Though operating under essentially the same statutory authorization since 1990 with the enactment of the original Ryan White Comprehensive AIDS Resources Emergency (“CARE”) Act, management and oversight of the Ryan White HIV/AIDS Program (“RWHAP”) by the Health Resources and Services Administration’s (“HRSA”) HIV/AIDS Bureau (“HAB”) has evolved over time.
In recent years, grant management has become a particular compliance focus point of HAB and the 340B Drug Pricing Program has served as a critical tool for service providers.
FTLF attorneys assist RWHAP grantees with all manner of programmatic and grant management compliance and strategic planning. Whether a direct recipient (generally under RWHAP Parts C or D) or subrecipient of a State (generally Part B) or local government (generally Part A), our attorneys assist operational opportunities and challenges inherent in the program’s structure.
We leverage combined knowledge in HHS grants management, the federal 340B Drug Pricing Program, the Medicaid program, and health care transactions, to assist RWHAP providers.
Key RWHAP programmatic resources (including the extremely detailed CARE Act and current Policy Clarification Notices (“PCNs”)) may be found on HAB’s program resources page (https://hab.hrsa.gov/program-grants-management/ryan-white-hivaids-program-recipient-resources).
Key grant management requirements are provided through the Uniform Guidance as implemented by HHS at 45 CFR Part 75 (https://www.ecfr.gov/current/title-45/subtitle-A/subchapter-A/part-75), with HRSA HAB supplemental guidance in the following areas available through certain PCNs:
- Permissible programmatic expenditures and “scope of project” – PCN 16-02;
- Patient/client eligibility – PCN 13-02;
- Program income – PCN 15-02 (and associated FAQs); and
- Administrative cost caps – PCN 15-01.