Notice of Funds Available (RFP)

Nebraska Council On Developmental Disabilities
This notice is not publicly posted.
The application deadline for this notice has expired.

2019.FGR.05:  Disability Benefits Planning and Assistance

Specifications

Posted Applications Due Start Date End Date Amount MatchPoverty Match Council Staff
Jul 29, 2019 Oct 01, 2019 Sep 30, 2020 $30,000.00 $10,000.00$0.00 Joni Dulaney

Introduction

The Nebraska Council on Developmental Disabilities (NCDD, or Council), under the State of Nebraska, Department of Health and Human Services (“DHHS”), Division of Public Health, announces the release of a Notice of Funds Available (NoFA) through a Request for Applications to meet the State Plan Goal of Employment. Funds for these projects are provided by the Council under DHHS through the Federal Administration on Intellectual and Developmental Disabilities.

Project Description

Goal 3, Objective C: Provide access to benefits planning and assistance services for an increased number of service providers, individuals with intellectual and other developmental disabilities and their families to support the person’s employment choices.

Complex disability benefit regulations have made it difficult for individuals with disabilities to enter the workforce while still maintaining essential healthcare coverage and disability benefits. Benefits planning and assistance services help individuals with disabilities develop an individualized plan to maximize work through full use of state and federal work incentive programs. Benefits planning services analyze how changes in employment, earnings, marital status, or other circumstances may affect an individual’s health coverage and disability related benefits. Ongoing assistance helps the individual plan for and transition through critical changes in cash benefits, Medicaid, and Medicare; make full use of available work incentive programs; and increase long term success.

Systemic Issues Related to Benefits Planning and Assistance:

Nebraska is experiencing challenges related to supporting individuals with developmental disabilities to seek and maintain competitive, integrated employment. Nebraskans with disabilities want to work. However for many, there are barriers and questions that prevent them from being confident that they will maintain required benefits, services, and supports if they are employed.

Employment services and referrals for transitioning youth with disabilities must be made through Nebraska Vocational Rehabilitation (VR) under the Workforce Innovation Opportunity Act (WIOA). One significant barrier individuals have encountered is that Nebraska VR has implemented an Order of Selection, which is a process for prioritizing VR-eligible individuals when funds are not available to serve everyone. Those in Priority Group 1 category are those with the most significant disabilities, Priority Group 2 are those with significant disabilities, and those in Priority Group 3 are all other eligible individuals. In December 2017, VR closed Priority Groups 2 and 3, and in April 2018, Priority Group 1 was served. VR remains under this Order of Selection, although funding made available in Fall 2018 allowed VR to remove 200 people from its waiting list.

Challenges related to serving these individuals include policies regarding access to employment services through the Comprehensive Developmental Disabilities Waiver for Adults, the Developmental Disabilities Adult Day Waiver, and the wording within the Interagency Agreement between the Nebraska Department of Health and Human Services Division of Developmental Disabilities (DD Division) and Nebraska Vocational Rehabilitation.

If a person is accepted into VR services, the benefits planning service is provided as an initial step to pursue competitive, integrated employment. Unfortunately, at this time, there are limited options for people with developmental disabilities to access benefits planning if they are not being served by VR, and ongoing assistance options are extremely limited. One option available to youth ages 14-21 who have developmental disabilities and live in Dodge, Washington, Cass, Sarpy, and Douglas Counties is through the Easterseals BRIDGE program. Additionally, anyone statewide can access the WIPA (Work Incentives Planning and Assistance) services offered under a grant held by Easterseals, but the capacity of the WIPA program is limited. The DD Division is unable to pay or reimburse for benefits planning, pre-employment transition services, and job coaching under the Developmental Disabilities Adult Day Waiver or the Comprehensive Developmental Disabilities Waiver.

Benefits analysis, planning, and work incentive assistance are key in meeting employment goals. Without the opportunity to work with a certified benefits planning specialist, many individuals with developmental disabilities and their parents/guardians are reluctant to accept employment for fear of losing services and benefits. Individuals who are currently employed are hesitant to accept more hours or promotions for this same reason. Unfortunately, these important services are not readily available across the state. The VR Order of Selection, the lack of a service definition in the current developmental disability waivers to allow providers to bill for this important service, and the lack or perceived lack of certified benefits planning specialists all contribute to inadequate benefits planning services in Nebraska.

Project Intent and Expected Outcomes:

The intent of this subaward is to form a Task Force to develop a framework to strengthen, support, and expand benefits planning and assistance services in Nebraska.

This Task Force will:

• Recruit a robust membership to the Task Force. Membership should include representatives from Nebraska VR, DHHS Division of DD, DHHS Division of Medicaid and Long Term Care, DHHS Division of Behavioral Health, self-advocates, parents/guardians, certified benefits planning providers (representatives of agencies currently providing benefits planning services may serve on the workgroup), developmental disabilities service providers, and other relevant stakeholders.
• Provide historical context of benefits planning in Nebraska, including these services as provided by Goodwill Industries of Greater Nebraska, Nebraska Easterseals, and other benefits providers.
• Investigate current benefits planning policies and processes to include the Memorandum of Understanding between Nebraska VR and the DD Division.
• Identify the certified benefits specialists and map their locations across the state.
• Solicit feedback on the issues, gaps, and barriers that hinder the ability of individuals to access benefits planning services.
• Compare the number of individuals receiving benefits planning services annually with the number of individuals with developmental disabilities who receive waiver services but have been denied access to VR employment services as a result of the Order of Selection wait list.
• Clarify how benefits planning services are provided to individuals receiving services through DHHS Division of Behavioral Health while individuals with developmental disabilities are not receiving these services. How are benefits planning professionals compensated for this service within the Behavioral Health and Developmental Disabilities systems?
• Research best practices and what other states are doing for benefits planning.
• Provide a final report of recommendations, strategies, and approaches Nebraska could take to improve benefits planning services to include:
o An overview of Nebraska’s current benefits planning services and employment incentives with recommendations for addressing the barriers and gaps in benefits planning services.
o Development of a policy framework that expands and strengthens the number of individuals receiving benefits planning services. The gap-filling framework will be expected to build on current benefits planning services while focusing on developing and strengthening benefits planning referral policies and processes necessary to improve access to quality benefits planning services.
o Systems-level, programmatic-level, and consumer-level strategies to strengthen and improve the utilization of benefits planning services.
o Optional services based on available evidence, emerging strategies, and promising practices in the field of benefits planning services to expand capacities and deliver direct services.
o Strategies to secure funding to pursue alternate benefits planning options. This may include braiding resources across various funding streams to deliver, sustain, and expand benefits planning services.

Provide a description of work that would be addressed in a second year if an additional year of funding would be requested. A second year of work on this project may include a demonstration project or other project to carry out recommendations from the final report

Qualifications and Guidelines

Money is available to fund one project a maximum of $30,000 for one year. One additional year of funding may be available. In order to receive continuation funding, the subrecipient must demonstrate appropriate activities in the previous year and must submit an application to be approved by members of the Council for the following year.

NOTE: To avoid a conflict of interest, applicants responding to this RFA must not be entities currently offering benefits planning services in Nebraska.

The DD Council

NCDD is an independent agency funded by the federal government to work with the State of Nebraska to better support people with developmental disabilities and their families. The Council engages in Advocacy, Capacity Building, and System change activities that assure that individuals with developmental disabilities and their families participate in the design and have access to needed community services, individualized support, and other forms of assistance that promote self-determination, independence, productivity, and integration and inclusion in all facets of community life.

NCDD is comprised of 24 volunteer members appointed by the governor and a small staff. Members include individuals with developmental disabilities and family members or guardians of individuals with developmental disabilities, professionals, advocates, and representatives of state and private agencies.

Council Goals and Objectives

A complete list of the Council's 5-Year State Plan Goals and Objectives is available in Attachment 2.

Definitions

Benefits Planning and Assistance: An on-going process that includes review of and assistance with state and federal benefits and their associated work incentives to support people who wish to pursue employment.

Community Inclusion refers to areas such as where an individual lives, works, or goes to school; relationships; pursuit of personal interests; meeting spiritual needs; learning and personal growth; physical and emotional health; self-direction; and exercising rights, roles and responsibilities as a citizen.

Competitive Integrated Employment: The term “competitive integrated employment” means work that is performed on a full-time or part-time basis (including self-employment) –

(A) for which an individual –
(i) is compensated at a rate that:
(I)(aa) shall be not less than the higher of the rate specified in section 6(a)(1) of the Fair Labor Standards Act of 1938 (29 U.S.C. 206(a)(1)) or the rate specified in the applicable State or local minimum wage law; and
(bb) is not less than the customary rate paid by the employer for the same or similar work performed by other employees who are not individuals with disabilities, and who are similarly situated in similar occupations by the same employer and who have similar training, experience, and skills; or
(II) in the case of an individual who is self-employed, yields an income that is comparable to the income received by other individuals who are not individuals with disabilities, and who are self-employed in similar occupations or on similar tasks and who have similar training, experience, and skills; and
(ii) is eligible for the level of benefits provided to other employees;

(B) that is at a location where the employee interacts with other persons who are not individuals with disabilities (not including supervisory personnel or individuals who are providing services to such employee) to the same extent that individuals who are not individuals with disabilities and who are in comparable positions interact with other persons; and

(C) that, as appropriate, presents opportunities for advancement that are similar to those for other employees who are not individuals with disabilities and who have similar positions.
(Source — Workforce Innovation Technical Assistance Center website)

Developmental Disability - The term “developmental disability” means a severe, chronic disability of a person that:
• Is attributable to a mental or physical impairment or combination of mental and physical impairments;
• Is manifested before the person attains age twenty-two;
• Is likely to continue indefinitely;
• Results in substantial functional limitations in three or more of the following areas of major life activity: (a) self-care; (b) receptive and expressive language; (c) learning; (d) mobility; (e) self-direction; (f) capacity for independent living; and (g) economic self-sufficiency;
• Reflects the individual’s need for a combination and sequence of special, interdisciplinary or generic services, individualized supports, or other forms of assistance that are of lifelong or extended duration and are individually planned and coordinated;
• Is an individual from birth to age 9, inclusive, who has a substantial developmental delay or specific congenital or acquired condition, may be considered to have a developmental disability without meeting three or more functional limitations in major life activities, if the individual, without services and supports, has a high probability of meeting those criteria later in life.

Diverse Identities refers to people of various races, cultural and ethnic heritages, genders, gender identities, gender expressions, sexual orientations, ages, and religions from diverse socio-economic and geographic backgrounds.

Application and Project Timeline

The application consists of a cover sheet (Attachment 1), a set of questions, work plan, budget, and budget justification to be submitted with the application.

Applications must be submitted online via www.ddsuite.org, NCDD's grants management system, prior to the published deadline. No hard copies will be accepted. Applicants must have or create a DD Suite user account and an organization account in order to submit an application. Go to www.ddsuite.org/TA for detailed instructions on creating DD Suite user and organization accounts (Systems Information/Accounts and Organizations).

Deadline to submit applications: Applications must be submitted through DD Suite by 11:59 PM on Monday, July 29, 2019.

Applicants notified of decision: August 30, 2019. All applicants who respond to this NOFA will be notified of the outcome of their application (awarded, application modifications requested, or denied) by email through DD Suite.

Projects will begin no earlier than October 1, 2019 and must be completed by September 30, 2020.

All questions regarding this grant solicitation must be submitted in writing via email to Joni Dulaney, NCDD Program Specialist, at joni.dulaney@nebraska.gov.

Applicants may be instructed to revise and resubmit incomplete applications.

The resulting subawards from this RFA are subject to and shall follow federal regulation, as set forth herein. Subrecipients receiving subaward funds may only be paid up to the actual and allowable costs (as defined herein) of completing the Project Description. No Subawards resulting from this RFA will be fee-for-service contracts, regardless of the method of payment, and no Subrecipient may keep a profit from its subaward. Program income must be noted as Match. More detail about the terms of this funding is set forth in Section 15.6 Program Income, and 15.7 Matching Requirements.

Community Support

The Council is mandated by federal law with assuring that individuals with developmental disabilities and their families are integrated and included in all facets of community life. Community inclusion factors are taken into consideration when Council members review applications. The extent that a subaward application promotes full participation of the target population in the same activities of community life, recreation, employment, and education being utilized by other community members goes into the decision process. Inclusion of the larger community in the planning and implementation of the project proposal is important to enhance awareness and the expectation of success.

Project Sustainability

Council subawards are awarded for one year. Applicants must describe in detail their plan to sustain the project once Council funds end (i.e., who will maintain the project, etc.). Subaward applicants can increase the likelihood that projects will be sustained by including local community service groups, businesses, public education, and local government entities in their development. The plan should identify the activities, features, or practices that the applicant wants to sustain.

Subaward Funds and Match

Council funds are available to support one project for a maximum of $30,000 for one year. Note: A total award of this amount of funds is not guaranteed, but is subject to actual money awarded to DHHS from the Federal Awarding Agency and to DHHS’ discretion. Applicants are required to provide a 25% match of the funds requested. The match can be either cash or in-kind. Cash match is support provided to a project by an agency that they would have to pay for. Examples include part of someone’s salary, rental space, or postage. In-kind match examples are donated time or items such as volunteer time or copying provided by a business. To determine the minimum matching funds required, divide the amount of Council funds requested by 3 (e.g., $30,000 divided by 3 = $10,000 minimum match required).

Council subaward funds cannot be used for the following:
• Construction or renovation costs
• Direct services for people with developmental disabilities (unless these services are part of a model demonstration).

RFA Overview

11.1 Period of Performance
The Period of Performance is the time during which a successful Applicant may incur costs to carry out the work authorized under this RFA and the resulting Subaward. See the definitions in 2 CFR § 200.77 or 45 CFR § 75.2. The initial Period of Performance for this RFA is from October 1, 2019 to September 30, 2020. This period may be extended by DHHS as allowable by the Federal Funding Agency. If state funds are involved in the award, this may also determine whether DHHS may extend a Period of Performance.

For the initial Period of Performance, all costs must be invoiced to DHHS by October 31, 2020 and liquidated (i.e., spent) by October 31, 2020. These dates are dependent on federal periods of allowability and DHHS’ own ability to timely process payments. They may be subject to change; final dates will be included in the final Subaward between the parties. If an Applicant believes it cannot meet these deadlines, it should not apply for funding under this RFA. Obligation and liquidation deadlines may be extended as allowed by the Federal Funding Agency, but no extensions are guaranteed. Future Periods of Performance, as allowed by DHHS, may have different obligation and liquidation deadlines.

11.2 Applicable Law
Because the funds to support the activities under this RFA involve federal funds, usage of these funds is subject to federal law, in addition to any applicable state law. The Uniform Grant Guidance, 2 CFR §§ 200 et seq. (“UGG”) applies to subawards funded from the United States Department of Agriculture (USDA), the Department of Housing and Urban Development (HUD), the Department of Labor (DOL), the Environmental Protection Agency (EPA) or other federal agencies. The United States Department of Health and Human Services (HHS) has adopted the UGG, but has implemented and re-codified it at 45 CFR §§ 75 et seq. (“HHSGG”); for awards funded by HHS, those regulations apply. Throughout this RFA, both the UGG and the HHSGG will be cited, although they are substantially similar.

The HHSGG shall apply to this RFA if it awards funds from block grants authorized by the Omnibus Budget Reconciliation Act of 1981, unless Nebraska statute or regulation has established provisions for the payment costs and services; in all other respects, as provided herein, those block grant subawards are governed by 45 CFR §§ 96 et seq.

Additional federal and state statutes and regulations may apply to the funding contained herein. These may be included in the Additional Program Requirements section as well as in the Subaward itself.

Further information about allowable costs and activities may be set forth herein.

11.3 Eligibility
Applicants must demonstrate a working knowledge of the issues that affect people with developmental disabilities and their families, experience working with and/or advocating on behalf of people with developmental disabilities, and a history of conducting education in the activity area identified in the application. NCDD strongly encourages applications from organizations that are located in rural or urban poverty areas, organizations that employ staff with disabilities, and/or organizations that represent linguistic and cultural minorities.
Additional requirements for determining the eligibility of entities may also be included in the Project Description.

11.4 Funding Parameters
One applicant will be awarded up to $30,000 for project activities to begin on or after October 1, 2019 and end no later than September 30, 2020. NCDD will award a minimum of two subawards in any of the four goals identified in this solicitation.

The minimum non-federal matching funds required for this project shall be an amount equal to 25% of the grant funds awarded (e.g., $10,000 match for a $30,000 subaward.) Applicants are strongly encouraged to provide additional non-federal matching funds to the project. The source of non-federal matching funds can include a direct financial contribution, revenue from other organizations, and in-kind contributions from the applicant or a third party such as volunteer time, supplies and meeting space.

NCDD subaward funds cannot be used for ongoing organizational activities, to supplant existing private, state or federal funding sources, to purchase equipment or furnishings, or to duplicate or replace existing services provided to people with developmental disabilities and family members.

RFA Procedure

This RFA seeks Applications to complete activities allowable under the funding source identified in the Period of Performance section above. All Applications must conform to all instructions, conditions, and requirements included in this RFA. Applicants should carefully examine this RFA, as well as the requirements on the state or federal funds involved.

12.1 Evaluation
All Applications submitted by the deadline in response to the RFA must meet the technical application requirements set forth in the Technical Review Criteria (Attachment 3). The Council's Grants Review Committee members will review each application using the Subaward Evaluation Criteria Score Sheet (Attachment 4) on August 15, 2019. Council members will also receive copies of the applications and are encouraged to review each application. Committee recommendations for funding will be presented at the August 16, 2019 Council meeting where members will vote on the applications to be funded.

Applicants will be notified through DD Suite of funding decisions by Friday, August 30, 2019. Applicants selected for funding may receive a contingency notice requesting clarification or additional information prior to the official award. Upon receipt and approval by Council staff of any contingencies, a formal subaward document will be sent to the applicant for electronic signature. The award will be effective on the approved project start date regardless of when all required documents are submitted and approved. If there are no contingencies to be addressed, the subaward document will be sent to the applicant for electronic signature. All subaward signatures will be obtained using DocuSign. No work shall begin on the project prior to October 1, 2019.

All applicants who respond to the public posting of this solicitation will be notified of the decision on their application (awarded, application modifications requested, or denied) by email through DD Suite. Applicants may also log on to their account on DD Suite at www.ddsuite.org to check the status of their application.

12.2 Grievance and Protest Procedures

All grievances must follow the DHHS Subaward Grievance/Protests Procedures, available on the DHHS website, www.dhhs.ne.gov. Grievances must be filed timely.

Project Specific Requirements

At a minimum, projects must include these following activities:
- Develop training/education curriculum and materials, if applicable
- Conduct outreach to publicize training and recruit trainees, if applicable
- Offer reasonable accommodations (including translation) as requested
- Conduct training/education activities, if applicable
- Collect verifiable data on the number, category and race of people (individuals/family members) participating in training/education activities
- Implement follow-up strategies and collect verifiable data to measure the number of individuals and family members who report increasing their activity as a result of your efforts.
- As applicable, identify strategies to successfully recruit and train individuals from culturally diverse communities.

Subrecipients must collect and report federal performance measure data to NCDD through periodic programmatic reports. Guidance to reporting on the new Federal Performance Measures is included as Attachment 5 to this notice.
Subrecipients must collect and report project expenses to NCDD through periodic expense reports.

Requirements of All NCDD Subrecipients

The following terms and conditions apply to all organizations awarded NCDD grant funds:
- Organizations receiving NCDD grant funds must provide updates on project activities as established and scheduled by NCDD. All Subrecipients shall submit periodic programmatic and expense reports online through the DD Suite. Detailed instructions on completing these reports can be found in the Grantee Process Help Modules on the Help page at http://www.ddsuite.org/TA.

- Subrecipients shall administer and report survey results using an NCDD approved Customer Satisfaction Survey (Attachment 7).

- General Terms - Subawards

- Verification of Taxpayer Reporting (W9) and ACH Form for electronic funds transfer payments. Note: Electronic fund transfer (EFT) is the required method of payment for all payees doing business with the State of Nebraska.

- Organizations that receive NCDD subaward funds shall submit quarterly payment requests on invoices that are provided by NCDD.

-NCDD reserves a royalty-free, non-exclusive, and irrevocable license to reproduce, publish or otherwise use, and to authorize others to use, any work developed under any grant awarded by NCDD.

- Final drafts of any training materials, publications, videos, websites or other products shall be reviewed and approved by NCDD prior to dissemination to the general public. Products must acknowledge NCDD funding (e.g., Funded through a grant from the Nebraska Council on Developmental Disabilities, U.S. Department of Health and Human Services, Administration on Intellectual and Developmental Disabilities, Federal Award No. 93.630).

- All materials developed by subrecipients under this award shall be available and/or reproducible in accessible formats. Materials will be submitted to the Council office in electronic format. Hard copy may be requested.

- As a condition of grant award, Subrecipients will collect and provide data to NCDD for post-project performance measures after the grant period has ended. Applicants are encouraged to review the Performance Measures in Attachment 5.

- The following federal audit requirements are applicable to NCDD funds: Office of Management and Budget (OMB) Circular A-21, A-87, A-122, and A-133, as well as Title 48 Code of Federal Regulations (CFR) Part 31, as well as the Single Audit Act of 1984 (P.L. 98-502).

- The following regulations from Title 45 Code of Federal Regulations (CFR) may be applicable to all sub-Subrecipients. 45 CFR Parts 16, 30, 76, 80, 81, 84, 85, 86, 87, 91, 92, 93, 97, 100, 1385, and 1386.

Terms

Applicants must be aware of the following terms when submitting their Applications. These terms will be included in the resulting Subaward between the parties, as well.

15.1 Addenda
The following Addenda will be incorporated into any Subaward with a selected Applicant. They are available online at http://dhhs.ne.gov/Pages/Grants-and-Contract-Opportunities.aspx:

• Addendum A - DHHS Standard Terms – Subawards
• Addendum B - DHHS Insurance Requirements – Subawards

DHHS reserves the right to amend these terms at any time during the RFA; to negotiate the terms with selected Applicants; to amend or change these terms for any subsequent Subaward signed and executed by the parties; or any combination of the above. Terms required by federal or state law will not be negotiated, and if an Applicant cannot agree to these terms, DHHS may withdraw or modify the Intent to Subaward and take any of the actions set forth herein.

15.2 DD Act Program Specific Requirements
The parties agree to comply with the Developmental Disabilities Assistance and Bill of Rights Act that:
A. The individuals served under the proposal meet the federal definition of developmental disabilities.

B. Funds will be used to make a significant contribution toward enhancing the independence, productivity, and integration into the community of persons with developmental disabilities.

C. Any services provided using grant funds will be provided to individuals with developmental disabilities in an individualized manner consistent with the unique strengths, resources, priorities, concerns, abilities and capabilities of such individual.

D. The human rights of the individuals with developmental disabilities (especially individuals without familial protection) who are receiving services under programs assisted under this subtitle will be protected consistent with Section 109 of the Developmental Disabilities Act, relating to the rights of individuals with developmental disabilities.

E. Programs, projects, and activities funded and the buildings in which such programs, projects, and activities are operated, will meet standards prescribed in regulations and all applicable Federal and State accessibility standards, including accessibility requirements of the Americans with Disabilities Act of 1990, Section 508 of the Rehabilitation Act of 1973, and the Fair Housing Act.

F. All programs and facilities operated with grant funds meet minimum standards, regulations, and guidelines as prescribed by federal, state, and local authority for the maintenance and operation of such programs and facilities.

G. In order to avoid discrimination against persons with limited English proficiency on grounds of national origin, adequate steps will be taken to ensure that such persons receive the language assistance necessary to afford them meaningful access to the programs, free of charge.

H. Conduct a satisfaction survey using a format and process identified by the Developmental Disabilities Planning Office, Health and Human Services.

15.3 Budget Changes
The final Subaward may contain terms to allow a Subrecipient to modify a budget, with or without approval from DHHS. Applicants should not, however, rely on this when submitting budgets.

15.4 Direct Costs
Under this Subaward, DHHS shall only pay for actual and allowable costs (as defined in this section) incurred during the Period of Performance.

To be allowable, all costs must be:
• Necessary for the performance of the Subaward activities;
• Reasonable, as provided in 2 CFR § 200.404 or 45 CFR § 75.404;
• Allocable to the federal award, as provided in 2 CFR § 200.405 or 45 CFR § 75.405;
• Consistent with all other requirements of the Cost Principles in 2 CFR § 200 Subpart E or 45 CFR § 75 Subpart E; and
• Consistent with all other law, regulation, policy, or other requirements applicable to the state or federal funds involved.

To be actual, all costs must be finalized and spent by the appropriate dates set forth in the Subaward.

Particular Federal Funding Agencies may have additional requirements and stipulations regarding allowable costs under that particular funding.

Applicants should be aware that direct personnel costs must be consistent with 45 CFR § 75.430 or 2 CFR § 200.430, as applicable. These costs must be able to be backed by sufficient documentation, or must be shown to be allocable to the award via an alternative, allowable method, such as a random moment time study.

15.5 Indirect Costs
Federal law defines indirect costs as “costs incurred for a common or joint purpose benefitting more than one cost objective, and not readily assignable to the cost objectives specifically benefitted, without effort disproportionate to the results achieved.” 2 CFR § 200.56 and 45 CFR § 75.2. All indirect costs may only be paid if they are consistent with the UGG or HHSGG, as applicable. As provided in 2 CFR § 200.414 and 45 CFR § 75.414, indirect costs may only be paid from a federal grant if paid through a federally-approved rate or a rate negotiated between DHHS and the Applicant. If the Applicant has never had a federally-approved indirect rate, it may charge indirect costs as consistent with the federal rules for de minimis indirect costs.

Cost Allocation plans may set forth a direct allocation of all costs under a subaward, or may allocate only a portion of those costs along with an indirect rate. Subrecipients may not, however, charge items as direct costs and also as indirect costs.

If Applicants plan to charge indirect costs other than through a cost allocation plan, Applicants thus must provide one of the following along with their budget: 1) A current federally-approved indirect cost rate agreement; 2) A currently approved indirect cost rate agreement with DHHS; or 3) A calculation of de minimis indirect costs consistent with federal rules. DHHS may provide a calculator to aid programs in calculating de minimis indirect costs, upon request;

Indirect costs and cost allocation plans may also be negotiated after the Intent to Subaward. As consistent with law, Applicants may voluntarily opt to take a lower indirect rate than their approved agreement, or indirect cost calculation, allows.

15.6 Program Income
Any revenue generated by the Subaward is Program Income (see definition in 2 CFR § 200.80 or 45 CFR § 75.2). Program Income requires an accounting of its use and must be handled in accordance with 2 CFR § 200.307 or 45 CFR § 75.307. As per the Notice of Award for the federal funds involved in this RFA or from other regulation, all program income generated by the project as a result of this RFA must be reported as matching funds. Please see the regulations cited above for more detail.

15.7 Matching Requirements
Subawards resulting from this RFA require the successful Applicant to match the funds awarded at a rate of 25% of total program costs. See 2 CFR § 200.306 or 45 CFR § 75.306. Match must be based on the total costs, not the percentage of the federal funds alone. Federal funds from another source may not be used as match.

15.8 Additional Program Requirements
This RFA and any resulting Subaward will be subject to the HHS Grants Policy Statement. A copy of it is available here: https://www.hhs.gov/sites/default/files/grants/grants/policies-regulations/hhsgps107.pdf.

Supporting Documents