(Recorded Webinar) Providing Services Outside the Scope of Your Grant: How to Ensure Compliance
In response to the Supreme Court’s decision in Dobbs v. Jackson, we have received many calls about how safety net, grant-funded organizations, such as community health centers, can provide elective abortions or other activities outside the scope of their federal funding. The majority of the presentation will focus on the concept of establishing and maintaining activities outside of the federally-supported project (i.e., “other lines of business”).
Using elective abortions as an example, our speakers will discuss the Hyde Amendment and other appropriation riders, what they are and how they work, but will not delve into the Dobbs decision. We will then address how grant-funded entities can provide elective abortions or other services that cannot be paid for with federal grant funds and are not subject to federal grant requirements.
Focusing on the Health Center Program, we will address cost allocation requirements with concrete examples, federal interest considerations whether real property, equipment, or supplies, program income, and other legal and practical considerations. While abortion has some unique attributes and risk given that the Appropriations Act explicitly prohibits the use of HHS grant funds for elective abortion, the legal and accounting concepts covered in the webinar are ostensibly relevant to any “other line of business.” We will touch upon the restrictions on using excess program income under the health center program (i.e., must further the project objectives and be otherwise permitted under Section 330) and will highlight that excess program income can be used to support other lines of business that satisfy such criteria. The presenters will summarize strategies, key areas of risk, and potential pitfalls.
- Fiscal Staff
- Compliance Officers
- Other grants management staff
After this webinar, you will be able to:
- Understand the Hyde Amendment prohibition
- Describe the key legal and accounting considerations applicable to establishing an “other line of business”
- Identify and avoid common compliance errors associated with, among other things, cost allocation and federal interest
Carrie Riley is a Partner in the health law, non-profit and corporate law, and federal grants law practice groups. She counsels a wide variety of health care clients, including Title X grantees and subrecipeints, and other private and public health care providers, on contracting, regulatory compliance, fraud and abuse, and reimbursement matters. Carrie also provides counsel on transactional matters, including formation and agreements for multi-provider affiliations/joint ventures, general contracting, and residency training arrangements. [Full Bio]
Serving as Managing Partner of the firm since 2003, and a member of the Health Law and Federal Grants practices since 1992, Ted is a national authority in the area of federal grants, particularly in the health and community service spheres. He advises clients on all aspects of program requirements, including issues such as cost-based reimbursement, governance and the never-ending list of grant administration matters. Ted’s expertise in financial, cost reporting, reimbursement, and administrative issues is widely recognized and he routinely handles government audits, internal investigations, and litigation. [Full Bio]
Certificates of Attendance: We verify attendance upon completion of a webinar (live or recorded version) and will only issue certificates in the name of the account holder enrolled in the course. If you need to document attendance for someone other than the account holder, we provide blank Certificates of Attendance for a supervisor to sign and certify that a different individual viewed the course.
Group Attendance: Due to the online nature of webinars, we cannot verify participation by more than one person. For groups, we provide an attendance record form and blank Certificates of Attendance to record attendance at a group viewing session and document each individual's participation. We recommend that a supervisor or colleague sign the certificate to certify attendance.
Read more about maintaining an attendance record in our FAQs.
- 1.00 Certificate of Attendance
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