Ryan White Program Income - How Do I Account For It, What Can I Spend It On?
The Health Resources and Services Administration (“HRSA”) HIV/AIDS Bureaus (“HAB”) has issued a considerable amount of guidance regarding program income over the past two years. That guidance has addressed HAB treatment of “340B program income,” attribution of program income among federal projects when grantees have multiple funding streams, and permissible and impermissible uses of RWHAP program income. FTLF attorneys Jason Reddish and Scott Sheffler combine their experience in 340B, federal grant management, and cost allocation to detail and explain HAB’s issuances, and discuss strategies for navigating these requirements. One of the problems grantees face with HAB’s guidance is that, while conceptually straight forward, it can be very difficult to apply to complex health care operation. This two day dive into this critical issue will include practical application of these requirements to real world scenarios, and discussion of strategies for successfully managing, and properly expending, one’s program income.
Ryan White (RWHAP) grantee:
- Other Finance Department staff
- Understand what constitutes program income under a federal grant, including income related to 340B drugs.
- Understand the limitations applicable to RWHAP program income.
- Learn requirements for properly accounting for program income.
- Discuss strategies for expenditure of program income generated through RWHAP activities.
Hyatt Place Washington DC/Georgetown/West End
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Jason focuses his practice on the federal 340B drug discount program and the complex legal and compliance issues facing safety net providers, pharmacies, and other 340B program stakeholders. Jason began his career representing pharmaceutical manufacturers before finding his passion helping 340B program covered entities, including disproportionate share hospitals, Federally Qualified Health Centers, Ryan White HIV/AIDS clinics, and other grantees navigate the 340B program. [Full Bio]
A Partner with the firm in the Federal Grants and Health Law practice groups, Scott advises clients on matters of federal grant law, government contract law, and health care law. Scott assists clients with the myriad requirements that apply upon acceptance of federal grant funding, including the administrative requirements and cost principles established in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), the Office of Management and Budget (OMB) Circulars that preceded the Uniform Guidance, and program-specific statutory and regulatory funding conditions. [Full Bio]
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