On July 8, 2019, RWC-340B submitted a comment letter in response to the HRSA Information Collection Request (ICR) published in the Federal Register on May 9, 2019. In the ICR, HRSA announced that it intends to revise the 340B program registration form for Ryan White Clinics (RWCs) and STD clinics to require the Notice of Funding Opportunity (NOFO) number associated with the grant and the time period of the assistance. In addition, HRSA proposes to require an STD clinic that receives in-kind funding to report the type of funding it receives.
RWC-340B’s letter to HRSA expressed concern that requiring RWCs and STD clinics to report a NOFO number when registering for the 340B program would impose an additional administrative burden on these covered entities. This new requirement is particularly concerning for clinics that receive subgrants or STD in-kind contributions because the recipient of these awards may not have access to the NOFO information for the primary grant. RWC-340B also expressed concern that HRSA’s request for a description of the type of assistance that an STD in-kind grantee receives may be a precursor to HRSA assessing whether the clinic is eligible for the 340B program based on that information. The letter reiterated RWC-340B’s opposition to HRSA’s unwritten policy that all non-FQHC grantees must register each clinic location operating under a single grant as a separate covered entity.
A copy of the letter that RWC-340B submitted is available on the RWC-340B website. We will keep you informed of any related developments.