We are currently in the process of finalizing our comments on the HRSA PIN 2013-01, Health Center Budgeting and Accounting Requirements. We appreciate all of the feedback and comments we have received from health centers and PCAs and want to remind you all that it is vitally important for ALL health centers and PCAs to submit their own comments on this PIN, highlighting the impact this will have your health centers. Comments are due August 30, 2013 and can be submitted via email to OPPDBudgetPIN@hrsa.gov. Please contact Roger Schwartz and Susan Sumrell if you have any questions about the PIN or NACHC’s comments on the PIN.
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Bellow is a copy of comments to PIN 2013-01 submitted to HRSA by Consejo de Salud de Puerto Rico, Inc.:
August 30, 2013
Consejo de Salud de Puerto Rico, Inc.
1034 Hostos Avenue
Ponce, PR 00716
Ref: Comments Regarding HRSA’s Policy Information Notice (PIN) 2013-01
Our comments regarding PIN 2013-01 are hereby presented with the outmost respect and with the expectation that our observations are received as a professional contribution to further enhance the commitments of all Community Based Organizations (CBO) whose grass root endeavors has unquestionably served as the foundation for the success of HRSA’s Primary Healthcare programs.
We specifically aim to point out that: Section IV. Scope of Project and Budget Requirements; B. Health Center Non-Grant Funds (Open for public comments), put at risk the equity, the goodwill value of community health centers and their corporate identity.
The fact that HRSA exert full discretionary control over Non-Grant Funds generated by a grantee completely diminishes and devaluates the equity contribution brought by the CBO into the development of the health care programs and the organization itself. Healthcare programs are not carried out in a vacuum. They are a combination of funds provided by the grantor and the equity provided by the grantee. In fact, HRSA requires that within 120 days of a grant award notification grantees are able to fully implement a given program. How could that happen if capital assets were not in place by that time. With few exceptions HRSA provides no money for such capital assets.
On the other hand the time and efforts put into the CBO by community members, most probably in the form of capital assets and an earned valuable reputation referred to as goodwill, is completely ignored by HRSA’s PIN 2013-01. Furthermore, HRSA requires that CBO’s statutes address that the majority of the Board members are consumers who volunteer to work for the organization while putting at legal risk their personal equities. However their referred section of PIN 2013-01 completely takes away their in-kind investment in the organization they have invested their time and effort. Such is the same case with the volunteers, who have also invested valuable time in the funded CBO organization. Again programs do not occur in a vacuum.
The corporate identity becomes diluted when PIN 2013-01 exert full control over Non-Grant funds. However, HRSA continues to hold the granted corporations fully accountable for the management of the organization and the implementation of strategic plans. This is particularly risky and dangerous in times of profound recession and when foreseen long term financial plans have been extremely difficult, even for the federal government itself. By taking away from CBO’s the discretionary use of non-grant funds the power of business opportunities is flattened and redirected into the bureaucracy of the government.
Moreover, PIN 2013-01 leaves in the air the inherent interest that other federal funding sources, foundations and private contributors may be entitled to. That including the interest acquired by the organization’s own equity.
Aforementioned issues bring up the question of whether the rights earned by CBO’s regarding their ownership of capital assets are being swept away by PIN 2013-01 and if such act may constitute to be violation of property rights. Thus, because of the high level of disagreement, which coincides with colleagues across the nation as well as with the opinion of experts, we strongly suggest that HRSA:
1. Given the highly questionable issues arising from PIN 2013-01, an extended period of time should be granted as to further consider a reasonable and fair solution.
2. That HRSA’s inherence over non-grant funds be on the basis of their prorated participation in the federally funded program while CBOs will exert full control over their share by prorating their equity in the program as well as that of other sources.
It is our best interest that our comments may well serve you to make a reasonable and fair decision on behalf of the fine legacy of community members across America’s primary healthcare centers.
Cordially yours,
Allan Cintron-Salichs, MBA, MHCM
Executive Director