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HRSA Service Area Competition (SAC) Grants: How to Defend Your Turf or Deftly Lift a HRSA Grant from an Unsuspecting Grantee

The Health Resources and Services Administration (HRSA) recently issued a Funding Opportunity Announcement (“FOA,” which is HRSA-speak for RFP) for the Service Area Competition (SAC) program. This program provides extremely valuable (for reasons we’ll explain in this post) five-year grants to operate one or more Federally Qualified Health Centers (FQHCs).

There are three ways to get become an FQHC, which will let an organization access Section 330 funds: (1) apply to have an existing health clinic certified as an FQHC (this is an incredibly complex process because the regulations are a nightmare); (2) wait for HRSA to issue a New Access Points (NAP) FOA and apply for a grant (this can be done in any community that meets Section 330 requirements, and it has a distinct advantage because a grant award is attached); or (3) wait for HRSA to publish a SAC FOA for your service area (which has the same advantage as number two).

The SAC route is probably the easiest because HRSA already knows that the area and residents qualify for Section 330 funds. Each time a FOA appears, existing Section 330 grantees at the end of their five-year grant period have to compete for new money against any other nonprofit or public agency that can (1) meet the eligibility test to become an FQHC and (2) chooses to apply.

This can make for mighty nervous Section 330 grantees, because running an FQHC or three can be a very lucrative undertaking for a nonprofit or public agency. As a result, even nominal collaborators can turn into cutthroat competitors and sack a grantee during a SAC funding cycle.*

Most federal programs require grantees to re-apply for continuation grants, including some (e.g., TRIO grants) that give bonus points to current grantees. Since operating a FQHC requires significant organizational infrastructure (e.g., specialized facilities and equipment, medical staff, HIPAA-compliant records management, and other features that go above and beyond basic nonprofit infrastructure), it is curious that HRSA requires current Section 330 grantees to compete for continuation funding. If a grantee is more or less getting the job done, why not just let them keep on doing what they’re doing? I assume the complicated re-application process is designed to keep the grantees on their toes. It also forces them to be accountable for the objectives stated in their original application (FQHC, NAP or SAC application), as well as the new SAC application.

HRSA Section 330 FOAs also require applicants to state highly specific objectives for required HRSA “Clinical and Financial Performance Measures,” as well for service delivery levels (e.g., number of patients, service encounters, etc.). Many applicants overstate their objectives beyond what is achievable in the real world. While we often differentiate between the Real World and the Proposal World in our approach to grant writing, sometimes the real world is important. HRSA Section 330 proposal writing is a case in point. Because the SAC application includes electronic data forms with highly specific input boxes and the metrics are so easily measured, a grantee can easily get too enthusiastic and wildly overstate the objectives that are likely to be achieved in the real world.

While being grandiose in stating objectives can be okay in many subjective human services proposals, it is a recipe for future unhappiness in HRSA Section 330 proposals. This is because failure to meet stated metrics will likely annoy your Program Officer, assuming you submit reasonably honest reports. An annoyed Program Officer is likely to torpedo your next SAC application or even cut back your current grant.

For example, a few years ago we wrote a number of funded HRSA, CDC, and foundation proposals for a Section 330 client in the midwest. While the client had no big problems in implementing several complex programs, she unfortunately got crosswise with her HRSA Program Officer over the stated objectives. Incredibly, the Program Officer got so annoyed that the client was forced into a SAC FOA three years ahead of schedule. With HRSA grants, don’t make this mistake and lose millions of dollars by overstating what your organization can do.

If your agency decides to try for the funding of an existing Section 330 grantee, it would be a good idea to request copies of their original application and reports. Just call up your competitor and ask them for these documents (note: this is joke, as no one in the real world would make this call). What you really want to do is call the HRSA Program Officer with the request and, if necessary, follow-up with a Freedom of Information Act (FOIA) request. Keep in mind that FOIA requests can take a long time, so it is best to plan your ambush well in advance.

* For more on the “collaborative” aspects of HRSA FOAs, see “Is it Collaboration or Competition that HRSA Wants in the Service Area Competition (SAC) and New Access Points (NAP) FOAs?.”

** See also The Real World and the Proposal World.

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