Coronavirus 2019 (COVID-19) Frequently Asked Questions

Updated 3/26/2020

We know that many of HRSA’s Ryan White HIV/AIDS Program recipients, subrecipients, and stakeholders are concerned about coronavirus 2019 (COVID-19). HRSA's Ryan White HIV/AIDS Program recipients provide a comprehensive system of HIV primary medical care, medication, and essential support services to the most vulnerable people with HIV, and many are well positioned to play an important role in delivering critical services and assisting local communities during an emergency.

HRSA encourages Ryan White HIV/AIDS Program recipients and subrecipients to be proactive in their emergency preparedness planning. Recipients should coordinate with existing partners at the state, regional, and local level in advance to identify and define appropriate roles and responsibilities, while also taking into consideration the need to maintain ongoing access to HIV care and treatment services and medication to their patients.

Up-to-date information on the outbreak is available from the Centers for Disease Control and Prevention. COVID-19 resources for people with HIV are available on HIV.gov.

Providing HIV Care and Client Services During Emergencies

AIDS Drug Assistance Programs

Utilizing Telehealth

Resources and Oversight

Funding Opportunities, Reporting Requirements, and Upcoming Events

Travel Guidance

Grants Management

Providing HIV Care and Client Services During Emergencies

Our program’s six month recertification process requires paper applications to be mailed to our office. In an effort to limit exposure and minimize spread of COVID-19 among employees, agency case managers, and RWHAP clients, we would like to implement the following changes: allow application forms to be emailed securely to the office; allow electronic signatures for clients hesitant to come into clinics; and allow case managers working remotely to use electronic signatures. Are these proposed changes acceptable? (Updated: 3/26/2020)

HRSA’s HIV/AIDS Bureau (HAB) Policy Clarification Notice (PCN) #13-02 (PDF- 174 KB) provides guidance and flexibility for RWHAP client certification and recertification, including the ability to conduct these processes electronically and through self-attestation. PCN #13-02 does not require that such processes occur in-person, although many recipients have imposed this as an additional requirement.

In this time of public health emergency, HRSA HAB recommends flexibility in annual certification and recertification processes which support social distancing. This includes conducting these processes electronically and through self-attestation to protect the health of RWHAP clients and service providers. HRSA HAB expects RWHAP recipients will ensure that all certification and recertification processes are conducted and documented within a reasonable timeframe. Recipients and subrecipients assume the risk of recouping any HRSA RWHAP funds utilized for clients ultimately determined to be ineligible, and instead charge an alternate payment source, or otherwise ensure that funds are returned to the HRSA RWHAP.

Will it be possible to continue to provide services if the recertification process is delayed? (Updated: 3/26/2020)

HRSA’s HIV/AIDS Bureau (HAB) Policy Clarification Notice (PCN) #13-02 (PDF - 174 KB) provides guidance and flexibility for RWHAP client certification and recertification, including the ability to conduct these processes electronically and through self-attestation. PCN #13-02 does not require that such processes occur in-person, although many recipients have imposed this as an additional requirement.

In this time of public health emergency, HRSA HAB recommends flexibility in annual certification and recertification processes which support social distancing. This includes conducting these processes electronically and through self-attestation to protect the health of RWHAP clients and service providers. HRSA HAB expects RWHAP recipients will ensure that all certification and recertification processes are conducted and documented within a reasonable timeframe. Recipients and subrecipients assume the risk of recouping any HRSA RWHAP funds utilized for clients ultimately determined to be ineligible, and instead charge an alternate payment source, or otherwise ensure that funds are returned to the HRSA RWHAP.

Should RWHAP recipients revise protocols for their outpatient clinics in response to COVID-19 and move patients for whom it is appropriate to telehealth or phone appointments, encourage states to waive in-person recertification requirements during this period or encourage AIDS Drug Assistance Programs (ADAPs) to provide 90-day drug supplies? (Updated: 3/26/2020)

HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. HRSA’s HIV/AIDS Bureau (HAB) Policy Clarification Notice (PCN) #13-02 (PDF - 174 KB) provides guidance and flexibility for RWHAP client certification and recertification, including the ability to conduct these processes electronically and through self-attestation. PCN #13-02 does not require that such processes occur in-person, although many recipients have imposed this as an additional requirement. Under guidance from the Centers for Medicare and Medicaid Services and HHS Office for Civil Rights as discussed in an HHS press release on March 17, RWHAP funds for eligible clients can be used for telehealth visits with funding at same rate as face-to-face visits. 

In this time of public health emergency, HRSA HAB recommends flexibility in annual certification and recertification processes which support social distancing. This includes conducting these processes electronically and through self-attestation to protect the health of RWHAP clients and service providers. HRSA HAB expects RWHAP recipients will ensure that all certification and recertification processes are conducted and documented within a reasonable timeframe. Recipients and subrecipients assume the risk of recouping any HRSA RWHAP funds utilized for clients ultimately determined to be ineligible, and instead charge an alternate payment source, or otherwise ensure that funds are returned to the HRSA RWHAP.

HRSA HAB recommends that AIDS Drug Assistance Programs allow for longer than 30 day dispensing, at the discretion of the prescribing provider. We will be monitoring the RWHAP recipients for any challenges that may occur in terms of access to their medication as a result of COVID-19.

New Many RWHAP outreach activities in our metropolitan area have been put on hold for the time being due to developments with Coronavirus (COVID-19). Do you have any recommendations for our Prevention Outreach Counselor who is not currently in the community setting conducting HIV screenings? What are other RWHAP recipients doing with this type of scope of work? (Added: 3/25/2020)

As part of their ongoing health education services, Ryan White HIV/AIDS Program recipients can and should inform and raise awareness among their patients and the community of COVID-19 preventive measures; how to recognize symptoms of COVID-19 infection; and what to do if and when they or a member of their family gets sick. For conducting allowable outreach activities in the community, HAB defers to state and local government for guidance on community and public contact during the COVID-19 pandemic. CDC guidance for healthcare facilities and healthcare workers can be found at the CDC ‘s COVID-19 website.

How can RWHAP recipients reduce administrative burden to keep people in care and to expedite the enrollment of new clients to ensure that they get medications and medical care as rapidly as possible, given immunosuppression concerns? (Updated: 3/26/2020)

RWHAP recipients should coordinate with existing partners at the state, regional, and local level to discuss and confirm the appropriateness of emergency response plans and procedures, identify and define appropriate roles and responsibilities, and monitor for effectiveness. HRSA’s HIV/AIDS Bureau (HAB) Policy Clarification Notice (PCN) #13-02 (PDF - 174 KB) provides guidance and flexibility for RWHAP client certification and recertification, including the ability to conduct these processes electronically and through self-attestation. PCN #13-02 does not require that such processes occur in-person, although many recipients have imposed this as an additional requirement.

In this time of public health emergency, HRSA HAB recommends flexibility in annual certification and recertification processes which support social distancing. This includes conducting these processes electronically and through self-attestation to protect the health of RWHAP clients and service providers. HRSA HAB expects RWHAP recipients will ensure that all certification and recertification processes are conducted and documented within a reasonable timeframe. Recipients and subrecipients assume the risk of recouping any HRSA RWHAP funds utilized for clients ultimately determined to be ineligible, and instead charge an alternate payment source, or otherwise ensure that funds are returned to the HRSA RWHAP.

Will there be any guidance issued from HRSA HAB regarding: a. precautions for clients and case managers regarding home visits and information regarding COVID-19 for our specific HIV positive population; b. homeless or clients residing in shelters/transitional housing; c. food insecurities/household goods; d. response and support if/when a client test positive for COVID-19? (Updated: 3/26/2020)

HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some services may be more needed than others. RWHAP recipients should consult the CDC Coronavirus website and the compendium of resources on COVID-19 for people with HIV on HIV.gov, which has guidance and resources for specific populations, such as the homeless. RWHAP recipients should develop their own protocols for home visits or other service provider interactions that are responsive to their local jurisdiction needs.

Are Planning Council activities considered “essential services?" (Added: 3/20/2020)

HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities, including activities by Planning Councils, may be impacted by COVID-19 emergencies within their jurisdictions, which may impact their ability to meet grant requirements. Some Planning Council activities may be able to be conducted remotely or virtually, however, generally Planning Councils are not considered “essential services.” Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on the completion of required activities.

Does HRSA have any updates regarding COVID-19 and the ability to use RWHAP Part A funds for clients that present with symptoms as transmission increases across the U.S.? Many of our consumers are uninsured and underinsured and may not be able to afford commercial testing. (Added: 3/20/2020)

To the extent that RWHAP clients are being impacted by COVID-19 and the receipt of such services are reasonably expected to impact their HIV health outcomes, RWHAP funds can be utilized. 

New Are RWHAP recipients allowed to use RWHAP funds to purchase pre-paid cell phones for clients who may need them to support remote service provision? (Added: 3/25/2020)

Emergency Financial Assistance (EFA) is the RWHAP service category that may be used to provide pre-paid cell phones for RWHAP clients. To leverage scarce resources, the recipient should also coordinate with existing partners at the state, regional, and local level in advance to identify and define appropriate roles and responsibilities in the event of an emergency. This includes establishing relationships with local hospitals, health departments, and other large community health care providers.

New Does RWHAP Part B allow recipients to make some exceptions to our Standards of Care that would permit us to respond to clients who experience need based on COVID-19 employment/income issues? We are not looking to ease our standards for everyone since most of our SSI and SSDI recipients will be unaffected by COVID-19 in regards to their income. However, can RWHAP recipients make case-by-case decisions that are variations on our usual Standards of Care? (Added: 3/25/2020)

HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities may be postponed, modified, or extended. PCN #16-02 allows for Emergency Financial Assistance to be used as one-time or short-term payments to assist an HRSA RWHAP client with an urgent need for essential items or services necessary to improve health outcomes, including: utilities, housing, food (including groceries and food vouchers), transportation, medication not covered by an AIDS Drug Assistance Program or AIDS Pharmaceutical Assistance, or another HRSA RWHAP-allowable cost needed to improve health outcomes. Emergency Financial Assistance must occur as a direct payment to an agency or through a voucher program. Standards are determined by RWHAP recipients, however, they must be equitably applied.

Our Ryan White HIV/AIDS Program subrecipients are requesting guidance on COVID-19 policies and procedures for HIV positive clients? Should they be considering suspending support groups during this time? (Updated: 3/26/2020)

For up-to-date information on COVID-19 policies and procedures, please see the Centers for Disease Control and Prevention website and the compendium of resources on COVID-19 for people with HIV on HIV.gov. HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities may be postponed, modified, or extended. Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on the completion of required activities.

New The closure of restaurants and many other businesses has impacted many of our RWHAP patients financially, and many patients are worried about their ability to meet basic needs including food and housing. Can RWHAP Part C funding be used to help patients in these situations, such as provision of food vouchers? (Added: 3/25/2020)

HRSA’s HIV/AIDS Bureau (HAB) Policy Clarification Notice (PCN) #16-02 (PDF - 173 KB) provides information on allowable services for RWHAP recipients and subrecipients. Recipients are permitted to provide allowable support services, including emergency financial assistance, to their eligible RWHAP clients. Recipients are expected to comply with the “Uniform Guidance” stated in the Background section of PCN #16-02 in addition to the legislative and programmatic requirements of RWHAP. For more specific guidance on changes to your approved budget and scope of services, please contact your project officer to discuss any proposed changes.

New Will any clinical information/direction will be forthcoming from HRSA HAB related to care of RWHAP clients? (Added: 3/25/2020)

The U.S. Department of Health and Human Services (HHS) issues clinical guidance on HIV care and treatment. Any clinical information on HIV care and treatment for people with HIV impacted by COVID-19 will be issued by HHS. For additional guidance, please see the Centers for Disease Control and Prevention COVID-19 website.

How can Ryan White HIV/AIDS Program recipients contribute to community awareness and education to lessen the severity and impact of the COVID-19 outbreak? (Updated: 3/26/2020)

As part of their ongoing health education services, Ryan White HIV/AIDS Program recipients can and should inform and raise awareness among their patients and the community of COVID-19 preventive measures; how to recognize symptoms of COVID-19 infection; and what to do if and when they or a member of their family gets sick. Ryan White HIV/AIDS Program recipients can provide information in a culturally appropriate manner to accommodate people with limited English proficiency.

Up-to-date information about COVID-19 symptoms, prevention, and treatment is available from the CDC, including materials in Chinese and Spanish. In addition, a compendium of resources on COVID-19 for people with HIV is available on HIV.gov.

AIDS Drug Assistance Programs

Can an emergency supply of medications be provided even if the provider cannot see the patient? (Added: 3/19/2020)

This will depend on what the RWHAP client’s health care coverage and/or ADAP will allow. Each RWHAP recipient will need to review what the options are on a case-by-case basis.

Patients need to be able to get medications refilled for 90 days without a visit. Georgia just announced a 60-day policy, but should this be 90 days across the country? (Updated: 3/26/2020)

Medication refill timelines are determined by the health care coverage and/or ADAP of the RWHAP client. HRSA HAB recommends that AIDS Drug Assistance Programs allow for longer than 30 day dispensing, at the discretion of the prescribing provider.

Can requirements for ADAP and RWHAP recertification be temporarily waived? We are concerned about people being cut off drugs or services. (Updated: 3/26/2020)

HRSA’s HIV/AIDS Bureau (HAB) Policy Clarification Notice (PCN) #13-02 (PDF - 174 KB) provides guidance and flexibility for RWHAP client certification and recertification, including the ability to conduct these processes electronically and through self-attestation. PCN #13-02 does not require that such processes occur in-person, although many recipients have imposed this as an additional requirement. 

In this time of public health emergency, HRSA HAB recommends flexibility in annual certification and recertification processes which support social distancing. This includes conducting these processes electronically and through self-attestation to protect the health of RWHAP clients and service providers. HRSA HAB expects RWHAP recipients will ensure that all certification and recertification processes are conducted and documented within a reasonable timeframe. Recipients and subrecipients assume the risk of recouping any HRSA RWHAP funds utilized for clients ultimately determined to be ineligible, and instead charge an alternate payment source, or otherwise ensure that funds are returned to the HRSA RWHAP.

Are ADAPs able to work their pharmacy benefits manager partners to provide pharmacy network exceptions for patients who may not have access to their regular pharmacy? (Added: 3/19/2020)

Depending on the structure of their contracts, ADAPs may work with their pharmacy benefits manager vendor to provide alternative access to medications, however, this will vary by jurisdiction as each ADAP has a different structure and program guidelines. 

Utilizing Telehealth

Can providers do telehealth from their home or do they need to be at the RWHAP clinic? (Updated: 3/26/2020)

HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. Under guidance from the Centers for Medicare and Medicaid Services and HHS Office for Civil Rights as discussed in an HHS press release on March 17, RWHAP funds for eligible clients can be used for telehealth visits with funding at same rate as face-to-face visits.  HRSA strongly encourages RWHAP service providers that provide, or are planning to provide health services via telehealth to consult with professional organizations, regulatory bodies, and private counsel to help assess, develop, and maintain written telehealth policies that are compliant with Federal, State, and local requirements and applicable standards of practice. Likewise, HRSA encourages RWHAP service providers to consider the range of issues that would support successful implementation of telehealth. As a reminder, PCN #16-02 (PDF - 176 KB) encourages service providers to consider all methods of providing services, including the use of technology (e.g., telehealth).

Can a telephone call count as a telehealth visit? (Updated: 3/26/2020)

HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. Under guidance from the Centers for Medicare and Medicaid Services and HHS Office for Civil Rights as discussed in an HHS press release on March 17, RWHAP funds for eligible clients can be used for telehealth visits with funding at same rate as face-to-face visits.  HRSA strongly encourages RWHAP service providers that provide, or are planning to provide health services via telehealth to consult with professional organizations, regulatory bodies, and private counsel to help assess, develop, and maintain written telehealth policies that are compliant with Federal, State, and local requirements and applicable standards of practice. Likewise, HRSA encourages RWHAP service providers to consider the range of issues that would support successful implementation of telehealth. As a reminder, PCN #16-02 (PDF - 176 KB) encourages service providers to consider all methods of providing services, including the use of technology (e.g., telehealth).

Resources and Oversight

Will HRSA’s HIV/AIDS Bureau be conducting site visits as scheduled? (Added: 3/19/2020)

HRSA’s HIV/AIDS Bureau is monitoring and following the recommendations of the CDC. With that in mind, and given the potential impact of COVID-19 on RWHAP service providers and clients, HAB will postpone all planned on-site comprehensive, diagnostic, and technical assistance until a later date to be determined. This decision is made in consideration of the potential impact to RWHAP recipient operations during the COVID-19 outbreak, HAB staff, and consultants as well as the need for staff to be available for immediate mission critical assignments. There may be some circumstances in which a virtual site visit would be possible. Your Project Officer will work with you to assess that option. Site visits are an important part of the RWHAP monitoring and oversight process; therefore, HAB will reschedule the postposed site visits as soon as it is practicable.

Can any measure be taken to ensure that HIV clinics have the equipment and supplies they need for treating people with COVID-19? Many clinics are ill prepared to treat patients with COVID-19. Clinics do not have adequate Personal Protective Equipment (PPE). Even things like cleaning supplies and gloves are dwindling and cannot even be found at local grocery stores if a clinic runs out. (Added: 3/19/2020)

If a RWHAP clinic’s regular distributors are unable to fulfill orders for critical medical supplies such as PPE, the first step is to contact your local and/or state public health department for immediate assistance. If the state is unable to provide supplies, state health officials — through the governor or his/her representative — may request federal assistance from the U.S. Department of Health and Human Services (HHS).

If assistance is approved, the HHS Assistant Secretary for Preparedness and Response will direct deployment of supplies from the Strategic National Stockpile to state public health officials. The state is then responsible for distributing the supplies to areas in need. We understand the difficulty of this situation, but the state department of health is your best option for assistance with needed supplies.

New Can a RWHAP recipient-funded staff be assigned COVID-19 duties during a State declared public health emergency? (Added: 3/25/2020)

A Governor of a state, local or tribal organization or their designee may request to temporarily reassign state and local public health department, tribal, or agency personnel funded in whole or in part through programs authorized under the PHS Act to immediately address a public health emergency in the state or Indian tribe during the period of the emergency. Detailed information, including Guidance for Temporary Reassignment of State and Local Personnel during a Public Health Emergency, is available on the Assistant Secretary for Preparedness and Response (ASPR) website. To request the temporary reassignment of personnel, a state governor, tribal leader, or designee must complete the Request for the Temporary Reassignment of State, Tribal, and Local Personnel During a Public Health Emergency Declared by the HHS Secretary and submit it to TemporaryReassignment@hhs.gov. Please ensure that the authorizing program legislation does not prohibit this provision.

Funding Opportunities, Reporting Requirements, and Upcoming Events

New Has HRSA has made a decision to extend grant submission deadlines amid the COVID-19 pandemic, or will HRSA consider extending grant submission deadlines on a case by case basis? (Added: 3/25/2020)

At this moment, the Notice of Funding Opportunity (NOFO) submission deadline for HRSA-20-067 has been extended to April 23, 2020. However the NOFO deadline for HRSA-20-069 remain unchanged. We encourage you, if possible, to submit an application prior to the published deadline in Grants.gov. We will continue to monitor and assess if, and when, the deadline for this NOFO needs to be extended.

Regarding NOFO submissions in general: If your organization is unable to submit the application in a timely manner due to justified circumstances, you can request an extension of a NOFO published deadline. HRSA’s Division of Grants Policy (DGP) in the Office of Federal Assistance Management is the only office authorized to grant waivers. DGP may consider an extension of published deadlines or allowance of a submission outside of the Grants.gov system, when justified by circumstances such as natural disasters (e.g., floods or hurricanes), other disruptions of services (e.g., a prolonged blackout), or in the rare event of a validated technical issue on the side of the government that prevented you from applying before the deadline. DGP will determine the affected geographical area(s) or other applicant group parameters. You must contact the Division of Grants Policy at HRSA, within 5 calendar days from the closing date, via email at DGPWaivers@hrsa.gov and provide a detailed explanation. Your email must include the HRSA funding opportunity number, the name, address, and telephone number of the organization, the organization’s DUNS number, and the name and telephone number of the Project Director. Extensions for funding opportunity deadlines are only granted in the rare event of a natural disaster or validated technical system problem on the side of the Government that prevented a timely application submission (Refer to SF-424 Application Guide on pages 14-15 and 48).

What is the status of the 2020 National Ryan White Conference on HIV Care & Treatment? (Added: 3/17/2020)

HRSA’s HIV/AIDS Bureau has heard from several Ryan White HIV/AIDS Program recipients about novel coronavirus 2019 (COVID-19) and if/how it may impact the 2020 National Ryan White Conference on HIV Care & Treatment in Washington, DC in August 2020.

With the meeting five months away, at this time, we are planning to proceed with the conference. We will continue to monitor the situation and let you know if anything changes as it evolves. Your health, well-being and safety are the priority. We will be in touch in the weeks and months ahead. In the meantime, don’t hesitate to reach out if you have questions or concerns regarding the National Conference.

Will there be a change to the reporting deadline for the Ryan White HIV/AIDS Program Services Report? (Added: 3/17/2020)

HRSA’s HIV/AIDS Bureau is extending the RWHAP Services Report (RSR) reporting deadline by 30 days to Thursday, April 30, 2020. The RSR is open and recipients can submit as early as possible; however, data will be accepted through April 30, 2020. We will continue to monitor COVID-19 activities and assess the impact on RWHAP recipient and subrecipient activities. As always, DART and Data Support Exit Disclaimer are available to assist you with any technical assistance needs.

Given its impact on the elderly, will COVID-19 be discussed on HRSA’s upcoming aging and HIV webinar series? (Added: 3/17/2020)

Currently, COVID-19 and its impact on the aging and elderly, and particularly people with HIV, is not included in the webinar content/agenda. We will remain vigilant of the developments surrounding the spread of the virus, and consider whether adjustments in content/agenda are appropriate moving forward. We encourage recipients to refer to guidance available from the U.S. Department of Health and Human Services (HHS), as well guidance from their state and local health departments.

Travel Guidance

Would HRSA’s HIV/AIDS Bureau provide guidance around recipient travel? (Updated: 3/19/2020)

HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities, including those requiring travel, may be postponed. Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on restarting any postponed or cancelled activities.

We have annual site visits scheduled in the coming weeks. As part of our COVID-19 preparations, we are reevaluating all upcoming planned air travel. Are we able to postpone these site visits until the COVID-19 situation becomes clearer? (Updated: 3/19/2020)

On March 13, 2020, the President declared a national emergency. HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities, such as subrecipient site visits, may be postponed. Once the emergency has waned, we will work with you on restarting the completion of those activities.

New Can we charge cancellation fees due to COVID-19 to the grant, such as air tickets, hotels, and conference expenses? (Added: 3/26/2020)

Yes. Per guidance issued by Office of Management and Budget (OMB) Memo M-20-17 (PDF - 5.5 MB), HRSA recipients may charge full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Recipients should not assume that additional funds will be available should the charging of cancellation or other fees result in a shortage of funds to eventually carry out the event or travel. Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 - Financial management and standards for financial management systems and 45 CFR § 75.361 - Retention requirement for records to substantiate the charging of any cancellation or other fees related to interruption of operations or services.

Grants Management

Is there is a protocol for paying invoices and/or agencies if they have to shut down? (Updated: 3/25/2020)

The recipient should coordinate with existing partners at the state, regional, and local level in advance to identify and define appropriate roles and responsibilities in the event of an emergency. This protocol is not specific to the Health Resources and Services Administration’s HIV/AIDS Bureau, and it would depend on what the Emergency Preparedness plan is for the jurisdiction.

Additionally, HRSA will allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Further, HRSA will allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. HRSA will also evaluate the grant recipient's ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances based on subsequent progress reports and other communications with the grant recipient. Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 - Financial management and 45 § 75.361 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. (OMB M-20-17)

New What can our provider network bill for if they have to shut down temporarily due to coronavirus. Does HRSA have a stance/policy on this? We allow for telehealth visits in our service standard, so virtual visits are happening, we just aren’t sure about the other staff. (Added: 3/25/2020)

The recipient should coordinate with existing partners at the state, regional, and local level in advance to identify and define appropriate roles and responsibilities in the event of an emergency. This protocol is not specific to the Health Resources and Services Administration’s HIV/AIDS Bureau, and it would depend on what the Emergency Preparedness plan is for the jurisdiction.

HRSA strongly encourages RWHAP service providers that provide, or are planning to provide health services via telehealth or other means to consult with professional organizations, regulatory bodies, and private counsel to help assess, develop, and maintain written telehealth policies that are compliant with Federal, State, and local requirements and applicable standards of practice. Likewise, HRSA encourages RWHAP service providers to consider the range of issues that would support successful implementation of telehealth alternative means of service delivery, including but not limited to telehealth.

Additionally, HRSA will allow recipients to continue to charge salaries and benefits to currently active Federal awards consistent with the recipients' policy of paying salaries (under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Further, HRSA will allow other costs to be charged to Federal awards necessary to resume activities supported by the award, consistent with applicable Federal cost principles and the benefit to the project. HRSA will also evaluate the grant recipient's ability to resume the project activity in the future and the appropriateness of future funding, as done under normal circumstances based on subsequent progress reports and other communications with the grant recipient. Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 - Financial management and 45 § 75.361 - Retention requirement of records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services. (OMB M-20-17)

New A RWHAP subrecipient provider agency has been shut down because one of their staff members tested positive for COVID-19. As a result, this agency will not be able to submit their final voucher by our deadline. Could HRSA provide guidance or extend the deadline? (Added: 3/25/2020)

HRSA’s HIV/AIDS Bureau recognizes that many recipients are working to address or may be impacted by COVID-19 emergencies within their jurisdictions, which may impact their ability to meet grant requirements. We encourage recipients to continue to provide RWHAP services and grant activities in a safe and efficient manner. Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on the completion of required activities.

As COVID-19 evolves, we expect that it will impact our operations. How do we need to document that for the grant? Specifically we expect that the increased need for people to quarantine and the various guidance about limiting meetings/interaction/reducing services, especially with regards to the most vulnerable populations, will impact the ability of some of our funded agencies to carry out some services to meet objectives and our ability to conduct site visits. (Added: 3/20/2020)

HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities may be postponed, modified, or extended. Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on the completion of required activities.

How should Ryan White HIV/AIDS Program recipients manage client services in the event that a critical staff member with no backup comes down with COVID-19 and needs to be quarantined? (Updated: 3/25/2020)

HRSA’s HIV/AIDS Bureau recognizes that many recipients are working to address or may be impacted by COVID-19 emergencies within their jurisdictions, which may impact their ability to meet grant requirements. We encourage recipients to continue to provide RWHAP services and grant activities in a safe and efficient manner. Please talk with your project officer regarding alternative approaches to planned activities. Once the emergency has waned, we will work with you on the completion of required activities.

Can recipients use grant funds to pay salaries for staff on the budget who are not in the office due to clinic closures because of COVID-19? (Updated: 3/26/2020)

Yes. Per guidance issued by Office of Management and Budget (OMB) Memo M-20-11 and M-20-17, HRSA HAB recipients may continue to charge salaries and benefits to currently active awards consistent with their organization's policy of paying salaries under unexpected or extraordinary circumstances) from all funding sources, Federal and non-Federal. Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 - Financial management and standards for financial management systems and 45 CFR § 75.361 - Retention requirement for records to substantiate the charging of any salaries and other project activities costs related to interruption of operations or services.

Date Last Reviewed:  March 2020