Grants Management that Makes Sense
by Elizabeth “Issie” Karan, Legal Counsel
Hemophilia Treatment Centers (HTCs) often must grapple with grey areas when it comes to compliance with the rules for their federal funding. The Hemophilia Alliance team works to demystify these guardrails and steer HTCs towards effective operations. We want to highlight an area of grants management that often creates confusion.
Many HTCs are lucky enough to accrue a balance of program income during their grant period. This is not common for federally funded grants. As a result, many accountants familiar with other grant programs expect HTCs to zero out their accounts at the end of the fiscal year. Because revenue cycles involving high-cost therapies can be volatile, HTCs should consider prudent accounting practices. The Uniform Grants Guidance allows federal grantees to carry forward balances to subsequent periods of performance with permission from their awarding agency. The Maternal and Child Health Bureau (MCHB), which oversees the regional HTCs and the grant program more generally, has the authority to allow this practice.
At 45 CFR § 75.308 (d)(3), Revision of budget and program plans, the UGG states:
“… HHS awarding agencies are authorized, at their option, to waive prior written approvals… [s]uch waivers may include authorizing recipients to … [c]arry forward unobligated balances to subsequent periods of performance…”
If HTCs do not currently carry forward unobligated balances or receive pressure not to, we recommend that you speak with your regional grantee about your policy. HTCs should embrace grants management policies that sustain their comprehensive care model for generations of bleeding and clotting disorder patients to come.
Also in this Issue…
Notes from Joe
· Harmony in Hemophilia
· Join us for the Alliance Hill Day!
· Request for Coverage of Desmopressin Acetate Nasal Spray (DDAVP)
· 1st Annual Hemophilia Alliance Pharmacist CE Conference