB.
  • Project abstracts should be submitted in the HRSA EHB as a final step in the application, and the full and complete abstract should be the one used for review, not anything submitted prior to this point in the process.
  • To alleviate the challenges that arise when the HRSA EHB requires more information or complexity than is available in the NOFO, we recommend HRSA link a version of the EHB application to the grants.gov NOFO guidance so health centers can easily see both prior to beginning the application.

Community Health Systems, Inc., Moreno Valley, CA

The two-step application process (Grants.gov and HRSA EHBs) is burdensome because unless validation from Grants.gov is complete, applicants are not able to work on their EHB application.

Eastern Aleutian Tribes, Anchorage, AK

When a HRSA grantee has been receiving a Community Health Center grant for specific community(ies) and successfully managing it for more than 10 years and no other health providers exist in their isolated and remote community(ies), HRSA should develop a reduced application process with less required data points and less required documents to attach. It makes no sense to require successful grantees to spend weeks/months on developing a fully competitive application when the applicant and HRSA knows that nobody else is interested in competing for the HRSA funds.

Family Health Centers of San Diego, San Diego, CA

We feel the process be streamlined and improved in several ways. 1. Improve consistency across NOFO and other grant guidance documents, and in EHB; 2. Ensure that TA Q&A responses are not contradictory to other guidance, as has been the case in some situations; and, 3. Use EHB auto-item hiding function to remove entry fields that are not applicable based on prior responses (as is done in some Changes in Scope) to avoid confusion between NOFO, Q&A and EHB.

Health Center Partners of Southern California, San Diego, CA

The 2-part application process is cumbersome. The application process begins with grants.gov and requires input of information before that will open the grant in the EHB. For health centers, several team members likely work on these large HRSA grants, but only limited administrative staff will have access to grants.gov.

International Community Health Center, Seattle, WA

One way to ease the administrative burden of submitting proposals would be to limit the amount of grants that require a two-step process split between Grants.gov and Electronic Handbooks (EHB). We have experienced some issues in the past with reconciling our page counts with the counts produced by EHB. This could be mitigated by creating a way for users to preview EHB page counts before actually submitting the proposal.

Mendocino Community Health Clinic (MCHC), Ukiah, CA

The two-step application process (Grants.gov and HRSA EHB) is extremely burdensome. Unless validation from Grants.gov is complete, applicants are not able to work on their EHB application. The project abstract, which is required to be uploaded in Grants.gov prior to the health center application in the EHB, is much easier to write at the completion of the application, not at the beginning. Occasionally the HRSA EHB process is more complex or actually requires information not readily apparent from the NOFO; resulting in an unexpected amount of work at the end of the application process or even a decision not to submit an application after all the preliminary work and validation via Grants.gov is done.

To ease this process, we recommend the following:

  1. We recommend that the first step of the process, via Grants.gov, require only a letter of intent before the applicant is able to begin the application in the EHB.
  2. We recommends that the Grants.gov project abstract not be used for review by Congress. Project abstracts should be submitted in the HRSA EHB as a final step in the application, and that full and complete abstract should be the one actually used for review by Congress.
  3. Because there are times that the HRSA EHB process requires more information or complexity than is available in the NOFO, we recommend that HRSA link a version of the EHB application to the grants.gov NOFO guidance so health centers have the whole picture, prior to beginning the application.

National Association of Community Health Centers (NACHC), Washington, DC

NACHC urges HRSA to reduce burden in the application process by providing five-year project periods to health centers that have previously demonstrated successful management of, and full compliance with, a 330 grant.

As BPHC is well aware, the process of preparing a SAC application is extremely intensive and burdensome, even for high-performing health centers with no compliance issues. CEOs of such health centers estimate that preparing a SAC application requires between 120 and 280 hours of staff time, depending on the size of the organization and their project. In addition, health centers often find it advisable to pay consultants to assist them in navigating the complex application process, as even a small oversight could cause them to lose funding.

During the G.W. Bush Administration, high-performing health center grantees routinely received five-year project periods. Within the past decade, the maximum length of a project period was reduced to three years. This change – which was not required by statute – significantly increased the burden placed on existing grantees by requiring them to prepare SAC applications with much greater frequency.

NACHC understands and fully supports BPHC's efforts to ensure continuous compliance among Section 330 health centers. However, for health centers with established track records of full compliance and successful management of Section 330 grants, frequent SACs are unnecessarily burdensome. As you are aware, the "one-one-&-done" framework recently established by the Bipartisan Budget Act of 2018 ensures that all health centers that have any outstanding compliance issues at the time of the SAC award are limited to a one-year project period. In addition, according the FY2019 SAC guidance, first-time grant recipients are also limited to one-year project periods. Thus, the only health centers that will be eligible for anything longer than a one-year project period will be those who have already had a 330 grant, and are in complete compliance with all 330 requirements.

For these health centers with established track records of full compliance and successful management of Section 330 grants, we urge HRSA to extend project periods to five years. If deemed appropriate, HRSA could institute additional compliance checks during the additional two years, such as additional reporting requirements. (Please note that NACHC does not support adding a second OSV during a 5-year project period.) In addition, if one of these health centers was found to have a significant number of compliance issues during their OSV, their project period could be shortened, to ensure that BPHC has adequate opportunities to assess compliance. These methods would ensure continued compliance among high-performing health centers while imposing significantly less burden and costs than a full-scale SAC process.

Neighborhood Healthcare, Escondido, CA

The two-step application process (Grants.gov and HRSA EHB) is extremely burdensome. Unless validation from Grants.gov is complete, applicants are not able to work on their EHB application. The project abstract, which is required to be uploaded in Grants.gov prior to the health center application in the EHB, is much easier to write at the completion of the application, not at the beginning. Occasionally the HRSA EHB process is more complex or actually requires information not readily apparent from the NOFO; resulting in an unexpected amount of work at the end of the application process or even a decision not to submit an application after all the preliminary work and validation via Grants.gov is done.

To ease this process, we recommend the following:

  1. That the first step of the process, via Grants.gov, require only a letter of intent before the applicant is able to begin the application in the EHB.
  2. The Grants.gov project abstract not be used for review by Congress. Project abstracts should be submitted in the HRSA EHB as a final step in the application, and that full and complete abstract should be the one actually used for review by Congress.
  3. Because there are times that the HRSA EHB process requires more information or complexity than is available in the NOFO, we recommend that HRSA link a version of the EHB application to the grants.gov NOFO guidance so health centers have the whole picture, prior to beginning the application.

The Callie Clinic, Sherman, TX

RWHAP Part C HIV Early Intervention Services: New Geographic Service Areas, FON: HRSA-18-092.

"This competition is open to current RWHAP Part C EIS recipients and new organizations proposing to provide services in a new geographic service area as described by the applicant. HRSA anticipates awarding up to 15 new service areas under this notice. Newly proposed service areas must not geographically overlap with existing service areas as defined in Appendix B to the notice of funding opportunity (NOFO) HRSA-18-001, HRSA-18-004, and HRSA-18-005.

This competition is open to current RWHAP Part C EIS recipients and new organizations proposing to provide RWHAP Part C EIS funded services in new geographic service areas as described by the applicant. HRSA will fund up to 15 new service areas under this notice of funding opportunity (NOFO). For the purposes of this NOFO, a new service area is a defined geographic area with a demonstrated need for comprehensive primary health care and support services in an outpatient setting for low income, uninsured, and underserved PLWH, not adequately covered by other sources of support. Newly proposed service areas must not geographically overlap with existing RWHAP Part C EIS service areas as defined in Appendix B in NOFO HRSA-18-001, HRSA-18-004, and HRSA-18-005."

  • The above method of "open" competition is not really open when your guidance states the following:
    • "Newly proposed service areas must not geographically overlap with existing service areas as defined in Appendix B to the notice of funding opportunity (NOFO) HRSA-18-001, HRSA-18-004, and HRSA-18-005."
    • Yet, you have allowed overlap of counties in HRSA-18-001 and HRSA-18-004.

HRSA-18-001

Counties in HRSA-18-001: Collin, Dallas, Denton, Ellis, Henderson, Hunt, Kaufman, Rockwall

HRSA-18-004

Counties in HRSA-18-004: Collin, Cooke, Dallas, Denton, Ellis, Fannin, Grayson, Henderson, Hunt, Kaufman, Navarro, Rockwall

  • For the three counties that are geographically furthest away and closer to Oklahoma than the DFW area (Cooke, Grayson and Fannin Counties); you have lumped them with the Dallas area. We are a rural, underserved area with many low income, uninsured, and underserved PLWH, not adequately covered by other sources of support (Part C, Part D and Part A).

United Health Centers of the San Joaquin Valley, Parlier, CA

Information submitted on EHB related to the narrative should further be condensed to make it easier for the health center and the HRSA reviewer.

The letters of support process should be eliminated since HRSA is allowing overlap in services.

RFI section E.2

Alabama Department of Public Health, Montgomery, AL

Each grant year typically ends with a relatively small amount of unspent funds, attributed to minor adjustments in payrolls, odd pay periods, and other accounting adjustments. The requirement for formal carryover requests for these unobligated balances is time consuming and onerous, and diverts a significant amount of staff time away from primary grant activities. It also creates a significant administrative burden within HRSA, at both the grant management and program management levels. This formal carryover request procedures needs to be eliminated, especially for grant budget periods that fall within the same overall project period.

The current process of requiring a narrative document for annual progress reporting is very burdensome when the same information could be presented by providing numbers in a chart format, giving the OPTION to provide narrative statements to clarify aberrations from past reporting or substantiate low or high numbers. It is recommended that HRSA’s grant application process be simplified and standardized, similar to the process prescribed in Federal Acquisition Regulations (FAR) for contract solicitations and awards. The FAR prescribes the use of standardized forms, and employs a universal ‘section’ or ‘schedule’ format in which different parts of the solicitation and award are located. The use of this standardize procedure and ‘fill in the blank’ forms would greatly streamline the current, time consuming process required by HRSA for lengthy project narratives and related documents. In addition, it would also significantly enhance HRSA’s review and evaluation process, and streamline the comparison and evaluation of grant applications submitted by different applicants.

Finally, it is burdensome and seems unnecessary to require biographies for new staff members associated with any particular grant. These individuals have already been vetted through a formal interview process and hired by the grantee as the most capable person available to perform the job.

ALTURA Centers for Health, Tulare, CA

For New Access Points, the time limit of getting the new site up and running in 120 days is virtually impossible if the new site is new construction (it is also difficult for renovation as well). Even if the health center owns the land and has the construction plans complete, it takes 30-90 days for the City to go through the permitting process. New construction takes at least 6 months after the permits are received. After construction is finished , the new site must pass OSHPD inspection and be licensed with the State before we can see our first patient. Even if everything runs smoothly, it is a 9-12 month process to get a new site up and running.

Bi-State Primary Care Association, Montpelier, VT

Bi-State and the VT and NH FQHCs recognize and appreciate that HRSA has already made some improvements to the prior authorization process. In our experience, some Carryover of Unobligated Balance requests have taken many months (6+ in some instances) to resolve. When we intend to use these funds to pay subrecipients and/or vendors, we especially run the risk of a lapse of services (as we cannot extend subcontracts until our HRSA approval is official). If it is possible for approval of these requests to be expedited or automatic, that would be very helpful.

California Department of Public Health, Sacramento, CA

Recipients are required to complete an Unobligated Balance and Carryforward Request form to identify funding distribution, Proposed Carryforward Usage, and submit a formal Carryover Letter Request, which includes an amount and justification detailing as to why the funds were not expended. In the Electronic Handbook, the forms, instructions and dates do not match the information provided in the Notice of Awards (for example dates and the year on the forms are not always accurate). Increasing the use of the authority could be helpful if information in the Electronic Handbook was accurate and up to date for recipients.

California Primary Care Association (CPCA), Sacramento, CA

CPCA supports the use of expanded authorities to automatically waive the requirement for prior approval for specific actions, (e.g., carryforward unobligated balances to subsequent periods of performance, no-cost extension, etc.). Specific actions that we recommend HRSA take include:

  • The biggest area of opportunity for burden reduction is the unnecessary carryover requests required by 330 supplemental awards that are awarded across two budget periods. A supplemental award is issued, usually with a specific one year period that almost inevitably crosses over two 330 budget years. Work on the supplemental award is supposed to occur over the one year award period, however health centers are required to submit a carryover budget and justification, despite the fact that the grant was expressly awarded for a period that is longer than the 330 budget year and funds are being expended in accordance with the project timeline. This process unnecessarily creates additional work for grantees, Project Officers and Grants Management Specialists alike. CPCA recommends an automatic authorization for this type of planned carryover.
  • We recommend that HRSA not require a change in scope in the case where the change is minor (adjusting operating hours by 5 or fewer per week, for example).
  • We highly recommend that HRSA adopt the approach of SAMHSA, which is to allow automatic carryover of amounts less than 10% of that year's award, without prior approval.
  • Please try to align timeline between UDS and Budget Period Report.
  • While we have appreciated the current work by HRSA to simplify the BPR process, the clinical information requested by the BPR is already duplicated in the UDS. We recommend that HRSA eliminate the UDS/Clinical portions on BPR and add the narrative explanations to UDS or visa-versa. Making the BPR (s) after the UDS would also be helpful.

Community Clinic Association of Los Angeles County (CCALAC), Los Angeles, CA

Health centers support the use of expanded authorities to automatically waive the requirement for prior approval for specific actions ( e.g., carryforward unobligated balances to subsequent periods of performance, no-cost extension, etc.).

The biggest opportunity for burden reduction seems to be the unnecessary carryover requests required by 330 supplemental awards that are awarded across two budget periods. One-year supplemental awards almost always cross over two 330 budget years. Work on the supplemental award is supposed to occur over the one year award period; however health centers are required to submit a carryover budget and justification, despite the fact that the grant was expressly awarded for a period that is longer than the 330 budget year and funds are being expended in accordance with the project timeline. This process unnecessarily creates additional work for grantees, Project Officers and Grants Management Specialists alike. We recommend an automatic authorization for this type of planned carryover.

Other recommendations to reduce burden in this area include:

  • Not requiring a change in scope in the case where the change is minor (adjusting operating hours by 5 or fewer per week, for example).
  • Adopt the approach of the Substance Abuse and Mental Health Services Administration (SAMHSA), which allows automatic carryover, without prior approval, of amounts less than 10 percent of that year's award.
  • Adjust the timelines ofUDS and the Budget Period Report (BPR); the BPR(s) should follow UDS.
  • Eliminate the UDS/Clinical portions on BPR and add the narrative explanations to UDS or visa-versa as the clinical information requested by the BPR is duplicated in the UDS.

Community Health Systems, Inc., Moreno Valley, CA

Notice of Awards' terms and conditions are too "wordy". NoAs should reference where the information can be found instead of listing it on the NoA. Also, when a condition is lifted, the condition is restated, but it seems confusing when reading it.

Family Health Centers of San Diego, San Diego, CA

Submission requirements associated with capital improvement projects are burdensome. Any effort to consolidate or reduce associated burden would be beneficial. We would refer you to our response to RFI Section A. 3. With regard to decreasing the reporting burden required by the bureau we feel the biggest area of opportunity for reduction would be the unnecessary carryover requests required by 330 supplemental awards that are awarded across two budget periods. A supplemental award is issued, usually with a specific one year period that almost inevitably crosses over two 330 budget years. Work on the supplemental award is supposed to occur over the one year award period, however we are required to submit a carryover budget and then justify why we didn't spend the money in the current 330 budget year, and identify how we are going to spend the money in the coming 330 budget year. The response should simply be that the grant was expressly awarded for that period and funds are being expended in accordance with the project timeline, yet HRSA requires a more in-depth analysis as outlined above. This process unnecessarily creates additional work for grantees, Project Officers and Grants Management Specialists alike. We would highly recommend that HRSA adopt the approach of SAMHSA, which is to allow automatic carryover of amounts less than 10% of that year's award, without prior approval.

Mendocino Community Health Clinic (MCHC), Ukiah, CA

MCHC supports the use of expanded authorities to automatically waive the requirement for prior approval for specific actions, (e.g., carryforward unobligated balances to subsequent periods of performance, no-cost extension, etc.). Specific actions that we recommend HRSA take include:

  • With regard to decreasing the reporting burden required by the bureau we feel the biggest area of opportunity for reduction would be the unnecessary carryover requests required by 330 supplemental awards that are awarded across two budget periods. A supplemental award is issued, usually with a specific one year period that almost inevitably crosses over two 330 budget years. Work on the supplemental award is supposed to occur over the one year award period, however health centers are required to submit a carryover budget and justification, despite the fact that the grant was expressly awarded for a period that is longer than the 330 budget year and funds are being expended in accordance with the project timeline. This process unnecessarily creates additional work for grantees, Project Officers and Grants Management Specialists alike. MCHC recommends an automatic authorization for this type of planned carryover.
  • We highly recommend that HRSA adopt the approach of SAMHSA, which is to allow automatic carryover of amounts less than 10% of that year's award, without prior approval.
  • While we have appreciated the current work by HRSA to simplify the BPR process, the clinical information requested by the BPR is already duplicated in the UDS. We recommend that HRSA eliminate the UDS/Clinical portions on BPR and add the narrative explanations to UDS or visa-versa.

National Association of Community Health Centers (NACHC), Washington, DC

NACHC encourages HRSA to expedite the process of reviewing and approving Carry-Over requests

NACHC and health centers appreciate the opportunity to carryover some categories of unobligated funds from one budget year to the next, as this provides health centers with additional flexibility in the event of unforeseen circumstances. However, at present, health centers sometimes wait over six months for a carryover request to be approved. This flexibility would be even more valuable if such requests were reviewed and approved on a more expedited basis.

Neighborhood Healthcare (NHcare), Escondido, CA

NHcare supports the use of expanded authorities to automatically waive the requirement for prior approval for specific actions, (e.g., carryforward unobligated balances to subsequent periods of performance, no-cost extension, etc.). Specific actions that we recommend HRSA take include:

  • With regard to decreasing the reporting burden required by the bureau we feel the biggest area of opportunity for reduction would be the unnecessary carryover requests required by 330 supplemental awards that are awarded across two budget periods. A supplemental award is issued, usually with a specific one-year period that almost inevitably crosses over two 330 budget years. Work on the supplemental award is supposed to occur over the one-year award period, however health centers are required to submit a carryover budget and justification, despite the fact that the grant was expressly awarded for a period that is longer than the 330 budget year and funds are being expended in accordance with the project timeline. This process unnecessarily creates additional work for grantees, Project Officers and Grants Management Specialists alike. NHcare recommends an automatic authorization for this type of planned carryover.
  • We recommend that HRSA not require a change in scope in the case where the change is minor (adjusting operating hours by 5 or fewer per week, for example).
  • We highly recommend that HRSA adopt the approach of SAMHSA, which is to allow automatic carryover of amounts less than 10% of that year's award, without prior approval.
  • While we have appreciated the current work by HRSA to simplify the BPR process, the clinical information requested by the BPR is already duplicated in the UDS. We recommend that HRSA eliminate the UDS/Clinical portions on BPR and add the narrative explanations to UDS or visa-versa. Making the BPR (s) after the UDS would also be helpful.

United Health Centers of the San Joaquin Valley, Parlier, CA

Follow-up requirements listed in the NGAs related to the post award process are burdensome. For example, SF-424C, the budget justification and equipment list should be revised to make the process easier for health centers and HRSA reviewers.

Whitman-Walker Health (WWH), Washington, DC

It would significantly reduce grant recipient burdens if the process of carrying forward unobligated balances to subsequent performance periods were streamlined. While the increase of the use of expanded authorities may be helpful to reduce recipient burden, WWH’s current experience is that the burden is augmented because of agency delay rather than by the requirement to receive prior approval for specific actions per se. Currently, carryover requests often take more than a month to process, which can create inconsistencies in budget amounts that are themselves time-consuming to identify and adjust.

Additionally, instructions for carryover requests should be simplifies and clarified. The current instructions are less than clear and subject to multiple interpretations. Lastly, when the recipient receives an updated NOGA in the post-award process, there can be significant challenges. Grant recipients often receive multiple NOGAs for the same grant period for a variety of reasons. While each NOGA contains dates and a grant numbers, it can be difficult to track which NOGA is current for which funding stream. This makes it more challenging to ensure that all requirements for each grant are fully met.

RFI section E.3

ALTURA Centers for Health, Tulare, CA

It would be nice if the budget form templates were given in Excel format instead of Word.

AT Still University, Kirksville, MO

Keep: Streamlined language and clarity of expectations.

Keep: Offering 2 TA calls—the first focused more on the NOFO and issues of eligibility/competitiveness; the second focused more on specifics of application and program development.

Stop: Limiting applications on specific offerings (i.e., predoctoral training, etc.) to 1 per EIN. For institutions that operate geographically distinct schools serving vastly different workforce pipeline targets, this greatly limits innovation and potential impact on underserved populations.

Start: Allowing more than 1 application per EIN and consider limiting to 1 geographically distinct school. Hence, when an institution of higher ed has 1 EIN, it will then be possible for both dental and/or medical schools to fairly compete for their respective opportunities to earn an award.

Start: Shortening turnaround times for posting TA recordings. These are very helpful, and we refer back to them frequently.

Start: Improving turnaround times for FAQ responses. Often FAQ responses don't become available after the TA calls until immediately before the application deadline. It is critical to have this information much sooner.

Bi-State Primary Care Association, Montpelier, VT

Notice of Funding Opportunities (NOFOs) currently contain a detailed section for Project Narrative Description, which includes the various suggested narrative sections such as NEED, METHODOLOGY, RESOLUTON OF CHALLENGES, etc., as well as suggestions for the information that should be included in the narrative to provide further detail. NOFOs also contain a separate detailed section explaining the Review Criteria. Sometimes the NOFO specifically includes language connecting certain criteria to certain narrative sections, but this crosswalk is never a one-to-one match. Additionally, there is often significant duplication in these two sections of the NOFO. We believe that it would be easier for the grant respondent, HRSA staff, and any grant reviewers if the NOFO included a single suggested outline that included both the narrative details and the review criteria.

In our experience, some NOFOs have also required excessive supporting documentation, especially in the budget narrative. The guidance about developing the budget narrative generally advises that the budget narrative should be concise, and it is not a place to extend the project narrative. In some instances we are aware that HRSA has come back to the applicant and requested a significantly more detailed description of line items. For example, when describing mileage expenses, the budget narrative submitted in the original application might describe, "$250 in mileage for travel to regional meetings with sub recipients @ .545 per mile." As a Grant Specific Term, HRSA may then request the applicant to add in who will be using the mileage, to give an exact number of miles, and to identify how many trips and to which sites. The context for the travel has already been provided in the project narrative, and the number of trips is estimated, and therefore the reality may be different from the additional detail provided. The back and forth on the budgets can take several weeks after the project start date, resulting in delays in starting the work. This is especially burdensome when the project has sub recipients because the applicant would not be able to initiate the subrecipient agreements to start work until HRSA resolves and approves the budget.

Several FQHCs also noted that they would appreciate more flexibility/less prescription on the uses for one-time funding, for example, the ability to include those one-time dollars for operational or other purposes as related to the funding purpose.

California Department of Public Health, Sacramento, CA

Recipients often look to manuals, policy notices, and other documents that are posted on the HRSA website for program guidance and requirements. Because the NOFO Terms and Conditions are not posted online, there is chance that they get overlooked. Additionally, sometimes the Terms and Conditions contradict the FOA or other published guidance. It is important to keep the Terms and Condition in sync with other published guidance.

California Primary Care Association (CPCA), Sacramento, CA

One of the most burdensome aspects of the HRSA grants application process is the continued variance between what appears in the NOFO itself and what appears in the EHB for submission. Oftentimes access to the EHB is delayed so all program development and grant preparation is done using the NOFO, and then once access to EHB is available, we must revise our response to align with the EHB. If discrepancies between the NOFO and EHB and inevitable, then earlier access to EHB would help to alleviate the problem. We recommend that HRSA:

  1. Improve consistency across NOFO and other grant guidance documents, and in EHB;
  2. Ensure that TA Q&A responses are not contradictory to other guidance, as has been the case in some situations;
  3. Use EHB auto-item hiding function to remove entry fields that are not applicable based on prior responses (as is done in some Changes in Scope) to avoid confusion between NOFO, Q&A and EHB.
  4. Allocate more time to Q&A during the TA calls.
  5. Recordings of TA calls should be available sooner than the 1-week turnaround.
  6. Due dates should be a little longer to accommodate the 2-step application process.

Community Clinic Association of Los Angeles County (CCALAC), Los Angeles, CA

As mentioned above in response to Section E.1, one of the most burdensome aspects of the HRSA grants application process is the continued variance between what appears in the Notice of Funding Opportunity (NOFO) and what appears in the EHB for submission. Health centers report that access to the EHB is often delayed so all program development and grant preparation is done using the NOFO. Once access to EHB is available, responses must be revised to align with the EHB.

With regard to NOFOs, we recommend the following:

  • Improve consistency across NOFO and other grant guidance documents and in EHB.
  • Link a version of the EHB application to the grants.gov NOFO guidance so health centers can easily see both, prior to beginning the application.
  • Extend deadlines to allow more time for submission to accommodate the 2-step application process.

With regard to Technical Assistance (TA), we recommend the following:

  • Allocate more time to Question & Answer (Q&A) during the TA calls.
  • Ensure that the Q&A responses are in line with all other available guidance.
  • Make TA call recordings available sooner than one week from the call date.

Community Health Systems, Inc., Moreno Valley, CA

More time can be allocated to Q&A during the TA calls. Recordings should be available sooner than the 1-week turnaround. Due dates should be a little longer to accommodate the 2-step application process.

Family Health Centers of San Diego, San Diego, CA

One of the most burdensome aspects of the HRSA grants application process is the continued variance between what appears in the NOFO itself and what appears in the EHB for submission. As noted in RFI Section A.2 We strongly feel that any funding for technology should be focused on the EHB. Oftentimes access to the EHB is delayed so all program development and grant preparation is done using the NOFO, and then once access to EHB is available, we must revise our response to align with the EHB. If discrepancies between the NOFO and EHB and inevitable, then earlier access to EHB would help to alleviate the problem.

International Community Health Center, Seattle, WA

NOFOs could be better organized to more clearly outline proposal requirements in one section of the document. Currently, proposal narrative prompts, format requirements, and other rules are divided between multiple sections of the NOFOs, including appendices, as well as separate sources such as the Two-Tier Application Guide. In order to make it easier for users to understand the requirements, have a checklist of all required elements of the proposal, followed by an outline of format requirements, prompts and review criteria for the narrative, and explanation of other required elements, such as budgets, forms, and attachments. This would make requirements more clear and planning easier.

Mendocino Community Health Clinic (MCHC), Ukiah, CA

One of the most burdensome aspects ofthe HRSA grants application process is the continued variance between what appears in the NOFO itself and what appears in the EHB for submission. Oftentimes access to the EHB is delayed so all program development and grant preparation is done using the NOFO, and then once access to EHB is available, we must revise our response to align with the EHB. If discrepancies between the NOFO and EHB and inevitable, then earlier access to EHB would help to alleviate the problem. We recommend that HRSA:

  1. Improve consistency across NOFO and other grant guidance documents, and in EHB;
  2. Ensure that TA Q&A responses are not contradictory to other guidance, as has been the case in some situations;
  3. Use EHB auto-item hiding function to remove entry fields that are not applicable based on prior responses (as is done in some Changes in Scope) to avoid confusion between NOFO, Q&A and EHB.
  4. Allocate more time to Q&A during the TA calls.
  5. Recordings of TA calls should be available sooner than the 1-week turnaround.
  6. Due dates should be a little longer to accommodate the 2-step application process.

National Association of Community Health Centers (NACHC), Washington, DC

NACHC recommends that NOFOs clearly indicate which review criteria should be addressed in which section of the Project Narrative

As discussed in the comments submitted by the Bi-State PCA, it is sometimes difficult to determine which review criteria are to be addressed under which section of the Project Narrative. We recommend providing a cross-walk clearly indicating which sections of the Narrative (and other parts of the application) will form the basis for evaluating each criteria. While this crosswalk would not need to be comprehensive – in order to give reviewers the flexibility to consider information provided elsewhere – it would provide applicants with a structure for ensuring that they include the most relevant information in locations where reviewers are most likely to look for it.

Neighborhood Healthcare, Escondido, CA

One of the most burdensome aspects of the HRSA grants application process is the continued variance between what appears in the NOFO itself and what appears in the EHB for submission. Oftentimes access to the EHB is delayed so all program development and grant preparation is done using the NOFO, and then once access to EHB is available, we must revise our response to align with the EHB. If discrepancies between the NOFO and EHB are inevitable, then earlier access to EHB would help to alleviate the problem. We recommend that HRSA:

  1. Improve consistency across NOFO and other grant guidance documents, and in EHB;
  2. Ensure that TA Q&A responses are not contradictory to other guidance, as has been the case in some situations;
  3. Use EHB auto-item hiding function to remove entry fields that are not applicable based on prior responses (as is done in some Changes in Scope) to avoid confusion between NOFO, Q&A and EHB.
  4. Allocate more time to Q&A during the TA calls.
  5. Recordings of TA calls should be available sooner than the 1-week turnaround.
  6. Due dates should be a little longer to accommodate the 2-step application process.

Whitman-Walker Health (WWH), Washington, DC

The NOFAs that HRSA is currently publishing on Grants.gov generally are clear in their requirements. There is, however, often confusion around what portion of the grant application is required to be submitted into Grants.gov and what portions into EHB. If it were possible to streamline the two so that all components of all application could be submitted through a single portal, that would significantly reduce burden.

When WWH does receive comments on applications submitted, the comments are helpful. However, WWH does not consistently receive comments on all grant applications submitted to HRSA, and it would greatly improve WWH’s understanding of what is needed to submit a high-quality application if we did receive comments consistently.

Date Last Reviewed:  October 2018