2. Grants Management
This chapter outlines areas related to the management of the Health Resources and Services Administration’s (HRSA) HIV/AIDS Bureau’s (HAB) AIDS Drug Assistance Program (ADAP) earmarked funds and Title II funds allocated to ADAPs, including conditions of award and the carry over of funds.
Attachment: Sample Notice of Grant Award with ADAP-specific Special Conditions and Special Remarks.
The Grants Management Branch (GMB) of the Health Resources and Services Administration's (HRSA) HIV/AIDS Bureau (HAB) oversees all aspects of the awards to Title II/AIDS Drug Assistance Program (ADAP) grantees. The GMB serves as the counterpart to the business office of the grantee and is responsible for all business management aspects associated with the review, negotiation, award, and administration of grants.
The functions of the GMB include, but are not limited to, the following:
The Title II/ADAP grantee is responsible for the proper stewardship of all grant funds. The grantee needs to establish sound and effective business management systems to assure the proper stewardship of funds and activities. These systems must meet the requirements outlined by the Office of Management and Budget (OMB) for recipients of Federal funding.
Title II/ADAP grantees can find relevant information regarding the administration of grants in the following two OMB circulars:
These two OMB circulars provide grantees with the minimum requirements or explanations for some of the following subjects:
Costs Applicable to Grants and Contracts
The following OMB resources establish principles and standards for determining costs applicable to grants, contracts, and other agreements entered into by the types of organizations specified:
Audit Policies and Standards
The following OMB resource provides government-wide policies and standards for non-Federal organization-wide audits of recipients of Federal awards:
For additional guidance, ADAP grantees may also utilize the April 1, 1994, Public Health Service (PHS) Grants Policy Statement, which was provided by the GMB to grantees when they received their first award. This policy statement compiles policies and reviews policy issues that have been raised in the past regarding the administration of grant awards.
The information provided in this chapter about conditions of award is not sufficient alone to guide grantees on their grants management deadlines and obligations. Only the current Notice of Grant Award sufficiently identifies actual deadlines and obligations for Title II/ADAP grantees.
In the administration of Title II/ADAP awards, grantees are responsible for meeting all special conditions and fulfilling all reporting requirements indicated in the Notice of Grant Award (NGA). Because each NGA includes dates and deadlines that are specific to that budget period, it is very important that Title II/ADAP grantees follow the special conditions and reporting requirements for the appropriate budget period. Always be sure to consult the Notice of Grant Award for the current budget period to identify deadlines and obligations for the Title II/ADAP grant expenditures.
Failure to comply with any of the special conditions and reporting requirements of award by the specified due date may result in the suspension of the grantee's ability to draw down funds and/or the disallowance of funds.
In addition, the NGA includes a Special Remarks section, a Standard Remarks section, and a Contacts section. The Special Remarks section contains information such as matching requirements, expenditure limitations, and the dollar amount included in the award for a specific activity (e.g., Minority AIDS Initiative funding, AIDS Drug Assistance Program funding, etc.). The Standard Remarks section contains general grants administration information. Names, addresses, and telephone numbers of persons to contact regarding grants management issues and/or programmatic issues are located in the Contacts section of the NGA.
Requests for the carry-over of funds from the previous to current budget period must be submitted to the GMB. Carry-over requests are reviewed on a case-by-case basis. HAB retains the authority to offset future grant awards and reallocate unspent funds to other Title II grantees. As always, it is incumbent on the grantee to expeditiously and effectively utilize Title II funds to meet the needs of people living with HIV disease (PLWH).
In reviewing requests for approval of carry-over funds, HAB will continue to assess the following:
HAB will review any requests for carry-over of ADAP dollars and request that the grantee address any of the following program restrictions:
Also, with regard to the intended purpose and budget justification, HAB will require grantees to address the following issues:
Requests for early and partial emergency advance awards must be submitted to the GMB, HAB, HRSA. HAB has considered requests for partial emergency advances in the past. However, there is no guarantee that this advancement will continue. ADAPs should not assume that emergency awards would be offered in the future. In Fiscal year 1999, HRSA made these awards from the FY 1999 Title II appropriations earmark for ADAPs. Emergency awards were made for use during the remainder of the Title II budget period, which ended 03/31/99. Awards were only made to States that:
It should be noted that HRSA did not make any "early advance" awards during the FY 2000, 2001 budget periods.
MAINTENANCE OF EFFORT
The Ryan White Comprehensive AIDS Resources Emergency (CARE) Act of 2000 requires Title II grantees (i.e., each of the 50 States, the District of Columbia, the Islands and Territories) to maintain State expenditures for HIV-related activities at a level equal to the one-year period preceding the Fiscal year for which the grantee is applying to receive a Title II grant. This maintenance of effort requirement has been in the CARE Act since its inception in 1990. To demonstrate compliance with this provision, States need to maintain adequate systems for consistently tracking and reporting HIV-related expenditure data from year to year.
Grantees are accountable to ensure that Federal funds do not displace State spending but instead expand HIV-related activities. An audit conducted in 1996 by the Office of the Inspector General, Department of Health and Human Services, recommended that HRSA establish formal parameters to standardize how CARE Act grantees meet the maintenance of effort requirement.
For complete information on the Maintenance of Effort, please see Section II, Chapter 2 of the Title II Manual.
Sources Used for This Chapter
HRSA, HIV/AIDS Bureau, Division of Service Systems. "Grants Management." Ryan White Care Act Title II Manual. Rockville, MD: U.S. Department of Health and Human Services, 1999, revised 2002.
To Obtain Publications Mentioned in This Chapter
All of the OMB Circulars mentioned in this chapter are available from the Office of Federal Financial Management, Office of Management and Budget, 725 17th Street NW, Room 6025, Washington, DC 20503; telephone (202) 395-7332.
The OMB Circulars may be obtained online.
Hard copies of the PHS Grants Policy Statement (April 1, 1994) are no longer in publication. The PHS Grants Policy Statement (April 1, 1994) may be obtained online.