(Recorded Webinar) Part IV: The Building Blocks of Fiscal Viability
PART IV: Contracts, Sub-awards, & Financial Management
On Part IV of the De-Mystifying the Compliance Manual webinar series, we will address the health center program requirements related to the expenditure of grant and non-grant funds and the applicable obligations under the Administrative Requirements issued by the Department of Health and Human Services (HHS) in 45 C.F.R. Part 75. Participants will explore:
- Contracting and purchasing processes, including specific required contract provisions and conflict of interest standards;
- When to use a sub-award and applicable requirements for sub-recipient agreements; and
- General financial management and accounting systems that help to safeguard the health center’s assets and ensure the appropriate expenditure of funds, in compliance with the requirements of 45 C.F.R. Part 75.
This webinar will focus on topics from the following chapters of the Compliance Manual:
- Chapter 17: Budget
- Chapter 15: Financial Management and Accounting Systems
- Chapter 12: Contracts and Sub-Awards
- Chapter 13: Conflict of Interest Policy
In the past few years, HRSA has transitioned its compliance efforts from requiring FQHCS to utilize multiple guidance documents to ensure adherence to health center program requirements to issuing the Health Center Program Compliance Manual (the Manual), a consolidated resource to assist FQHCs in understanding, demonstrating, and operationalizing compliance. The Manual, which supersedes most (but not all) prior guidance, incorporates a new approach to everyday compliance.
To assist in conducting a “hands-on” compliance evaluation, HRSA issued a Site Visit Protocol (the SVP), which aligns with the Manual and reflects a more objective assessment tool than prior review guides. The current SVP (issued in April 2019), includes additional clarification on documentation requirements and assessment methodologies.
Together, the Manual and the SVP are the main tools used by HRSA for both on-site reviews of grantees and FQHC look-alike entities (Operational Site Visits - OSVs) and “desk audits” of project and designation renewal applications, by addressing:
- Each requirement’s statutory and regulatory basis
- Key elements of compliance that form the framework of every health center’s project
- Documentation necessary to verify compliance (both on paper and in practice)
- Areas where health centers maintain discretion
There is an expectation of 100% ongoing compliance with the Health Center Program Requirements. Is your health center prepared to meet this challenge? Given the possible consequences of non-compliance, including 1-year project periods for non-compliance with a single element and potential loss of 330-grant funds, it is critical that every health center be and remain vigilant, whether you are expecting an OSV, submitting a grant or look-alike designation application, or looking to bolster current operations and establish your HRSA compliance workplan as part of ongoing compliance efforts.
- Health Center Executive Staff
- Financial Leadership and Staff, including accounting and contracting staff
- Administrative/operations leadership and staff
- Compliance Officers
- Board members
- Other Staff assisting with HRSA compliance and/or OSV preparation
After this webinar series, you will be able to:
- Discuss the distinction between contracts and sub-awards, and the specific processes and requirements related to each (including specific contract and sub-recipient agreement terms).
- Identify an actual or potential conflict of interest under HRSA and other applicable standards.
- Describe the general requirements under 45 CFR Part 75 for appropriate financial management and accounting systems to determine whether your systems meet HRSA requirements.
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, grant administration, cost reporting, and administrative issues and routinely handles challenging issues such as government audits, internal investigations, and litigation. Ted's priority is to help each organization carry out its mission by offering practical, down-to-earth counsel and to ensure that legal challenges do not distract from that focus. [Full Bio]
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