FAQ: FY 2022 RCORP-Implementation (HRSA-22-057)

• General Application FAQs
• Eligible Entities, Consortium Members, and Proposed Service Areas
• Allowable Costs and Financial Questions

General Application FAQs

I am having difficulty finding the Notice of Funding Opportunity (NOFO) – can you direct me to the full application instructions?

• Direct link to NOFO (Select “Package” → ”Preview” → ”Download Instructions”)
• To apply: go to opportunity HRSA-22-057 on Grants.gov and select "Apply."
• HRSA's website also has a brief summary of the funding opportunity and a link to the NOFO.

I was unable to attend HRSA's Technical Assistance (TA) Webinar for this funding opportunity. Is the webinar recording available?

A full recording of the webinar can be found here.

I am having difficulty accessing/navigating grants.gov. How do you recommend I proceed?

Applicants should contact the Grants.gov support team at: 1-800-518-4726 or support@grants.gov.

I am having difficulty accessing the System for Award Management (SAM) to register or update my account. How do you recommend I proceed?

Contact the Federal Support Desk. They can assist you with creating an account, assigning roles to an account, entity registrations, exclusions, and searching for data in SAM.

Please note: you must submit your application electronically by the deadline posted on the NOFO. If you need to request a waiver from the submission requirement, you must request an exemption in writing from DGPWaivers@hrsa.gov within five calendar days of the opportunity’s closing date, and provide details as to why you are technologically unable to submit electronically through the Grants.gov portal. Please refer to pages 16-17 of the HRSA SF-424 Application Guide (PDF - 663 KB).

What is the page limit for the application?

Per page 7 of the NOFO, HRSA may not consider an application for funding if it exceeds the page limit of 80 pages.

I have a specific question about the Notice of Funding Opportunity that is not answered here.

Please review the TA webinar slides and recording if you have not already.

Please contact HRSA Staff at ruralopioidresponse@hrsa.gov or Sabrina Frost at 301-945-5131. Please note that HRSA staff will answer clarifying questions about the NOFO requirements, but cannot provide guidance on proposed approaches.

Eligible Entities, Consortium Members, and Proposed Service Areas

What are the requirements for creating a consortium?

Please refer to pages 6-7 of the NOFO.

Consortia

• The applicant organization can be either rural or non-rural, but a majority, or over 50%, of consortium members must be located in a HRSA-designated rural area. Consortia must be made up of at least four entities with four different EINs. They are expected to be from multiple sectors (public health, health care, education, justice, community organization, etc.). Tribal applicants without four separate EINs may be eligible as long as the four consortium partners serve separate functions (e.g., school administration, health departments, law enforcement, etc.).

Service Area

• The proposed service area must be an entirely HRSA-designated rural area. Applicants must demonstrate this using the rural analyzer tool and listing service area counties and/or census tracts.

The rural consortium member/target population is located in a county that is partially rural. How should my organization address this in the application?

Applicant organizations and consortium members can determine whether their physical street address is located in a HRSA-designated rural area by using the rural analyzer tool (see page 6 of the NOFO).

Applicants must confirm that the target population is located exclusively in the portions of the county that are considered rural (PDF - 401 KB).

If your proposed county is only partially rural, you can only provide services to the rural census tracts of that county and cannot target the entire county.

Are consortium members required to register in SAM?

Per page 6 of the NOFO, if awarded funding, grant recipients must notify consortium members who will be serving as sub-contractors/sub-recipients that they must be registered in SAM and provide the grant recipient with their DUNS number. See pages 29-30 of the HRSA SF-424 Application Guide (PDF - 663 KB) for more information.

How will HRSA determine whether a service area is “high risk”?

It is up to the applicant to demonstrate their level of need/risk in the Needs Assessment section of the Project Narrative (see pages 15-20 of the NOFO).

Is it allowable for a provider to be located in an urban facility, but serving patients in HRSA-designated rural areas through telemedicine?

Per page 5 of the NOFO, this scenario is allowable, so long as the target patient population is exclusively rural, as defined by the rural analyzer tool.

The applicant must also establish their non-rural service delivery site serves rural populations and must also establish that the services are related to improving health care in rural areas, as opposed to merely improving the health care of rural populations (e.g., by providing provider training and mentorship opportunities for rural health care providers, etc.).

Can applicants apply for this funding opportunity if they have received an FY 2020 or FY 2021 RCORP-Implementation grant (as either the applicant organization or consortium member)?

Per pages 6-7 of the NOFO, applicants that are FY 2020 or FY 2021 RCORP-Implementation award recipients and/or Consortium Members are ONLY eligible to apply for this funding opportunity if they meet the following conditions:

• The target geographic rural service area proposed in the application does not overlap at all with the one currently served by the consortium for the FY 2020 or FY 2021 RCORP-Implementation award and all proposed services are delivered in the new target rural service area. FY 2020 and FY 2021 RCORP-Implementation award recipients and/or consortium members should demonstrate they meet these conditions in Attachment 7; and
• More than 50% of the consortium members proposed in this application are physically located in the new service area and are signatories to the Letter of Commitment (see Attachment 3 of the NOFO).

Can applicants apply for this funding opportunity if they have received an FY 2019 RCORP-Implementation grant (as either the applicant organization or consortium member)?

FY 2019 RCORP-Implementation grantees can apply for the FY 2022 RCORP-Implementation grant. It is up to your organization whether you apply to continue services implemented as part of your FY 2019 grant or propose an entirely different consortium/service area, but please note that you should apply as though you are applying for the grant for the first time, you must be able to justify unmet need, and there is no funding priority or preference associated with being a FY 2019 Implementation grant recipient. Please also note that, per the NOFO, “The methodology should include a thorough, detailed explanation of how you will achieve each core activity and how you will collaborate, and not duplicate, existing OUD/SUD programming in the target rural service area, including other RCORP awards.”

If I am an FY 2019 RCORP-Implementation grant recipient, should I apply as a new or competing continuation grant?

If the FY 2019 RCORP-Implementation grant recipient is applying for funds to continue the same project, with the same focus and the same service area as their FY 2019 RCORP-Implementation project, then it is a competing continuation. If the project differs in scope, activities, goals/objectives, and/or service area, then it is considered a new project. There is no funding priority or preference associated with selecting competing continuation.

If I am an FY 2020 and FY 2021 Implementation grant recipient, should I apply as a new or competing continuation grant?

FY 2020 and FY 2021 Implementation grant recipients should apply as a new grant.

Can applicants apply for this funding opportunity if they have received other RCORP award (that is not an FY 2020 or FY 2021 RCORP-Implementation grant)?

Applicant organizations or consortium members of FY 2018, FY 2019 or FY 2020 RCORP-Planning, FY 2019 RCORP-MAT Expansion, FY 2020 RCORP-NAS, or FY 2021 RCORP-Psychostimulant Support must demonstrate that there is no duplication of effort between the proposed FY 2022 RCORP-Implementation application and any previous or current project. Please see Attachment 7 for additional information and instructions.

Can RCORP-Planning grantees use the Needs Assessment, Work Plan, and other documents created during the RCORP-Planning period to apply for this funding opportunity?

Documents created during the RCORP-Planning period can inform the corresponding sections of the FY 2022 RCORP-Implementation application. However, please note that the FY 2022 RCORP-Implementation application may have different requirements than the documents submitted during RCORP-Planning. Your application must address the requirements outlined in the FY 2022 RCORP-Implementation NOFO regardless of the documents you created in the RCORP-Planning period.

Are organizations able to apply under more than one consortium?

Per page 7 of the NOFO, organizations are limited from serving as the applicant organization on more than one FY 2022 RCORP-Implementation application—i.e., only one application can be associated with an EIN or DUNS number. However, an organization would be eligible to apply as a consortium member for multiple applications, just not as the applicant organization for more than one application.

As outlined on pages 7-8 of the NOFO, organizations that are located in different rural service areas, but that share an EIN or DUNS number, may request an exception to this policy (see Attachment 8 of the NOFO). However, a single organization (e.g., a parent organization/headquarters) may not apply more than once for this funding opportunity on behalf of its satellite offices or clinics.

Can our consortium members electronically sign the Letter of Commitment?

Yes (see page 21 of the NOFO).

Are there sample Letters of Commitment we can use to complete Attachment 3 of the application?

Though not required, the RCORP technical assistance provider, JBS International, Inc., has a template on their technical assistance portal that applicants may use. Please note that regardless of the format, the Letter of Commitment must contain all elements described on pages 21-22 of the NOFO and that applicants are required to submit a single Letter of Commitment signed by at least four separately owned (i.e., different EINs) consortium members, including the applicant organization, and at least 50 percent of signatories must be physically located in HRSA-designated rural areas (as defined by the rural analyzer tool).

Do consortium partners need to be entities with EINs? Appendix C lists potential consortium members, and it includes community members such as individuals in recovery.

At least four consortium members (the four members needed for the Letter of Commitment) need to be entities with EINs. Additional consortium members beyond these four members may be individuals.

Per page 6 of the NOFO, the four requested consortium members must be separately owned (i.e., different EINs).

Are universities eligible to submit an application?

Yes, eligible applicants include all domestic public or private, non-profit or for-profit entities, including faith-based and community-based organizations, tribes, and tribal organizations (see page 4 of the NOFO).

Is there a requirement of how many counties need to be included for the target rural service area?

There is no requirement or limit on the number of counties that can be included. There is no requirement regarding the proximity among the proposed rural counties and/or rural census tracts.

However, the proposed service area must align with the proposed work plan and budget.

The rural area I want to target for my application is already being served by an existing FY 2020 or FY 2021 RCORP-Implementation award. Can I still apply?

Yes, but please note page 17 of the NOFO states, “The methodology should include a thorough, detailed explanation of how you will achieve each core activity and how you will collaborate, and not duplicate, existing OUD/SUD programming in the target rural service area, including other RCORP awards.”

Does the Project Abstract count towards the overall application page limit?

No. Applicants should provide a summary of the application in the Project Abstract in the Project Abstract box of the Project Abstract Form, using 4,000 characters or less.

Because the abstract is often distributed to provide information to the public and Congress, prepare this so that it is clear, accurate, concise, and without reference to other parts of the application. It must include a brief description of the proposed project including the needs to be addressed, the proposed services, and the population group(s) to be served. If the application is funded, your project abstract information (as submitted) will be made available to public websites and/or databases including USAspending.gov.

Where can I find the data/information required for the Needs Assessment section of the application?

Refer to the Needs Assessment section of the Project Narrative (pages 15-16 of the NOFO) for the type of data and information you will need.

Per the NOFO, applicants should use the most recent available data/information from appropriate sources (e.g., local, state, tribal, federal) and cite any information they provide. Appendix B contains several resources applicants can leverage.

If awarded, the RCORP evaluation team is available to help identify appropriate data sources for subsequent reporting cycles.

There are no data available for my service area for some of the indicators requested in the Needs Assessment section of the Project Narrative. Is this problematic?

Per page 16 of the NOFO, applicants encountering difficulty obtaining data for certain indicators are encouraged to contact their state or local health departments and/or refer to data and information provided by the Rural Health Information Hub and the Opioid Misuse Community Assessment Tool developed by NORC at the University of Chicago.

If you are still unable to locate appropriate and accurate data, per the NOFO, please provide an explanation for why the data could not be found and how you will leverage the RCORP-Implementation grant to strengthen the quality and availability of OUD/SUD data in your target rural service area. Data reporting is a requirement of this Implementation grant, if awarded.

Can award recipients use RCORP-Implementation funds to treat urban residents who seek care at their facilities if incidental and related to improving health care in rural areas?

While award recipients should exclusively target populations residing in HRSA-designated rural areas, it is acceptable if urban residents also happen to benefit incidentally from the grant.

Since award recipients will be working closely with an external RCORP evaluator, should I budget for an evaluator to assess the impact of my project?

If awarded funds, your consortium should be prepared to track, collect and report data to give to the external RCORP evaluator and complete all required qualitative and quantitative reporting requirements as outlined in the NOFO (pages 38-40). If your consortium is unable to track and collect these data without an evaluation expert, you can include hours for a consultant or other data specialist to perform these required tasks in your staffing plan and budget and budget narrative.

Note that applicants are required to designate at least one individual in the staffing plan to serve as a “Data Coordinator” (page 22-23), responsible for tracking, collecting, aggregating, and reporting qualitative and quantitative data and information from consortium members. This position does not necessarily entail analyzing the data or utilizing the data to inform process or quality improvement.

Do all consortium/network members need to receive RCORP-Implementation grant funds in order to be considered full, participating consortium members for the purposes of this grant?

No, it is not necessary to distribute the grant funds across all consortium members. However, each consortium member should be aware of the others’ roles and responsibilities on this grant as delineated in the work plan and Letter of Commitment, and the award is not to be used for the exclusive benefit of any one consortium member (see page 21 of the NOFO).

Do I need to submit four separate Letters of Commitment, or can I submit one letter signed by at least four consortium members?

Per page 6 of the NOFO, applicants should submit one Letter of Commitment signed by at least four separately-owned entities, including the applicant organization, in Attachment 3.

Regarding the Letter of Commitment (Attachment 3), to whom and where do I address the letter?

You can format the letter however you would like, as long as it adheres to the specific requirements stated in the NOFO. If you would like to address it to HRSA, the address is as follows:

• Health Resources and Services Administration
• 5600 Fishers Lane
• Rockville, MD 20857

As a reminder, per pages 21-22 and 25 of the NOFO, the Letter of Commitment (Attachment 3) should be submitted as part of the electronic application package through Grants.gov. HRSA will not accept or consider Letters of Commitment or Support received through other means, including through the mail, email, etc.

Can my consortium focus on individuals with other SUDs other than OUD?

The primary focus of the grant should be on individuals with OUD. However, recognizing that many individuals with OUD are polysubstance users or have other co-occurring conditions, your consortium may address the other needs of this population (see page 1 of the NOFO).

Does each consortium member need to implement all of the core/required activities listed on pages 10-12 of the NOFO?

No, individual consortium members may implement a subset of the required/core activities, but all required/core activities must be accounted for, and implemented, by the consortium as a whole. Moreover, each consortium member should be aware of the other members’ roles and responsibilities as delineated in the work plan and Letter of Commitment (see page 21 of the NOFO).

Does the consortium need to implement all core/required activities outlined on pages 10-12 of the NOFO immediately, upon receipt of award?

The consortium should make progress on each core/required activity during each year of the grant, as reflected in the Work Plan, but the activities do not need to be completed until the end of the three-year period of performance (see page 10 of the NOFO).

Does the consortium need to implement every core/required activity outlined on pages 10-12 of the NOFO in every part of our service area?

The consortium does not need to implement all core prevention, treatment and recovery activities in every part of the target HRSA-designated rural area (see page 10 of the NOFO).

All core/required activities must be reflected in the applicant’s work plan, but applicants should use the information in the Needs Assessment section of the Project Narrative (pages 15-16) to determine how, when, and where each core/required activity should be implemented.

If my consortium is already implementing one of the core/required activities, do I still need to include it in my project?

Yes, if a consortium is already implementing one or more of the core/required activities within the service area, applicants may propose to expand or enhance those activities (see page 10 of the NOFO).

My consortium will not have hired all of our project staff by the time the application is due. How do I account for this in my application?

In Attachment 5 (“Staffing Plan”), it is appropriate to write TBH under “Name” if the individual has not yet been hired. However, you should include a description of the process and timeline for hiring staff, as well as the qualifications and expertise required by the position. All key staff associated with the project should be hired within 60 days of the project start date (see page 22 of the NOFO).

What is the FTE requirement for the Project Director?

Per page 22 of the NOFO, the Project Director is a key staff member and an FTE of at least 0.25 is required for this position. Project Directors cannot bill more than 1.0 FTE across federal grants.

Can we designate more than one Project Director on the grant?

More than one Project Director is allowable in the staffing plan, but only one Project Director can be designated in Box 8f of the SF-424 Application Page, and this is the Project Director who will be officially reflected in the Notice of Award if awarded funding (see page 22-23 of the NOFO).

If there is more than one Project Director, a total FTE of at least 0.25 between the two Project Directors is allowable.

One of our staff members will be serving two separate and distinct roles on the grant that do not overlap. Do we submit two separate biosketches for that individual?

Yes. However, you should ensure that individual does not exceed 1.0 FTE (see page 23 of the NOFO).

Can an individual apply as the lead applicant on this grant?

No. Eligible applicants include all domestic public or private, non-profit or for-profit entities, including faith-based and community-based organizations, tribes, and tribal organizations (see page 4 of the NOFO).

Note while individuals may be included as consortium members, there must also be at least four separately owned entities/organizations to meet HRSA’s required consortium specifications (see page 6 of the NOFO).

Allowable Costs and Financial Questions

Will I need to complete an A-133 audit for this grant?

In general, if an award recipient’s federal awards exceed $750,000 in any given year, they will need to conduct an audit.

However, please refer to Subpart F of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards for further guidance.

Are minor renovations an allowable cost for this grant?

Certain minor renovations up to $200,000 are allowable under this grant. Further guidance is provided on pages 30-31 of the NOFO.

Successful award recipients proposing minor renovation projects will be required to submit a prior approval request to HRSA upon receipt of award and refrain from implementing the minor renovations until the request has been approved.

Are participant support costs allowable for this grant?

Participant support costs—i.e., direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects—are allowable costs, subject to HRSA review and approval upon receipt of award.

In this context, “employees” refers to individuals directly employed on an hourly, salaried, or employment contract basis by the applicant organization/award recipient. Individuals employed by sub-contractors, consortium members, and sub-recipients are not included in this definition (see pages 31-32 of the NOFO).

Can applicants use RCORP-Implementation funds to set up an urban telehealth hub that will provide services to facilities located in our HRSA-designated rural service area?

You may use RCORP-Implementation funds to purchase telehealth infrastructure in an urban setting if the infrastructure will exclusively be used to provide services to patients at the rurally-located facility (see page 31 of the NOFO).

Can I use RCORP-Implementation funds to purchase a vehicle to use as a mobile treatment unit?

Purchase of a mobile unit is an allowable cost as long as the unit is reasonably priced and exclusively used to deliver, or facilitate transport to, services funded by the RCORP-Implementation grant. Additional information is provided on page 31 of the NOFO.

You may not begin any purchases until you receive HRSA approval and must have contingency plans in place to ensure that delays in receiving HRSA approval of your mobile unit or vehicle purchase do not affect your ability to execute work plan activities and HRSA deliverables on time (see page 31 of the NOFO).

Can I use RCORP-Implementation grant funds to purchase medication?

Per page 32 of the NOFO, Food and Drug Administration (FDA)-approved opioid agonist medications (e.g., methadone, buprenorphine products including buprenorphine/naloxone combination and buprenorphine mono-product formulations) for the maintenance treatment of OUD, opioid antagonist medication (e.g., naltrexone products) to prevent relapse to opioid use, and naloxone to treat opioid overdose are all allowable costs under RCORP-Implementation.

RCORP-Implementation funds cannot be used to purchase medical marijuana.

Can I use RCORP-Implementation grant funds to purchase syringes?

The purchase of syringes is unallowable in all phases of the program (see page 30 of the NOFO).

Please refer to the HRSA SF-424 Application Guide (PDF - 663 KB) (pp. 28) for guidance around syringe purchases using grant funds: "Notwithstanding any other provision of this Act, no funds appropriated in this Act shall be used to purchase sterile needles or syringes for the hypodermic injection of any illegal drug: Provided, That such limitation does not apply to the use of funds for elements of a program other than making such purchases if the relevant State or local health department, in consultation with the Centers for Disease Control and Prevention, determines that the State or local jurisdiction, as applicable, is experiencing, or is at risk for, a significant increase in hepatitis infections or an HIV outbreak due to injection drug use, and such program is operating in accordance with State and local law.”

Will there be an in-person meeting for grantees to attend? If so, should we include that in our proposed budget?

Yes, applicants should budget for two individuals to travel annually to a workshop. The workshop will likely be located in the Washington, DC area. These expenses should be reflected in the SF-424 form and the budget narrative. Additional details for the timing of those workshops will be provided by HRSA when they are available (see page 24 of the NOFO).

Note: HRSA will continue to monitor possible health risks associated with travel, and may adjust these trips accordingly.

Can RCORP-Implementation funding be used to cover prevention, treatment, and recovery costs for patients who are uninsured/underinsured?

Yes, per page 32 of the NOFO. Award recipients who plan to use funds in this manner should ensure that the RCORP-Implementation grant serves as a payer of last resort—i.e., all services covered by reimbursement should be billed and every reasonable effort should be made to obtain payment from third-party payers. Only after grant recipients receive a final determination from the insurer regarding lack of full reimbursement can the RCORP-Implementation grant be used to cover the cost of services for underinsured individuals. RCORP-Implementation grant funds can also be used to cover the cost of services for uninsured patients.

RCORP-Implementation funds cannot be used for the following purposes:

• To supplant existing funding sources;
• To pay down bad debt. Bad debt is debt that has been determined to be uncollectable, including losses (whether actual or estimated) arising from uncollectable accounts and other claims. Related collection and legal costs arising from such debts after they have been determined to be uncollectable are also unallowable;
• To pay the difference between the costs to a provider for performing a service and the provider's negotiated rate with third-party payers (i.e., anticipated shortfall).

What are the guidelines for RCORP-Implementation applicants and consortium members who wish to use RCORP-Implementation funds to subsidize prevention, treatment, and recovery services for the un- or under-insured?

For all applicants and consortium members (regardless of charity care or sliding fee policy):

• RCORP-Implementation funds can be used to pay the co-insurance, out-of-pocket expenses, and/or co-payment for patients who are unable to pay for prevention, treatment, and recovery services provided by the RCORP-Implementation grant.
• Applicants must include a line item(s) in the RCORP-Implementation budget under “Other” for subsidized care with a detailed description of how the estimate was derived. For each project year, the justification should include the anticipated number of patients and encounters that would be covered by the grant; the payer mix of the patient population; the type and average cost of services that would be subsidized; and a rationale for why grant funds are needed to subsidize the cost of services.
• If the funds will be used by consortium members that are subcontractors on the RCORP-Implementation grant to subsidize care, then applicants must include line item(s) under “Contractual” for these costs. The budget narrative must provide a detailed justification for how each consortium member arrived at their estimate based on the above guidance.

For providers that have a charity care policy—i.e., a policy to provide health care services free of charge (or where only partial payment is expected not to include contractual allowances for otherwise insured patients) to individuals who meet certain financial criteria:

• You must include the provider’s documented charity care policy as an attachment to the application.
• RCORP-Implementation funds can only be used as a last resort to cover care for uninsured patients, or underinsured patients eligible for charity care (after the hospital has made every reasonable effort to obtain payment from third-party providers).

For hospitals or non-hospital providers that do not have a charity care or sliding fee policy:

• RCORP-Implementation funds can only be used as a last resort to cover care for uninsured patients, or underinsured patients with a documented financial need who cannot pay for services.

For Federally Qualified Health Centers (FQHCs):

• FQHCs must adhere to health center requirements around Sliding Fee Discounts.

Is there a cap for the indirect cost proposed in the application?

There is no cap for the indirect cost. If indirect costs are included in the budget, you will need to provide the indirect cost rate agreement. If you do not have an indirect cost rate agreement, but wish to include indirect costs, then a rate of no more than 10 percent of modified total direct costs (MTDC) may be applied.

Review indirect cost guidance in the HRSA SF-424 Application Guide (PDF - 663 KB).

Do I need a separate budget and budget narrative for each year, as part of the application?

You do not necessarily need a budget for each year. Each cost element should be itemized and described with a detailed budget and budget justification that covers, at a minimum, the first year of funding. If you are not changing anything in the original budget for years two and three, then you can submit one SF-424(a) which covers the entire funding period. However, if each budget period will support different cost and/or activities, then you will need to submit one for each year.

However you choose to format the budget, you must allocate funds across all three years of the grant period.