Coronavirus Disease 2019 (COVID-19) Frequently Asked Questions

Updated 5/26/2020

HRSA understands the important work Ryan White HIV/AIDS Program recipients, subrecipients, and stakeholders are doing in response to the coronavirus disease 2019 (COVID-19) public health emergency. We are updating this page regularly as information becomes available.

FY 2020 CARES Act Funding for Ryan White HIV/AIDS Program Recipients

HRSA HAB All Grant Recipient Resources

  • HRSA HAB All Grant Recipient Webinar (5/20/2020) Audio* (MP3 - 8 MB) | Webinar Replay Exit Disclaimer
  • HRSA HAB All Grant Recipient Call (4/30/2020) Audio* (MP3 - 6 MB) Transcript* (PDF - 131 KB)
  • HRSA HAB All Grant Recipient Webinar (4/15/2020) Audio* (MP3 - 5.8 MB) | Transcript* (PDF - 54.5 KB) | Webinar Replay Exit Disclaimer
  • HRSA HAB All Grant Recipient Call (3/26/2020) Audio* (MP3 - 6.7 MB)

Resources for Updated Information

The answers on this page are organized into the following categories:

CARES Act Funding

Reporting Requirements

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

CARES Act Funding

Will Ryan White HIV/AIDS Program recipients be eligible for federal funding from the FY 2020 CARES Act legislation signed into law? (Updated: 4/15/2020)

On April 15, 2020, the U.S. Department of Health and Human Services (HHS), through the Health Resources and Services Administration (HRSA), awarded $90 million for Ryan White HIV/AIDS Program recipients across the country to prevent, prepare for, and respond to coronavirus disease 2019 (COVID-19). This funding is provided by the fiscal year 2020 Coronavirus Aid, Relief and Economic Security (CARES) Act, which President Trump signed into law on Friday, March 27, 2020.

What is the purpose of the FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients? (Added: 4/15/2020)

The fiscal year (FY) 2020 Coronavirus Aid, Relief and Economic Security Act -P.L. 116- 136 (CARES Act) provides one-time funding for eligible health care providers, including current Health Resources and Services Administration (HRSA) Ryan White HIV/AIDS Program (RWHAP) recipients to prevent, prepare for, and respond to coronavirus disease 2019 (COVID-19). 

For Ryan White HIV/AIDS Program recipients, the funding is directed to clinics and community based organizations, city/county health departments, state health departments, the AIDS Education and Training Centers, and the AIDS Drug Assistance Program Technical Assistance and Training Program for preventing, preparing for, and responding to COVID-19 for RWHAP clients, including expenses related to extended operating hours, increased staffing hours (overtime), additional equipment, workforce training and capacity development, and services to support social distancing, such as home delivered meals and transportation. All activities and purchases supported with FY 2020 CARES Act funding for RWHAP recipients must be used for services, activities, and supplies needed to prevent or minimize the impact of COVID-19 on RWHAP clients.

Can Ryan White HIV/AIDS Program recipients use FY 2020 Coronavirus Aid, Relief, and Economic Security (CARES) Act funding to pay providers who are not working on COVID-19 related activities? (Added: 4/15/2020)

No. If RWHAP recipients are isolating providers in order to minimize spread, the FY 2020 CARES Act funding for RWHAP recipients may not be used to pay the salaries of providers that are not involved in the COVID-19 response.

How was the amount of FY 2020 CARES Act funding determined for each Ryan White HIV/AIDS Program award recipient? (Updated: 4/22/2020)

For Ryan White HIV/AIDS Program (RWHAP) Parts A, B and C, 2018 Ryan White HIV/AIDS Program Services Report (RSR) data were used to develop the funding methodology, focusing on the numbers of clients served. For RWHAP Part D, the funding methodology was based on FY 2019 funding amounts. 

Note that for RWHAP Parts A and B, using RSR data (the number of clients reported as receiving a service in each jurisdiction through RWHAP) are different from using Centers for Disease Control and Prevention surveillance data (the number of people living with HIV and AIDS in that jurisdiction) on which Part A H89 and Part B X07 awards are based.

Do Ryan White HIV/AIDS Program recipients need to apply for the FY 2020 CARES Act funding? (Added: 4/15/2020)

To expedite distribution of this critical funding, HRSA plans to make funds immediately available and subsequently collect budget plans. Recipients will receive reporting instructions for the project narrative and budget information that must be provided within 30 days of receiving the FY 2020 CARES Act award.

When can Ryan White HIV/AIDS Program recipients begin using the FY 2020 CARES Act funding? (Added: 4/15/2020)

Upon receipt of the award.

Why was the FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients issued through a supplemental award? (Added: 4/15/2020)

The FY 2020 CARES Act authorized supplements to existing grants and cooperative agreements. To support tracking of CARES Act spending across different parts of the government, FY 2020 CARES Act awards were issued separately from a Ryan White HIV/AIDS Program recipient’s grant award. Ryan White HIV/AIDS Program recipients will need to separately track and account for their COVID-19 prevention, preparedness, and response-related activities supported through this funding.

What is the period of performance for the use of the FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients? (Added: 4/15/2020)

The period of performance for this funding is 12 months. Funding is available for immediate use, and pre-award costs are permitted for COVID-19 prevention, preparedness, and response-related expenses dating back to January 20, 2020.

What are allowable uses of the FY 2020 CARES Act funding? (Updated: 4/30/2020)

All Ryan White HIV/AIDS Program COVID-19 activities and purchases supported with FY 2020 CARES Act funding must be used for services, activities, and supplies needed to prevent or minimize the impact of COVID-19 on RWHAP clients.

The CARES Act provision for the Ryan White HIV/AIDS Program offers recipients some flexibility to address COVID-19 related health and support needs of clients. See Examples of Coronavirus Aid, Relief, and Economic Security (CARES) Act Supplemental Funding Uses and Ryan White HIV/AIDS Program Service Categories for more information.

The FY 2020 CARES Act funding will primarily support core medical and support services for RWHAP clients. Funds also are being allocated to technical assistance programs to ensure that HIV healthcare organizations and professionals have timely access to the most current training and technical assistance needed to address COVID-19 related issues impacting people with or at risk for HIV. These funds are being awarded to the following RWHAP technical assistance programs to address the surge in workforce development needs as a result of challenges presented by COVID-19: 

  • AIDS Education and Training Centers (AETC), National Clinician Consultation Center (NCCC)
  • AETC, Enhancement and Update of the National HIV Curriculum (NHC) e-Learning Platform
  • AETC, National Coordination and Resource Center
  • AETC, Regional Centers
  • Ryan White HIV/AIDS Program- AIDS Drug Assistance Program (ADAP) Training and Technical Assistance Program

How should FY 2020 CARES Act funded Ryan White HIV/AIDS Program recipients allocate their funding? Do activities need to map to a RWHAP service category? Can recipients allocate funds for services that are not currently funded by the EMA? For example, if an agency only receives case management but needs EFA, can the recipient fund them for EFA under the FY 2020 CARES Act grant? (Added: 5/13/2020)

Funding has been appropriated under the Coronavirus Aid, Relief and Economic Security (CARES) Act (P.L. 116-136) to help Ryan White HIV/AIDS Program (RWHAP) recipients prepare for, prevent, and respond to the COVID-19 pandemic. All activities and purchases supported with FY 2020 CARES Act funding must be used for services, activities, and supplies needed to prepare for, prevent, and respond to COVID-19 with respect to RWHAP clients.

FY 2020 CARES Act funding should be allocated to RWHAP service categories as outlined in PCN 16-02 (PDF - 172 KB). Allocations are not limited to those service categories that the recipient currently funds under the RWHAP award, so long as they are allowable and meet the purposes of the FY 2020 CARES Act funding. Please see the Examples of Allowable Uses of Funds (PDF - 200 KB) document.

Recipients should use their existing processes to allocate funding, except that Planning Council/Planning Body allocations are waived for FY 2020 CARES Act funding. See communication regarding waived requirements sent on April 30, 2020.

Are the Ryan White HIV/AIDS Program administrative caps applicable to the FY 2020 CARES Act awards? (Added: 4/15/2020)

Yes, recipients are required to comply with RWHAP administrative cost caps.

Administration/Planning and Evaluation - Administration costs are costs associated with the administration of the grant. No more than 10 percent of the budget can be spent on administrative costs. Recipients should allocate staff activities that are administrative in nature to administrative costs. The aggregate total of administrative expenditures for RWHAP Parts A and B subrecipients, including all indirect costs, may not exceed 10 percent of the aggregate amount of all subawards.

For RWHAP Parts A and B administration and planning and evaluation costs combined should not exceed 15 percent of the total award.

For RWHAP Parts C and D total administrative costs should not exceed 10 percent of the total award. Indirect expenses must be considered administrative expenses subject to the 10 percent cap under Part D.

Can awarded Ryan White HIV/AIDS Program recipients use funds from the FY 2020 CARES Act to assist with telehealth visit costs? (Added: 4/22/2020)

The fiscal year (FY) 2020 Coronavirus Aid, Relief and Economic Security Act -P.L. 116- 136 (CARES Act) provides one-time funding for eligible health care providers, including current Health Resources and Services Administration (HRSA) Ryan White HIV/AIDS Program (RWHAP) recipients to prevent, prepare for, and respond to coronavirus disease 2019 (COVID-19). HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. 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).

Do Ryan White HIV/AIDS Program Part A Planning Councils have to prioritize and allocate the FY 2020 CARES Act funds? (Added: 5/13/2020)

Planning councils are charged with determining the size and demographics of the population, determining the needs of the population, establishing priorities, developing comprehensive plans, assessing the efficiency of administrative mechanisms, participating in the development of the statewide coordinated statement of need, establishing methods of obtaining input, and coordinating with Federal grant recipients that provide HIV-related services. However, in regard to the FY 2020 CARES Act funds for RWHAP recipients, planning council responsibilities are waived. § 2602(b)(4) of the Public Health Service (PHS) Act.

Can funds from a FY 2020 CARES Act award be used to purchase and administer COVID-19 tests to household members of a RWHAP-eligible client that tested positive for COVID-19? These household members do not meet RWHAP eligibility criteria. (Added: 5/4/2020)

Yes. FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients may be used to pay for personal protective equipment (PPE) for household/family members living in the same home as the RWHAP client because this is an essential item necessary to preserve the health and well-being of the RWHAP client receiving HIV-related care and treatment services. See Policy Clarification Notice 16-02 (PDF - 172 KB), Emergency Financial Assistance (EFA). Note: EFA must occur as a direct payment to an agency or through a voucher program.

FY 2020 CARES Act funding may also be used for COVID-19 testing of household/family members that present with COVID-19 symptoms living in the same home as RWHAP clients.

Under the FY 2020 CARES Act award, can attending clinicians be tested subsequently and how would that test for the clinician be reported? (Added: 5/13/2020)

Under the FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients, the requirement to provide services only to people with HIV is waived in the extremely limited instances of household members living with Ryan White HIV/AIDS Program clients, and only for COVID-19 testing and the provision of personal protective equipment (PPE). In this situation, this would be an unallowable cost.

Can a RWHAP Part A recipient categorize masks under the Food Bank/Home Delivered Meals service category? We plan to offer RWHAP eligible clients cleaning supply kits, which include masks. (Added: 5/13/2020)

Yes, RWHAP recipients may provide PPE, specifically protective masks, under the Food Bank/Home-Delivered Meals service category with FY 2020 CARES Act funds as they are considered personal hygiene items. 

Is there additional guidance for submission of the work plan and budget for FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients? (Added: 5/13/2020)

Within 30 days of award release date, FY 2020 CARES Act Ryan White HIV/AIDS Program awarded recipients must submit the following: (1) SF424-A Budget Form, (2) Budget Narrative, (3) Project Overview, and (4) Equipment List Form (if applicable). Recipients must submit the report on-line in the Electronic Handbooks (EHB) system.

See FY 2020 CARES Act Funding for Ryan White HIV/AIDS Program Recipients for instructions to support your submission, as well as details for technical assistance calls to address your submission questions.

Can a RWHAP recipient use program income generated from their underlying RWHAP Part C or D grant to pay for FY 2020 CARES Act-allowable RWHAP activities? (Added: 5/4/2020)

No. Program income earned as a result of the RWHAP award must be used for the purposes and under the conditions of the RWHAP award. Likewise, program income earned as a result of the FY 2020 CARES Act funding must be used for the purposes and under the conditions of the FY 2020 CARES Act funding for RWHAP recipient.

Is it an allowable cost under the FY 2020 CARES Act funding for RWHAP recipients to use emergency financial assistance to purchase face masks (PPE) so that clients can receive essential services in instances where masks are required due to a county ordinance requiring face masks be used in public? (Updated: 4/30/2020)

Funding has been appropriated under the Coronavirus Aid, Relief and Economic Security (CARES) Act (P.L. 116- 136) to help Ryan White HIV/AIDS Program (RWHAP) recipients prepare for, prevent, and respond to the COVID-19 pandemic. This funding has been appropriated to support recipients as they respond to COVID-19 related health service needs. All activities and purchases supported with FY 2020 CARES Act funding for RWHAP recipients must be used for services, activities, and supplies needed to prepare for, prevent, and respond to COVID-19 with respect to RWHAP clients.

In the Examples of Allowable Uses of Funds (PDF - 200 KB), allowable costs include, but are not limited to:

  • Purchase supplies for respiratory hygiene and cough etiquette, including alcohol-based hand sanitizer that contains 60-95% alcohol, tissues, and no-touch receptacles for disposal.
  • Purchase personal protective equipment (PPE) for RWHAP recipient personnel and RWHAP clients, including National Institute for Occupational Safety and Health (NIOSH)-approved N95 respirators for RWHAP recipient personnel.

Can FY 2020 CARES Act funding for Ryan White HIV/AIDS Program ADAP recipients be used to purchase health insurance for eligible clients? Specifically, do they have the authority to do so with these funds? (Added: 4/27/2020)

AIDS Drug Assistance Program (ADAP) services are included in RWHAP Part B. The Part B authority includes the purchase of health insurance as an allowable cost. FY 2020 CARES Act funding should not supplant cost/activities already covered by fiscal year appropriations. HRSA would follow-up with any recipients as needed to ensure appropriate use of funds.

Medical services allowable under the Ryan White HIV/AIDS Program are also allowable under the FY CARES Act funding for Ryan White HIV/AIDS Program recipients. See PCN 18-01 (PDF - 85 KB) for information related to payment of health insurance premiums and copayments under Ryan White HIV/AIDS Program Parts A, B, ADAP, C, and D.

Can FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients be used to cover lost revenue for HAB supplemental awards? (Added: 4/27/2020)

In alignment with OMB M-20-17, HRSA will provide flexibilities to recipients by reviewing the allowability of costs not normally chargeable to awards. HRSA provides additional information on our Grants site.

Cost Principles (45 CFR Part 75, Subpart E) must be used in determining allowable costs that may be charged to a HRSA award. Costs must be necessary and reasonable to carry out grant approved project activities, allocable to the funded grant project, and allowable under the Cost Principles, or otherwise authorized by the grant program statute. The treatment of costs must be consistent with recipient or sub-recipient policies and procedures that apply uniformly to both federally-financed and other non-federally funded activities.

Costs that are not described in the funding opportunity or based in the referenced grant program statute are not approvable under a HRSA grant. Items that would not have been approved prior to COVID-19 are not allowed under the OMB M-20-17 flexibilities.

Can the FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients be used for grocery store gift cards if access to a food pantry is not available?  Would that need to come under Emergency Financial Assistance (EFA) or is there more flexibility with this funding? (Added: 5/13/2020)

HRSA HAB encourages promoting access to and continuity of care in a safe way during social distancing PCN #16-02 (PDF - 173 KB) allows for EFA 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. HRSA RWHAP recipients are encouraged to administer voucher and store gift card programs in a manner which assures that vouchers and store gift cards cannot be exchanged for cash or used for anything other than the allowable goods or services, and that systems are in place to account for disbursed vouchers and store gift cards.

Are Ryan White HIV/AIDS Program Part A recipients allowed to use the FY 2020 CARES Act funds for household/family members of RWHAP consumers? This would be for COVID-19 testing and personal protective equipment (PPE) distribution. (Added: 4/29/2020)

Yes. FY 2020 CARES Act funding may be used to pay for PPE for household/family members living in the same home as the RWHAP client because this is an essential item necessary to preserve the health and well-being of the RWHAP client receiving HIV-related care and treatment services. See Policy Clarification Notice 16-02 (PDF - 172 KB), Emergency Financial Assistance (EFA). Note: EFA must occur as a direct payment to an agency or through a voucher program.

FY 2020 CARES Act funding may also be used for COVID-19 testing of household/family members that present with COVID-19 symptoms living in the same home as RWHAP clients.

Reporting Requirements

New How do providers submit the COVID-19 Data Report (CDR) to the HIV/AIDS Bureau? Do they submit them through the electronic handbooks (EHBs)? Will Ryan White HIV/AIDS Program recipients need to review their providers’ CDRs? (Added: 5/18/2020)

All providers (recipient-providers, subrecipient-providers, and second-level providers) who used FY 2020 CARES Act funding to provide RWHAP core medical or support services will submit the CDR to the HIV/AIDS Bureau.  Directly-funded recipient providers will log in through the EHBs to submit the CDR. Subrecipient-providers and second-level providers will log in through the HAB Web Applications system to submit the CDR. Instructions will be available shortly. Recipients will not need to review and approve the provider CDRs, however will be able to access the submissions to review.

New For the data report, how do FY 2020 CARES Act funded Ryan White HIV/AIDS Program recipients report a person/individual who is in the same household with a RWHAP- eligible client for COVID-19 testing who is not HIV positive? (Added: 5/18/2020)

The monthly COVID-19 Data Report (CDR) will collect information on both RWHAP-eligible clients and immediate household members. The requirement to serve only people with HIV is waived for the FY 2020 CARES Act funding to include immediate household members.  For the number of people tested, please include RWHAP-eligible clients and immediate household members.

New What is the guidance that FY 2020 CARES Act funded Ryan White HIV/AIDS Program recipients need to follow on unduplicated clients? (Added: 5/18/2020)

The number entered in the field for the Total number of clients served with FY 2020 CARES Act funding should be the deduplicated client count.  By service category, providers should report the number of clients who received each service using FY 2020 CARES Act funding; if clients receive multiple services, they would appear in the count for each category.  The numbers in the service categories will likely sum to more than the Total deduplicated count.  In addition, each client served should be counted only one time in each service category they receive, regardless of the number of visits in that service category (i.e., a client who received four case management visits within one month would be counted as one client, not four visits). This information will be included in the instruction manual.

New  Regarding the FY 2020 CARES Act funding for Ryan White HIV/AIDS Program clients, what level of detail is going to be required for any client level reporting? (Added: 5/18/2020)

The COVID-19 Data Report (CDR) is aggregate-level data only, reported for RWHAP-eligible clients and immediate household members. However, client-level data on RWHAP-eligible clients should be included in the RSR; all client-level information for the RSR will be required.

New If FY 2020 CARES Act funds are used to purchase PPE in bulk for Ryan White HIV/AIDS Program clients and subrecipient staff, under what service would it fall? (Added: 5/18/2020)

Bulk purchases of PPE should be proportionally allocated across the relevant service categories according to a reasonable methodology.

New Are FY 2020 CARES Act funds bound by the parameters of specific Ryan White HIV/AIDS Program service categories? For example if a medical case management (MCM) program needs to buy prepaid cell phones for RWHAP clients, but does not currently get funding for Emergency Financial Assistance (EFA), which is how they normally have to purchase, can the recipient purchase phones through supplemental funds to support MCM service? (Added: 5/18/2020)

The FY 2020 CARES Act funding for Ryan White HIV/AIDS Program recipients is not bound by the parameters of the previously awarded RWHAP grant but must be expended for allowable RWHAP purposes and costs. Mobile phones are allowable costs so long as all statutory and regulatory requirements are met.

New Should services provided using FY 2020 CARES Act funds also be reported on the 2020 RSR, or only on the CDR? (Added: 5/18/2020)

For RSR reporting, all RWHAP-eligible clients served using CARES Act funding should be included in the client-level data.  However, it will not be required to differentiate between funding sources for client-level service provision (as in previous RSRs). 

New Do Ryan White HIV/AIDS Program recipients need to aggregate their providers reports? (Added: 5/18/2020)

No, RWHAP recipients do not need to aggregate their provider reports. Each provider (recipient-providers, subrecipient-providers, and second-level providers) will submit their own data directly to HRSA. There is no review and approval at the recipient-level.

New Do Ryan White HIV/AIDS Program recipients who subcontract all their client services need to submit a COVID-19 Data Report (CDR)? Since they do not serve clients, the RWHAP recipients could only submit aggregated, unduplicated client data. (Added: 5/18/2020)

Recipient-providers, subrecipient-providers, and second-level providers who used FY 2020 CARES Act funding to provide RWHAP core medical or support services to RWHAP-eligible clients and immediate household members are required to submit a CDR.

New For reporting confirmed COVID-19 tests on the COVID-19 Data Report (CDR), does it matter whether it is a PCR or antibody test? (Added: 5/18/2020)

Please report any COVID-19 test.

New Can you provide more detail on what is meant by “presumed positive?” Can a Ryan White HIV/AIDS Program recipient assume this means a client who has the unique symptoms characteristic of COVID-19 but who has not had an actual positive PCR test?  What are those symptoms, and who is authorized to make that presumptive diagnosis? (Added: 5/18/2020)

Please follow CDC guidelines regarding presumptive positive cases. Please refer to your organization's guidelines and procedures.

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: 3/31/2020)

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. 

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.

HRSA launched a new COVID-19 Uninsured Program Portal, allowing health care providers who have conducted COVID-19 testing or provided treatment for uninsured COVID-19 individuals on or after February 4, 2020, to request claims reimbursement. Rather than covering this cost through the CARES Act funding we received under RWHAP, should we direct providers to apply for reimbursement through the COVID-19 Uninsured Program Portal? (Added: 5/13/2020)

The FY 2020 CARES Act funding should be used for preventing, preparing for, and responding to COVID-19, as needs evolve for clients of Ryan White HIV/AIDS Program (RWHAP) recipients. Additionally, as part of the Families First Coronavirus Response Act (P.L. 116-127), Paycheck Protection Program and Health Care Enhancement Act, and CARES Act, the U.S. Department of Health and Human Services (HHS), will provide claims reimbursement to health care providers generally at Medicare rates for testing uninsured individuals for COVID-19 and treating uninsured individuals with a COVID-19 diagnosis on or after February 4, 2020. The Provider Relief Fund, distributed through HRSA, is not a state compensation program, an insurance policy, a federal or state health benefits program, or an entity that provides health services on a prepaid basis. As such, it does not trigger the payor of last resort provision codified in the RWHAP legislation. Providers should use their COVID-19 CARES Act funding specifically authorized for the RWHAP patient population, and are PROHIBITED from accessing the Provider Relief Fund for these same services.

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.

We have a population of clients who are currently misplaced and are stranded due to COVID-19 travel restrictions. Medication coverage through patient assistance programs with the manufacturer has been secured for 30 days. What is the allowability of providing drugs to these clients using RWHAP funds in the event that the drugs will not be covered under a patient assistance program? In addition, the RWHAP Part A recipient is concerned with the provision of outpatient/ambulatory visits, food bank and other supportive services to these stranded clients during this time. Can CARES Act funds be used to cover these emergency costs? (Added: 4/27/2020)

HRSA HAB requires that people with HIV are deemed eligible to receive RWHAP services, and the RWHAP legislation and HRSA HAB policy outline eligibility-related requirements. However, where not defined within these requirements, RWHAP recipients have flexibility as to how they define eligibility requirements for their services, including residency (where applicable), and what documentation they require. HRSA HAB encourages RWHAP recipients to have emergency response plans that include temporary eligibility rules that would apply in specific situations like this. This would allow a recipient to provide services that meet both HRSA HAB requirements and recipient-level policy. For example, in the situation described in the question, an ADAP could have, as a component of their emergency preparedness plan, that in a public health emergency it will accept a lower level of documentation for residency than it would normally.

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.

In instances where a COVID-19 positive client has been in a facility, and it needs to close for sanitization, are these costs associated with cleaning services and/or supplies subject to the 10% administrative cap for sub-recipients or will these be considered direct expenses? (Added: 4/29/2020)

If a facility that provides core medical or support services needs to close for sanitization due to the presence of a COVID-19 positive client receiving treatment at the facility, the costs associated can be considered a facility maintenance expense. As outlined in Policy Clarification Notice #15-01 (PDF - 124 KB), the portion of indirect/direct facilities expenses such as rent, maintenance, and utilities for areas primarily utilized to provide core medical and support services for eligible RWHAP clients (e.g., clinic, pharmacy, food bank, substance abuse treatment facilities) is not required to be included in the 10% administrative cost cap.

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.

What instruction can the HIV/AIDS Bureau provide pertaining to virtual meetings as it relates to Planning Council and our Committee meetings? Our bylaws require for physical presence when voting at the Planning Council and Committee meetings. Can the bylaws and policy and procedures be relaxed due to the COVID-19 when it comes to voting? (Added: 4/27/2020) 

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 affect 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. 

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.

We’ve heard from several Ryan White HIV/AIDS Program providers that food on shelves at grocery stores is low, and they would like to be able to support clients’ meals using RWHAP emergency financial assistance (EFA) funding. Would our case management agency in eastern Idaho be allowed to use EFA to support meals through Grub Hub and local restaurants that are offering take out options? (Added: 3/31/2020)

PCN #16-02 (PDF - 173 KB) 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.

Can Ryan White HIV/AIDS Program Part A Planning Councils (PC) buy phones, electronic devices help PC members with connectivity during this emergency so members can attend meetings? Also, can consumers who are not voting members of the PC, but on the consumer committee be provided with electronic devices so they will be able to fully participate in meetings? (Added: 3/31/2020)

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.

Since Ryan White HIV/AIDS Program-funded agencies are utilizing social distancing and trying not to bring many clients into the clinic, they are doing telephone case management and provider assessments.  They have run into the issue of some clients not have enough minutes on their phone and are unable to complete these types of visits.  Are they able to purchase phone cards or minutes for clients? (Added: 5/4/2020)

The fiscal year (FY) 2020 Coronavirus Aid, Relief and Economic Security Act -P.L. 116- 136 (CARES Act) provides one-time funding for eligible health care providers, including current Health Resources and Services Administration (HRSA) Ryan White HIV/AIDS Program (RWHAP) recipients to prevent, prepare for, and respond to coronavirus disease 2019 (COVID-19). Allowable uses include costs to support social distancing for patients, which may include providing home-delivered meals and medications, minor alterations and renovations such as safety barriers, or providing Emergency Financial Assistance in accordance with PCN #16-02 (PDF - 173 KB) to support client engagement in telehealth or phone-based consultation. The provision of calling cards may also be allowable under medical or non-medical case management services. HAB recommends that the recipient establish policies and procedures that cover the following and establishes policy and procedures on:

  • how clients can request calling cards,
  • a log to track which clients received a calling a card,
  • the frequency that calling cards will be disseminated to clients (monthly, quarterly, etc.).

Can a Ryan White HIV/AIDS Program Part A funded Food Bank Program pay for grocery delivery? Prior to the COVID-19 emergency, this provider had done distributed food vouchers, which they plan to go back to after the emergency is over. (Added: 3/31/2020)

HRSA HAB encourages promoting access to and continuity of care in a safe way during social distancing PCN #16-02 (PDF - 173 KB) 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.

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.

What can Ryan White HIV/AIDS Program recipients do to counter stigma towards certain groups, particularly people with HIV, during the COVID-19 outbreak? (Added: 4/2/2020)

Ryan White HIV/AIDS Program recipients and subrecipients are encouraged to review the CDC guidelines around reducing stigma. They describe actions recipients and subrecipients can take, such as maintaining the privacy and confidentiality of those seeking care, raising awareness of COVID-19 without increasing fear, and sharing accurate information about how the virus spreads.

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.

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: 3/31/2020)

HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. 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 - 173 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: 3/31/2020)

HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. 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 - 173 KB) encourages service providers to consider all methods of providing services, including the use of technology (e.g., telehealth).

Are there any provisions for teledentistry for Ryan White HIV/AIDS Program patients during the COVID-19 pandemic? Are recipients able to bill for limited oral evaluation when triage is completed by phone or video? (Added: 4/2/2020)

HAB PCN #16-02 (PDF - 173 KB) allows for Oral Health Care activities that include outpatient diagnosis, prevention, and therapy provided by dental health care professionals, including general dental practitioners, dental specialists, dental hygienists, and licensed dental assistants. 

HRSA HAB encourages the use of telehealth to promote access to and continuity of care in a safe way during social distancing. 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.

Resources and Oversight

Will HRSA’s HIV/AIDS Bureau be conducting site visits as scheduled? (Updated: 5/18/2020)

Given the importance of HRSA’s Ryan White HIV/AIDS Program (RWHAP) recipients in the local, state, and national response efforts, as well as CDC guidance, HAB will postpone all on-site visits planned through September 28, 2020. This decision is made in consideration of the potential impact to RWHAP service providers’ operations during the COVID-19 pandemic, HAB staff and consultants, as well as the need for staff to be available for immediate mission critical assignments.

Site visits are an important part of the RWHAP monitoring and oversight process. Therefore, HAB will reschedule the postponed comprehensive and other site visits as soon as is practical.

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.

Can a RWHAP recipient-funded staff be assigned COVID-19 duties during a State declared public health emergency? (Updated: 3/31/2020)

Under section 319(e) of the Public Health Service (PHS) Act, a Governor of a State or a tribal organization, or their designee, may request to temporarily reassign state and local public health department or agency personnel funded in whole or in part through programs authorized under the PHS Act (which includes the Ryan White HIV/AIDS Program) for purposes of immediately addressing a public health emergency in the State or Indian tribe during the period of the public health emergency. Section 319(e) of the PHS Act only allows reassignment of state, local, and tribal employees whose salaries are funded in whole or in part by PHS Act programs (and would not, for example, allow reassignment of staff at a private hospital-based clinic funded under Part C). 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 organization, or their 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

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? (Updated: 3/31/2020)

At this moment, the Notice of Funding Opportunity (NOFO) submission deadline for HRSA-20-067 has been extended to April 23, 2020. In addition, the NOFO submission deadline for HRSA-20-083 has been extended until April 17, 2020. The NOFO deadline for HRSA-20-065 has also been extended until May 29, 2020.

However the deadline for other HAB funding opportunities 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).

Are Ryan White HIV/AIDS Program Part C recipients expected to apply to the fiscal year (FY) 2021 Ryan White HIV/AIDS Program Part C Early Intervention Services (EIS) Notice of Funding Opportunity (NOFO)? (Added: 4/22/2020)

The Health Resources and Services Administration (HRSA), HIV/AIDS Bureau (HAB) has received numerous communications from current recipients expressing concern that they will be unable to submit applications for competition due to extreme interruptions and barriers to normal business operations. We recognize that the COVID-19 pandemic is having a profound impact on recipients’ staffing resources and their ability to conduct business functions and effectively address the emergency needs of clients.

In consideration of these ongoing issues, HRSA has determined that the FY 2021 RWHAP Part C EISEGA NOFO (HRSA-21-060, -061, and -062) will be postponed. HRSA plans to host a competition for the entire RWHAP Part C EISEGA program in FY 2022 when recipients’ business operations are anticipated to be stabilized and the appropriate staff and resources are available to develop quality applications for competition.

What is the status of the 2020 National Ryan White Conference on HIV Care & Treatment? (Updated: 5/4/2020)

In light of the coronavirus disease 2019 (COVID-19) pandemic, HRSA’s HIV/AIDS Bureau is making arrangements to host the 2020 National Ryan White Conference on HIV Care and Treatment virtually. This conference is currently scheduled for August 11-14, 2020 in Washington, DC.

Your health, well-being, and safety are the top priority for the HIV/AIDS Bureau. While there is not yet sufficient data on whether people with HIV are more susceptible or more likely to develop severe disease, we must take every precaution to reduce any potential risk to the vulnerable population the Ryan White HIV/AIDS Program serves. 

The HIV/AIDS Bureau knows many of the registered attendees and speakers are working on the front lines of the COVID-19 response around the world. This virtual format will allow those on the front line to still have an opportunity to attend the conference and not take them away from the communities they are working hard to serve. 

If the conference is hosted virtually, all Marriott Marquis Washington, DC hotel reservations will be cancelled on behalf of registered attendees.  Recipients and stakeholders will not need to request a hotel reservation cancellation.

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.

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.

Are RWHAP recipients allowed to perform remote site visits given that they are supposed to have on site visits every year through their contract? (Added: 5/13/2020)

HRSA’s HIV/AIDS Bureau understands that this is a public health emergency and that some grant activities, including activities by subrecipients, may be impacted by COVID-19 emergencies within their jurisdictions, which may impact their ability to meet grant requirements.  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 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.

Should Ryan White HIV/AIDS Program recipients cancel in-person training and technical assistance events and meetings planned in the upcoming months? (Added: 4/15/2020)

HRSA encourages awardees to cancel and/or postpone any in-person engagement events until a later date to be determined. Given the recommendation for social distancing to prevent the spread of the coronavirus, you could consider cancelling, postponing, or rescheduling events or meetings as online events.

Grants Management

In the event that RWHAP grant-funded staff are on furlough, would the program be able to charge fringe benefits to the RWHAP Part A grant, even though the salary is not being charged? (Added: 4/15/2020)

HRSA grant recipients must use Cost Principles (45 CFR Part 75, Subpart E) in determining allowable costs that may be charged to the HRSA award. Recipients must ensure compliance with the Uniform Administrative Requirements, Cost Principles, Audit Requirements for HHS awards (45 CFR Part 75), the individual funding announcement and the organization's policies.

Recipients may find helpful information from the Department of Labor at: COVID-19 effects on wages, work hours, and leave categories.

During the COVID-19 emergency, recipients must document that they are following their organizational policy (to include internal controls and documentation) during unexpected and extraordinary circumstances and they must be able to substantiate federal funds expended in accordance with HRSA guidance, as adopted and permitted by OMB M-20-17. 

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 service.

If a Ryan White HIV/AIDS Program recipient has to terminate grant-funded employees permanently, can the program charge severance packages to the grant? (Added: 4/15/2020)

HRSA grant recipients must use Cost Principles (45 CFR Part 75, Subpart E) in determining allowable costs that may be charged to the HRSA award. Recipients must ensure compliance with the Uniform Administrative Requirements, Cost Principles, Audit Requirements for HHS awards (45 CFR Part 75), the individual funding announcement and the organization's policies.

Recipients may find helpful information from the Department of Labor at: COVID-19 effects on wages, work hours, and leave categories.

During the COVID-19 emergency, recipients must document that they are following their organizational policy (to include internal controls and documentation) during unexpected and extraordinary circumstances and they must be able to substantiate federal funds expended in accordance with HRSA guidance, as adopted and permitted by OMB M-20-17. 

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 service.

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)

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)

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.

Can Ryan White HIV/AIDS Program recipients accelerate the drawdown of their grant funds as a needed response to the COVID-19 emergency? (Added: 4/27/2020)

Drawdown of grant funds must be used for activities within the scope of the originally approved grant activities. In the event that COVID-19 has impacted the grant, the recipient needs to reference the Cost Principles (45 CFR Part 75, Subpart E) for allowable costs charged to the RWHAP award, determine the extraordinary circumstances of COVID-19 and consider applying several factors such as: the original purpose the funds were awarded under, the timeframe in relation to the declared public health emergency and the allowability of the proposed use of the funds for COVID-19 emergency costs.

In addition to determining allowability, and the limited temporary need, the recipient would need to consider if sufficient funding is available, or if rebudgetting is necessary and if the rebugetting would meet the significant threshold thus requiring a Prior Approval Request submission. The Grants Management Specialist listed on the most recent Notice of Award can provide further assistance if necessary.

Recipients should be cautious about the impact that accelerating the drawdown of expenses could have on achieving the overall RWHAP grant activities. Recipients should not assume, that additional funds for the unanticipated costs will be made available should these expenses result in a shortage of funds from another category or that additional funds will be provided to perform other grant activities once the emergency has concluded.

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.

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.

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Date Last Reviewed:  May 2020