Frequently Asked Questions (FAQs): Impact of COVID-19 on BHW Grant Programs

We understand the critical role you play in improving health care for people who are geographically isolated and economically or medically vulnerable—at this time more than ever.

We have compiled the following frequently asked questions (FAQs) to address some of the most common concerns we have been hearing from grant recipients. These questions fall under the following topic areas:

If you have further questions, please contact your Project Officer (PO) and/or Grants Management Specialist (GMS) or check these additional HRSA resources:

List of Abbreviations

ANE-NPR: Advanced Nursing Education – Nurse Practitioner Residency
CDC: Centers for Disease Control and Prevention
DGMO: Division of Grants Management Operations
GMS: Grants Management Specialist
HRSA: Health Resources and Services Administration
NCC: Non-Competing Continuation
NCE: No-Cost Extension
OMB: Office of Management and Budget
PO: Project Officer
SAMHSA: Substance Abuse and Mental Health Services Administration

FAQs

New/Current Students

How does HRSA suggest we address university closures and other unexpected disruptions related to graduation, licensing, and enrollment? (Added: 5/22/2020)

We are aware of university closures and unanticipated program disruptions related to the nation’s COVID-19 public health emergency. We are working to develop Agency-wide policies to address concerns related to program completion and graduation for current students, and the summer 2020 enrollment of new students in HRSA-funded programs. Please check our COVID-19 information regularly for answers to these and other questions. Contact your PO and/or GMS, should you have further questions.

Will HRSA allow delays in program start dates because of disruptions arising from COVID-19? (Added: 5/22/2020)

We are aware of unanticipated program disruptions related to the nation’s COVID-19 public health emergency. We are working to develop Agency-wide policies to address concerns related to program start dates and the summer 2020 enrollment of new students in HRSA-funded programs. Please check our COVID-19 information regularly for answers to these and other questions. Contact your PO and/or GMS, should you have further questions.

Clinical Sites, Field Placements, and Didactic Training

May we delay placement site start dates for trainees from May 2020 to August 2020? (Added: 5/22/2020)

Yes, you may delay to August 2020 the start date for trainees scheduled to start in May 2020. Please document this delay on your NCC progress report and explain how it has affected your ability to meet your goals and objectives. Also, please review your institutional policy on stipends disbursement. If the delayed start requires you to disburse stipends after the end of your budget period, you must submit a carryover request.

Will HRSA allow timeline extensions for us to reach our program goals given that students/trainees are unable to meet their clinical hours as expected? (Added: 5/22/2020)

During social distancing and related steps taken in response to the COVID-19 crisis, we will allow flexibility in timelines for program goals and will not negatively assess you for failing to provide the expected number of clinical hours. In the face of this public health crisis, we also support alternative methods of completing clinical hours and meeting project goals. Contact your PO and/or GMS should you have further questions about timelines for completing project requirements.

Will HRSA work with accrediting agencies to modify or waive the required number of clinical hours or to allow students to meet the clinical hours requirement in a different way? (Added: 5/22/2020)

The licensing and accreditation standards of health professions fall under the jurisdiction of the individual states and accrediting bodies. You will need to contact the licensing agencies in your state and the relevant accrediting bodies for further help with clinical hours requirements. 

For summer 2020 and fall 2020 traineeships, may students double up on didactic courses in the summer and then complete double the clinical placements in the fall? (Added: 5/22/2020)

We will be as flexible as permitted regarding how program funds are used, provided such uses fall within applicable statutory and programmatic requirements and comply with the Terms and Conditions on the Notice of Award. Please work with your PO and GMS to discuss possible options.

Does HRSA have guidelines for the instruction and training of behavioral health professional and paraprofessional trainees in light of the COVID-19 public health emergency? (Added: 5/22/2020)

We recommend that you follow and comply with your institution’s policies and CDC guidance.

If students are not able to work on-site as previously expected, may we follow the students’ school policies and procedures regarding completion of the field placements? (Added: 5/22/2020)

Yes. We recommend that you follow your institution’s policies regarding the completion of field placements. We encourage you to investigate alternatives to face-to-face internships, such as tele-therapy/tele-behavioral health services and/or online training to maintain student hours.

Given the challenges with student field placements, may we maintain the required spending ratio over the life of the total award rather than in each year of the award? (Added: 5/22/2020)

We will allow flexibility concerning the administrative-to-trainee support ratio. Please contact your PO and GMS to discuss proposed ratio changes.

How should we handle a student uncomfortable reporting to a site with confirmed COVID-19 cases when the site expects the student to work? (Added: 5/22/2020)

We recommend you follow all applicable CDC guidance. 

Use of Funds

We received OMB memo (OMB M-20-20) that states grantees may charge to the grant certain costs associated with responding to COVID-19. Is HRSA following this guidance? (Added: 5/22/2020)

If you want to charge to the grant costs associated with the COVID-19 response (e.g., medical equipment or supplies or the donation of other resources such as labor, supplies, and contract services funded under the award), you will need to submit a prior approval request. Requests must include a description of the COVID-19 activities that will be charged to the grant and the amount of additional time being charged to the grant. HRSA will review each request and make a determination.

What are HRSA’s guidelines and recommendations for continuing or halting grant activities during the current crisis? (Added: 5/22/2020)

We encourage programs to continue their grant activities to the extent possible, particularly through any remote options available. Please reach out to your PO to discuss any changes or deviations needed with your project (e.g., changing scope, reallocating funds, modifying goals and objectives, etc.). 

Will HRSA automatically grant a No Cost Extension (NCE), or must the award recipient request it? (Added: 5/22/2020)

Programs operating under expanded authority may receive an automatic, one-time, 12-month NCE to complete approved project activities. Refer to the remarks and terms section of the original Notice of Award to see if your program is under expanded authority. 

If you are under expanded authority, you must submit a prior approval request through HRSA’s Electronic Handbooks for an extension without funds. This action lets us know you need the extension and allows us to update associated dates, including reporting dates.

For all other awardees active as of March 31, 2020 and scheduled to expire on or before December 31, 2020, DGMO can provide NCEs for up to 12 months to give time to assess recipients, resume individual projects, and report on program progress and financial status. You can request an extension through HRSA's Electronic Handbooks. Contact your GMS with any additional questions.

We are currently under a 12-month NCE set to end June 30, 2020. May we request a second NCE to resume project activities once restrictions are lifted and operational activities restored? (Added: 5/22/2020)

You may request a second NCE by submitting a prior approval request to DGMO. Requests must include a detailed description of the goals and objectives that will be met with additional time and specify the amount of additional time needed. We will review the request and make a determination.

May we reallocate grant funds to purchase technology, such as training modules or equipment, to educate staff on meeting the demands for remote training or telehealth? (Added: 5/22/2020)

You may re-budget up to 25% cumulative among approved cost categories without prior approval as long as you are not purchasing equipment in excess of $25,000; not taking funds from a trainee-related category (e.g., stipends) and moving it elsewhere; and not spending outside the scope of the original budget. Note: If the original budget did not include equipment purchases, you must submit a prior approval request.

May we use grant funds to purchase a virtual program to help students fulfill their clinical hours remotely? (Added: 5/22/2020)

Please reach out to your PO and GMS to determine if the cost for virtual programing is an allowable cost and within scope under your respective grant program. 

May we use grant funds to purchase internet hotspots to help preceptors in rural areas overcome the lack of internet access and complete their primary care certifications? (Added: 5/22/2020)

Please reach out to your GMS to determine whether this is an allowable cost under your respective grant program.

If a conference has been postponed or cancelled, may we leave the paid registration fees as a credit to attend the conference during the next fiscal year? (Added: 5/22/2020)

Yes, you may leave the payment as a credit to attend the conference for the next fiscal year. 

If a cancelled conference is not fully refunding registration fees, may we use grant funds to pay ticket cancellation fees or nonrefundable conference registration fees? (Added: 5/22/2020)

Yes. According to OMB Memo M-20-17, you may charge to the grant the full cost of cancellation when the event, travel, or other activities are conducted under the auspices of the grant. Recipients must maintain appropriate records and cost documentation as required by 45 CFR § 75.302 Financial management and standards for financial management systems, and by 45 CFR § 75.361 Retention requirement for records, to substantiate charging any cancellation or other fees related to the interruption of operations or services.

If field placement sites do not re-open for the rest of the semester, may we make stipend payments on a pro-rated basis for service already completed? (Added: 5/22/2020)

Yes, you may pro-rate the stipends for services completed, and, when applicable, give credit for alternatives to face-to-face field placement learning (e.g., tele-behavioral health simulations). We recommend that you follow your institution’s policy to ensure that trainees complete all required training.

If interns cannot complete their internships between now and August 31, do we discontinue their stipends? If they are able to resume their internships after August 31 in Year 4, would we carry over their stipends from Year 3? (Added: 5/22/2020)

We recognize that trainees were removed from placement sites in order to minimize the spread of COVID-19. If students are not able to complete their experiential learning and there are no alternate plans to complete this requirement, stipends cannot be disbursed. However, before taking such action, we recommend that you consider whether alternative methods to face-to-face internships are available for participants to maintain hours, such as tele-health services or online training. If internships cannot be completed in Year 3 but can be resumed in Year 4, you may carry over the stipends.

May we re-budget unspent funds from activities that did not take place this year toward trainee-related costs other than stipends? (Added: 5/22/2020)

You may re-budget up to 25% cumulative among approved cost categories without prior approval. However, there are some exclusions to this general rule, as cited in 45 CFR part 75.308 Revision to Budget and Program plans. Transferring funds allocated to participant support costs (i.e., stipends) to other cost categories always requires prior approval. All training carried out with these funds must be directly related to the purpose of the program. 

Please include the activities impacted by COVID-19 in the barriers section of your NCC Report. Also, in the resolution section of your NCC Report, include your approach to these challenges and how they will meet your goals and objectives. You can submit your prior approval requests through HRSA's Electronic Handbooks. Contact your GMS with any additional questions.

We are completing the spring term with on-line clinical training and will not be able to send any students into primary care clinical sites. Are we able to award stipends or recruit new students into the project? (Added: 5/22/2020)

We recommend that you continue your project goals and objectives as much as possible for the remainder of this project period. Due to the COVID-19 pandemic, you have the flexibility to reprogram any of your in-person clinical training to telehealth clinical training. If you can meet the program’s goals and objectives in this way, then you may award stipends and recruit new students. Please reach out to your PO to discuss any changes or deviations needed with your project (e.g., changing scope, reallocating funds, modifying goals and objectives, etc.).

Deadlines

Will HRSA extend the deadline for the Non-Competing Continuation (NCC) progress reports due to the COVID-19 crisis? (Added: 5/22/2020)

We are committed to assisting you during these difficult times. If you are unable to submit your non-competitive continuation (NCCs) report by the posted due date, please contact your GMS.

Your GMS will gather information from you to determine next steps, which may include extending the deadline, allowing a one-time limited non-competitive continuation report, or taking another action as appropriate. Please note that non-competitive continuation reports vary by program so it is important to contact your HRSA grant official for specific guidance. All requests will be handled on a case-by-case basis, depending on recipient circumstances.

Other

Given the growing concerns about social isolation and the substance misuse that could result, does HRSA have a COVID-19 grant response in behavioral health, social isolation, and substance use? (Added: 5/22/2020)

We recommend you consult the Substance Abuse and Mental Health Services Administration (SAMHSA) online resources for treatment and recovery. That list of virtual recovery resources includes help lines, websites, and virtual meetings to support substance use treatment. SAMHSA also offers resources and information for mental health response to COVID-19.

Division of Nursing and Public Health Specific Questions

Does HRSA have any guidance or practical suggestions regarding the program requirements for the Advanced Nursing Education Nurse Practitioner Residency (ANE-NPR) program? (Added: 5/22/2020)

We have outlined below some possible options for meeting the requirements of the ANE-NPR program. (These options might be relevant to other programs as well.) Please reach out to your PO or GMS to discuss any changes or deviations needed with your project. 

  1. For ANE-NPR grant projects unable to meet the NP resident numbers outlined in their approved application:
    • Add NP residents to future budget years to make up for insufficient NP residents in an earlier year; carry over requisite funds into the next budget year. (Grant management guidance allows for funds to be carried over to the next budget period within a given competitive segment or from the last budget period of a competitive segment to the first budget period of the next competitive segment.)
    • Stagger NP resident cohort start dates in the next budget year, maintaining learning pairs or triads, if possible. (While permissible, this strategy may present educational challenges, as groups are smaller and at different developmental stages. These differences can limit the size of the pool for sharing thoughts, milestones, experiences, etc., all of which contribute to robust training.)
    • Work with the GMS to adjust the next budget year funds awarded. (For example, if you train one fewer NP resident in Budget Year 1, the GMS would decrease the award money proportionally up to $100,000 per NP resident in Budget Year 2.)
  1. For ANE-NPR grant projects who are losing partners or clinical sites:

    All ANE-NPR grant projects must have a least one academic and one clinical partner. 

    If you have fewer clinical sites, consider the following options:

    • Increase the number of NP residents at another clinical site;
    • Increase the number of clinical sites for an established partner;
    • Establish a new partnership or additional partnerships; or
    • Stagger clinical days so that some NP residents are shadowing seasoned clinicians, while other NP residents are seeing patients with the preceptor.

Some of the behavioral health and opioid workforce program grants stipulate that didactic training must occur concurrently with final fieldwork placement. May occupational therapy students begin didactic training early if their field site placements are cancelled or delayed? (Added: 5/22/2020)

We do not stipulate that the didactic training occur concurrently with the experiential training. Students may begin the didactic portion of their final field placement even if they are not permitted to begin the experiential training right now due to COVID-19, as long as they are in their final field placement class.

Date Last Reviewed:  May 2020