ADMINISTRATIVE MANAGEMENT

 As a subrecipient of grant funding, you are responsible for the oversight and operations of award activities. This assures us that you are in compliance with applicable federal, state, and local requirements and performance expectations. 

As the awarding administrative agency, we are responsible for the programmatic monitoring and business management or oversight until the project period ends, and we close out your contract. 

 

Uniform Administrative Requirements 

The Office of Management and Budget (OMB) issued Uniform Administrative Requirements to streamline the regulations and requirements for grants management across the federal government. 

Link: https://ryanwhite.hrsa.gov/about/parts-and-initiatives/part-c-early-intervention  

Link: https://ryanwhite.hrsa.gov/about/parts-and-initiatives/part-d-swic  

 

DSHS Universal Standards 

The DSHS Universal Standards are applicable to all service categories funded under the Ryan White Part B Program for direct care service providers. These Universal Standards are taken directly from the HRSA Standards listed in the Part B HIV/AIDS Bureau (HAB) Universal National Monitoring Standards and expanded to include DSHS program requirements for all Ryan White Part B and State Service sub-recipients.  

(MOVE) Link to the resources section 

Link: https://ryanwhite.hrsa.gov/sites/default/files/ryanwhite/resources/hab-part-b-manual.pdf  

Link: https://www.dshs.state.tx.us/hivstd/taxonomy/default.shtm#section7  

 

Program Integrity 

Grant funding (Federal and State) must be spent as intended. As a subrecipient, you need to comply with program expectations, use funds in an efficient manner, and remain fiscally responsible. 

TRG provides oversight, guidance, and technical assistance to help ensure you spend grant dollars appropriately and prevent waste, fraud, and abuse. 

 

Guidance 

Subrecipients must comply with all grant policy terms and conditions outlined in the applicable U.S.

Department of Health and Human Services (USHHS) Grants Policies and Regulations, and requirements imposed by program statutes and regulations and HHS grant administration regulations, as applicable; as well as any requirements or limitations in any applicable appropriations acts. 

 

The USHHS Grants Policies and Regulations are currently available at https://www.hhs.gov/grants/grants/grants-policies-regulations/index.html

 

Subrecipient will ensure services are provided in accordance with the Health Resources and Services Administration (HRSA) Policy Notices (including administrative and fiscal requirements) located at https://ryanwhite.hrsa.gov/grants/policy-notices.  

Subrecipient will ensure services are provided in accordance with the DSHS Standards of Care and

Monitoring Guidelines http://www.dshs.texas.gov/hivstd/taxonomy/ when HRSA-specific Standards of Care do not exist. 

See TRG Appendix for full details: PDF of excerpt of Appendix B  

 

Program Participant Eligibility  

The following eligibility criteria must be established for individuals to receive funded services through Ryan White HIV/AIDS Program (RWHAP). Upon initiation of any services, subrecipients must determine whether an applicant meets the following eligibility criteria: 

  • Have a diagnosis of HIV infection,  

  • Provide documentation of Texas Residency (in the approved service area), and  

  • Provide complete and accurate income documentation 

  • Annual gross income must be equal to or below the approved income limit  

 

Following approval of initial eligibility, clients must be screened for program eligibility every six months to continue receiving assistance. 

 

Link: DSHS Eligibility to Receive HIV Services https://www.dshs.texas.gov/hivstd/policy/policies/220-001.shtm  

 

Conflict of Interest 

A conflict of interest occurs when an individual’s personal interests – family, friendships, financial, or social factors – could compromise his or her judgment, decisions, or actions in the workplace. Any potential (either actual or perceived) conflicts of interest must be disclosed on an annual basis. This disclosure includes the Board of Directors, employees (full-time & part-time), subcontractors, and volunteers. 

Link: TRG Policy Conflict of Interest 

Link: DSHS Policy 241.005 https://www.dshs.texas.gov/hivstd/policy/policies/241-005.shtm  

Link: HRSA COI Policy https://www.hrsa.gov/grants/standard-terms/conflict-interest-policy  

 

Confidentiality  

Strict confidentiality of all records is essential. Subrecipient must have a system, including detailed policies and/or procedures, in effect to protect client or patient records and all other documents deemed confidential by law that are maintained in connection with the activities funded under this grant.  All disclosures or transfers of client or patient information must be done in full compliance with applicable laws, including the appropriately signed release of information forms, where applicable.  All release of confidential information forms must comply with TRG Policy SR-1704 Exchange/Release of Information (Link: TRG Exchange/Release Policy). 

All Subrecipient agencies must be in full compliance with the current regulations and rules of the Health Insurance Portability and Accountability Act (HIPAA).  

 

The “Health and Safety Code” of the State of Texas provides for both civil and criminal penalties against anyone who violates the confidentiality of persons protected under the law.  All employees, volunteers, and members of the Board of Directors of Subrecipient agencies are required to sign statements of confidentiality assuring compliance with applicable laws on an annual basis.   

On an annual basis, TRG requires funded staff have a signed confidentiality statement and accompanying training on confidentiality and protected health information (PHI).  To comply with this expectation, The Texas Department of State Health Services (DSHS) has created an online training on the TRAIN Texas website (https://www.train.org/texas/welcome).   Subrecipients can complete the TRAIN Texas online training or use internal confidentiality/PHI training that have reviewed and approved by TRG.   

Link: TRG Confidentiality Policy 

Link: DSHS https://www.dshs.state.tx.us/thsvh/account.shtm