Ryan White Program Income (In-Person)
The Health Resources and Services Administration (HRSA) HIV/AIDS Bureau (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
- Permissible and impermissible uses of RWHAP program income
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.
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.
Ryan White (RWHAP) grantee:
- Other Finance Department staff
After this training, you will be able to:
- Identify what constitutes program income under a federal grant, including income related to 340B drugs.
- Describe the limitations applicable to RWHAP program income.
- Understand the requirements for properly accounting for program income.
- Discuss strategies for expenditure of program income generated through RWHAP activities.
Wednesday, September 28, 2022
10:00 am - 5:00 pm ET
|10:00 am - 10:30 am||Welcome and Overview|
|10:30 am - 11:45 pm|
Part 1: Grants Management and RWHAP
Discuss the legal system and requirements underlying federal grant awards, in particular financial management, cost allowability, and cost allocation issues that impact federal grant expenditures. Issues include the concept of “scope of project,” and the role of the grant budget.
|11:45 pm - 12:00 pm||Break|
|12:00 pm - 1:00 pm|
Part 1: Grants Management and RWHAP (Continued)
Discuss and describe the four primary RWHAP “Parts” (A through D), including the structure of the program and key entities. We will also discuss other common federal funding streams impacting RWHAP recipient operations, such as STD and Section 330 funding.
|1:00 pm - 1:30 pm|
|1:30 pm - 3:00 pm|
Part 2: 340B Program
Discuss the 340B Program, limitations on eligibility, and coordination among federal funding streams that confer 340B eligibility.
|3:00 pm - 3:15 pm||Break|
|3:15 pm - 5:00 pm||Part 2: 340B Program (Continued)|
Thursday, September 29, 2022
10:00 am - 4:30 pm ET
|10:00 am - 11:45 am|
Part 3: RWHAP Program Income Uses and Reporting
Discuss federal grant management concepts and requirements related to “program income,” HAB’s application of these requirements to 340B-related revenue, HAB’s interpretations and guidance regarding uses of program income, and strategies for using RWHAP program income.
|11:45 am - 12:00 pm||Break|
|12:00 pm - 12:45 pm|
Part 3: RWHAP Program Income Uses and Reporting (Continued)
|12:45 pm - 1:15 pm||Break|
|1:15 pm - 2:00 pm|
Evaluate RWHAP budgeting issues through examination of a hypothetical RWHAP Part C Budget, including issues related to overlapping RWHAP Part C and Part A/B/D grant projects.
|2:00 pm - 2:45 pm|
Part 4: Program Income Attribution
Review HAB guidance on PI tracking and “attribution.” Discuss various concepts for PI attribution, and complications that can arise in differing scenarios as programs become more complex.
|2:45 pm - 3:00 pm|
|3:00 pm - 4:30 pm|
Program Income Attribution Exercise
Participants will be asked to outline their current organizations and apply the principles we have discussed over the preceding day-and-a-half to attribution of program income. Groups will discuss their proposed approaches and how they addressed challenges faced by their particular circumstances.
AC Hotel by Marriott (0.1 mi)
1112 19th St NW
Washington, D.C. 20036
St. Gregory Hotel Dupont Circle** (0.2 mi)
2033 M St NW
Washington, D.C. 20036
Hyatt Place Washington DC/Georgetown/West End** (0.3 mi)
FTLF Discounted Rate Group Code 89073
2121 M St NW
Washington, D.C. 20037
Hilton Garden Inn Washington DC/Georgetown Area** (0.3 mi)
2201 M St NW
Washington, DC 20037
West End Washington DC, Tapestry Collection by Hilton (0.3 mi)
1121 New Hampshire Ave NW
Washington, D.C. 20037
Washington Marriott Georgetown (0.4 mi)
1221 22nd St NW
Washington, D.C. 20037
Embassy Suites by Hilton Washington DC Georgetown (0.4 mi)
1250 22nd St NW
Washington, D.C. 20037
** Discounted Rate available through FTLF link
Jason, a Partner with the firm, 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]
Participants can earn up to 13.80 CPE credits in Specialized Knowledge and Applications upon completion of all course requirements.
- Prerequisites: None
- Target Audience: Ryan White (RWHAP) grantee: CEO, CFO, Other Finance Department Staff
- Advanced Preparation: None
- Program Level: All
- Delivery Method: Group-Live
Feldesman Tucker Leifer Fidell LLP is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of accountancy have final authority on the acceptance of individual courses for CPE credit. Complaints regarding registered sponsors may be submitted to the National Registry of CPE Sponsors through its website www.nasbaregistry.org (formerly www.learningmarket.org).
(Through May 31)
(June 1 - September 27)
Bring your team! Discounts are available for groups of three (3) or more individuals from the same organization. Please contact us to process your registration.
Groups of 3 - 6
Groups of 7 - 10
Groups of 11 - 15
Over 15 attendees
|10% off||15% off||20% off||Call us!|
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