Use of Hospital Preparedness Program Funds

COVID-19 Preparedness and Response

National Healthcare Preparedness Programs (NHPP) has partnered with ASPR’s Grants Management to develop a fast-track approval method that enables jurisdictions to request the use of Hospital Preparedness Program (HPP) cooperative agreement funds for the development of action plans, training, and the rapid procurement of supplies needed during the current coronavirus disease 2019 (COVID-19) emergency response. ASPR has reduced the normal 30-day request process to one to three business days for urgent requests.

Enacted in June of 2019, the Pandemic and All-Hazards Preparedness and Advancing Innovation Act (PAHPAIA) amended section 319C-2 of the Public Health Service Act to allow HPP funds to be used for response activities. HPP funds may, on a limited, case-by-case basis, be used to support response activities to the extent they are used for HPP’s primary purpose: prepare communities and hospitals for public health emergencies and to improve surge capacity.

Upon written request by a recipient, HPP funds may, on a limited, case-by-case basis, be used to support response efforts if the activities fall within those authorized by the HPP’s statutory authority, section 319C-2, the HPP FOA, and the terms and conditions of the HPP notice of award. The activities also must support progress toward achieving ASPR’s four health care preparedness and response capabilities. In addition, the activities must meet the preparedness goals of the statute authorizing HPP.

From a federal grants management perspective, the use of HPP funds to prepare for suspected or known COVID-19 patients, including the development of action plans, purchase of supplies for health care facilities, and training for all personnel would be allowable expenses as long as they are:

• reasonable,
• allowed under the cost principles,
• and allocable to the program.

Activities may include, but are not limited to:

• Prepare health care coalitions (HCCs) and their members to coordinate, share information, educate, exercise, and train for COVID-19 and other infectious diseases.
• Engage the primary health care providers and entities that will be responsible for treating and responding to COVID-19, e.g., hospitals, emergency departments, urgent care, pulmonologists, nurses, EMS, PPE suppliers, in coalition activities, including education and information sharing, trainings and exercises. This will increase the membership of health care coalitions and improve their readiness for COVID-19 and other infectious diseases.
• Broaden preparedness initiatives within hospitals beyond the Emergency Department, by including intensivists/pulmonologists, infectious disease specialists, waste managers, clinical lab technicians, and nursing teams.
• Develop risk communications materials at the HCC and facility level for staff, health care providers, and patients. Appropriate risk communication at the HCC level can effectively mitigate the potential stress on hospitals by developing and sharing such materials, with a focus oriented towards the communities that may include specific populations affected by COVID-19 (for example, individuals who have recently traveled from China).

Funds may not be used for public health activities such as epidemiological investigation, surveillance, public health laboratory testing or equipment, etc. that are supported through CDC’s Public Health Emergency Preparedness (PHEP) Program cooperative agreement.

The use of HPP funds during an emergency response must be for activities within the approved scope of work in the HPP recipient’s work plans for the current budget period. However, it is not uncommon that emergency response activities may constitute a change in scope as they are not part of previously approved recipient work plans or subsequent budget redirections.

If recipients propose to use HPP funds for response activities that are outside the approved scope of work, then recipients must identify this change in their request so that they can obtain specific prior approval from ASPR to undertake these change-in-scope activities. Based on the request, the approval process may include both a budget redirection and a changes in the scope of activities. Prior approval by the ASPR chief grants management officer (CGMO) is required for a change in scope under any award, regardless of whether there is an associated budget revision.

Expedited Process to Request Use of HPP Funds for Response

Recipients must send an e-mail to both the assigned ASPR Grants Management’s grants management specialist (GMS) and the assigned HPP field project officer (FPO) with the following required information:

Justification for the use of funds and how the recipient plans to conduct various tasks as part of a comprehensive work plan activity.

If a change in scope is known or anticipated, a justification for the change in scope of the work plan.

Estimated amount of funds to be redirected, if any.

Budget category. If redirection is necessary, request should indicate from which budget category funds will be redirected and to which category they will be redirected.

Description of the activities, such as exercise goals and objectives, identified capabilities to be tested, or inclusion of at-risk individuals. For example:

• A statement of how the use of HPP funds in this event will enable the testing of emergency plans and protocols.
• A description of how activities to be performed will be consistent with ASPR guidance for mitigating risk to at-risk individuals.

Statement confirming that results of the exercise or incident will be documented in a formal after-action report (AAR) and improvement plan (IP) submitted to ASPR within 120 days of the conclusion of the disaster or public health emergency.

Statement demonstrating how a delay in approval or disapproval of the request would result in serious injury to citizens or other adverse public impact.

Following the HPP FPO’s review of the request and recommendation, ASPR Grants Management will issue its final determination within one to three business days and e-mail the recipient to let the jurisdiction know whether ASPR has approved the request to use HPP funds for emergency response activities. If the request is approved, the e-mail will serve as the recipient’s authorization to use funds. ASPR Grants Management will upload the authorizing e-mail into GrantSolutions. The recipient must submit a revised budget and a revised work plan within 30 days from the date of the ASPR Grants Management e-mail authorizing the use of HPP funds for emergency response activities.