Type of Notice: Request for Information
Title: Rural Health Grants Eligibility Request for Information
Response Date: November 23, 2019 (deadline extended)
Summary: HRSA seeks public input on whether or how eligibility criteria governing community-based grant programs administered by the Federal Office of Rural Health Policy (FORHP) affect rural health organizations’ ability to apply for and leverage grant funding through FORHP. In particular, HRSA seeks responses to the “Questions for Public Comment” section of this Request for Information (RFI). HRSA may use the responses collected to inform the development and implementation of future grant programs, among other purposes. The responses and/or a summary of the responses may be shared with the Department of Health and Human Services (HHS) and/or the public.
Dates: Submit comments to the email listed in the “Response Format” section by 11:59 p.m. Eastern Time on November 23, 2019.
Response Format: Responses to this RFI must be provided via email to RFIComments@hrsa.gov and must reference “Rural Health Grants Eligibility RFI” in the title. Submissions are due no later than 11:59 p.m. Eastern Time on November 23, 2019. HRSA will not accept hard-copy responses or other formats.
HRSA seeks public input on whether and how eligibility criteria governing community-based grant programs administered by FORHP affect rural health organizations’ ability to leverage grant funding through FORHP. This RFI is part of a regular and ongoing effort by FORHP to assess the extent to which its programs align with a rapidly evolving rural health care landscape. To improve HRSA’s understanding of this issue, HRSA encourages input from a broad range of stakeholders, including health care providers—e.g., rural health clinics, critical access hospitals, federally-qualified health centers, other rural hospitals, etc.—researchers; community members; advocates; State, local and Tribal governments; past and current FORHP grant recipients; and other interested parties.
FORHP administers community-based grant programs designed to increase access to care in rural communities and address their unique health care challenges. The majority of community-based grant programs administered by FORHP are authorized by Section 330A(e) of the Public Health Service Act (42 CFR 254c(e)) (“Section 330A(e)”), which states that the lead applicant shall be a rural public or rural nonprofit private entity; . . . [and] shall represent a consortium composed of members—that includes 3 or more health care providers. . . and that may be nonprofit or for-profit entities. Additionally, for any given funding opportunity, whether authorized by Section 330A(e) or a different authority, FORHP does not permit more than one application per Employment Identification Number (EIN) and specifies that consortium members must have separate and different EINs. The purpose of these requirements is to ensure that grant funds are distributed across health systems, regions, states, and communities and to encourage collaboration among a broad array of stakeholders. Additionally, the requirement for applicant organizations to secure buy-in for their project from at least two other, separately owned partners increases the likelihood that the project will be able to withstand changes in leadership and industry and sustain services. Over the last eight years, approximately 75 percent of rural consortia receiving FORHP grants have reported continuing some aspects of grant activities after the grant period ends.
However, HRSA recognizes a growing trend towards greater consolidation within the health care industry. For example, nearly 1 in 8 rural hospitals nationwide merged between 2005 and 2016. While the nature and extent of affiliation agreements between rural hospitals, community-based organizations, and health systems differ across regions and entities, HRSA seeks to better understand whether and how this trend, and other changes in the rural health care industry may be affecting rural health care organizations’ ability to apply for and leverage Section 330A(e) and other FORHP-administered funding opportunities.
For example, given FORHP’s policy of accepting one application per EIN, multiple rural hospitals acquired by, and assuming the same EIN as, a single health care system would not be eligible to submit separate applications for a given funding opportunity administered by FORHP, even if they propose different projects or cover different service areas. Similarly, given Section 330A(e)’s requirement that the lead applicant be a rural public or nonprofit private entity, a rural hospital acquired by, and assuming the same EIN as, an urban-based health care system would not be eligible to serve as the lead applicant for a Section 330A(e)-authorized grant.
Below are several questions for public comment to help inform HRSA’s understanding of the factors affecting rural health organizations’ ability to leverage FORHP-administered grant funding. Whenever possible, respondents are asked to use objective observations or experiences and to cite this evidence within their responses, bearing in mind the applicable standards set forth in law, regulations, and policy. HRSA welcomes feedback on the areas of consideration outlined below, as well as more general feedback or suggestions.
Questions for Public Comment
- How has the health care landscape changed in your community over the past few years? What trend(s), if any, have affected your ability to apply for and leverage grant funding administered through FORHP?
- What impact, if any (positive or negative), does the eligibility criteria governing community-based programs administered by FORHP have on your ability to apply for and leverage grant funding through FORHP? Specify which criteria you are referring to in your response (e.g., one application per EIN, rural public or nonprofit private status, etc.).
- What impact, if any, does the eligibility criteria governing community-based programs administered by FORHP have on the quality of and/or access to rural health care services in your community or region? Specify which criteria you are referring to in your response (e.g., one application per EIN, rural public or nonprofit private status, etc.).
- What costs (e.g., financial, administrative, political, etc.) does a health system incur when it secures separate and unique EINs for rural satellite offices? What benefits are associated with having multiple EINs across a large health care system? Conversely, what costs (e.g., financial, administrative, political, etc.) does a health system incur when it maintains one EIN across multiple partners (either urban or rural)? What benefits are associated with having one EIN across a large health care system?
- What specific suggestions do you have for revising the eligibility criteria governing community-based grant programs administered by FORHP (how and to what extent)?
- What specific suggestions do you have for entities that share a single EIN but would like to apply separately for community-based grant programs administered by FORHP?
Responses to this RFI must be provided via email to RFIComments@hrsa.gov and must reference “Rural Health Grants Eligibility RFI ” in the title. Please include organization name, state and partners (if applicable). The response should note the specific RFI question to which your comment is directed. If you provide comments to more than one question, please identify the specific RFI question to which each comment is directed. Information obtained as a result of this RFI may be used by HRSA and HHS for program planning and program decision making on a non-attribution basis. Responses to this RFI may be made publicly available; therefore, respondents should not include any information that might be considered proprietary or confidential. HRSA will not respond to any individual comments. Comments will be received through 11:59 p.m. Eastern Time on November 23, 2019.
Special Note to Commenters:
Whenever possible, respondents are asked to draw their responses from objective, empirical, and actionable evidence and to cite this evidence within their responses.
This RFI is part of a regular and ongoing effort by FORHP to assess the extent to which its programs align with a rapidly evolving rural health care landscape and is issued solely for information and planning purposes. It does not constitute a Request for Proposal, applications, proposal abstracts, or quotations. This RFI does not commit the Government to contract for any supplies or services or make a grant or cooperative agreement award or make revisions to the current eligibility criteria or application structure. Further, HRSA is not seeking proposals through this RFI and will not accept unsolicited proposals. Responders are advised that the U.S. Government will not pay for any information or administrative costs incurred in response to this RFI; all costs associated with responding to this RFI will be solely at the interested party’s expense. Not responding to this RFI does not preclude participation in any future procurement or program, if conducted. All submissions become Government property and will not be returned.
Please note that HRSA will not respond to questions about the policy issues raised in this RFI. HRSA may or may not choose to contact individual responders. Such communications would only serve to further clarify written responses.