Advance Interoperable Health Information Technology Services to Support Health Information Exchange Program

Grantees in this program will leverage the investments and lessons learned from the previous State HIE Program to advance the standardized, secure, and interoperable movement of health information across organizational, vendor, and geographic boundaries. Through the expansion and use of operational health information exchange infrastructure, grantees will seek to address workflow challenges and technical issues and improve the meaningful use of clinical data from external sources across the entire care continuum by:

• Expanding the adoption of health information exchange technology, tools, services, and policies that enable interoperable exchange
• Facilitating and enabling send, receive, find, and use capabilities to access health information from external sources and incorporate into care provider workflows
• Increase integration of health information in interoperable health IT to support care processes and decision making

The awards will fund efforts to provide training, education, technical assistance, and workflow redesign support to assist eligible and non-eligible caregivers and individuals with incorporating health information exchange into their existing day-day workflows to improve care coordination, population management, and measurement reporting. Grantees will use interstate and intrastate partnerships to enable clinical and non-clinical caregivers across the entire continuum to send, receive, find, and use a common clinical data set across unaffiliated organizations, with the goal of improving care coordination and transitions of care. In addition, this program will promote the use of health information exchange through interoperable health IT to move towards a robust learning health system where data may be leveraged securely and effectively.

The Advance Interoperable Health Information Technology Services to Support Health Information Exchange FOA was a full and open competition that has allocated $29,678,441.00 to fund twelve (12) awards in the form of cooperative agreements for states, territories, or state designated entities to provide technical assistance services to both eligible and non-eligible Target Populations for a period of performance of two (2) years. This program utilizes categories of eligibility as defined in the EHR Incentive programs to identify, in part, providers and hospitals with which grantees will work. Grantees were required to select at least one (1) eligible care provider and at least two (2) non-eligible care providers for their target population from the list below in order to meet the funding requirements.

Eligible Care Providers	Non-Eligible Care Providers	Other care providers and settings across the entire care continuum
Eligible Professionals; Eligible Critical Access Hospitals	Long Term Post-Acute Care (Skilled Nursing Facilities, Home Health Agencies, Rehabilitation Facilities), Behavioral Health, Individual	Emergency Medical Services; Poison Control Centers; Pharmacy; Social Services; Public Health; Public Health Disaster Response Providers; Researchers

View the HIE FOA [PDF - 1.6 MB]

Updated on April 6, 2015

1. Q: My organization is in the process of submitting an Indirect Cost Rate Agreement to the Department of Labor, and I wanted to ask if there are any suggestions as to how we should derive a sample rate in order to write the narrative? Do organizations use a certain indirect cost rate prior to having an approved one of their own?

   A: In the event that an organization does not have an approved indirect cost rate agreement, and this is the first time applying for one, 2 CFR 200.414(f) states the following:

   (f) In addition to the procedures outlined in the appendices in paragraph (e) of this section, any non-Federal entity that has never received a negotiated indirect cost rate, except for those non-Federal entities described in Appendix VII to Part 200—States and Local Government and Indian Tribe Indirect Cost Proposals, paragraph D.1.b, may elect to charge a de minimis rate of 10% of modified total direct costs (MTDC) which may be used indefinitely. As described in §200.403 “Factors affecting allow ability of costs”, costs must be consistently charged as either indirect or direct costs but may not be double charged or inconsistently charged as both. If chosen, this methodology once elected must be used consistently for all Federal awards until such time as a non-Federal entity chooses to negotiate for a rate, which the non-Federal entity may apply to do at any time.

2. Q: If I have any difficulty submitting my application today is there a phone number and email address of someone I could contact? Are they available after hours?

   A: Applications for all Funding Opportunity Announcements must be submitted electronically through http://www.grants.gov by 11:59pm Eastern Time today, April 6, 2015. If you have any difficulty submitting your application, please remember to contact the Grants.gov Contact Center 24 hours a day, 7 days a week at #1-800-518-4726 (local toll free). For International callers, please call #606-545-5035 to speak with a Contact Center representative. You may also reach a Contact Center representative via email at support@grants.gov.

   For additional information, please also see the Top 10 requested help topics (FAQs) located here on the iPortal.

Updated on March 30, 2015

1. Q: Can all the 3:1 match be in-kind or is there a % minimum of cash (non-Federal Cash) & in-kind (non-Federal in-kind)?

   A: Yes, in-kind contributions can be used to fulfill your match requirement; however we strongly advise that detailed information and supporting documentation is provided to show how the match was met from these entities contributing to your match requirement.

Updated on March 20, 2015

1. Q: Are we absolutely required to use the Data Sharing for Privacy (DS4P) method if we choose Behavioral Health as one of our non-eligible provider categories? This method of segmenting data will not work in our state due to state laws governing the HIE.

   A: No. As stated in the FOA, Section C. Scope of Services, grantees will support the use of health IT to integrate behavioral health information into primary care settings so that primary care physicians may holistically understand and more effectively coordinate patient care. ONC is particularly interested in solutions to electronically obtain an individual’s consent to disclose mental health or substance abuse information per 42 CFR Part 2, and the technical specifications for persisting an individual’s choice in sharing such information. Applicants should clearly describe existing technology that has been certified to, or supports standards and implementation specifications that provide specific functions supporting interoperability using national standards such as the ONC HIT CEHRT Program or Data Segmentation for Privacy, (DS4P). This includes, but is not limited to, transitions of care, clinical information reconciliation, and privacy and security, [“DS4P”]. Please refer to the table in Appendix F for example certification criteria that support interoperability, and p. 28/Section V. Application Review Information/Subsection C. Applicant Capabilities for more information.

Updated on March 11, 2015

1. Q: Further describe the matching Federal dollars to award dollars

   A: Total federal funding available under this FOA is approximately $28,000,000. Under this program, the applicant’s match requirement is $1 for every $3 Federal dollars. In other words, for every three (3) dollars received in Federal funding, the applicant must contribute at least one (1) dollar in non-Federal resources toward the project’s total cost. For example, if $100,000 in federal funds is requested for the period of performance, then the minimum match requirement is $100,000/3 or $33,333. In this example the program’s total cost would be $133,333. There are two types of match: 1) non-federal cash and 2) non-federal in-kind. In general, costs borne by the applicant and cash contributions of any and all third parties involved in the project, including sub-grantees, contractors and consultants, are considered matching funds. Generally, most contributions from sub-contractors or sub-grantees (third parties) will be non-federal in-kind matching funds. Volunteered time and use of facilities to hold meetings or conduct project activities may be considered in-kind (third party) donations. Examples of non-federal cash match include budgetary funds provided from the applicant agency’s budget for costs associated with the project.

2. Q: How have you planned or are planning to coordinate these activities with the PTN/SAN grantees?

   A: This FOA is intended to facilitate health information exchange and synergies in support of other federal, state, and/or community health reform efforts. Work performed under the Practice Transformation Network and the Support and Alignment Network and this FOA must remain under completely separate funding streams, and you may not draw down funding for duplicative work or duplicative efforts.

3. Q: So as I understand it, for-profit organizations are not eligible. Am I correct in my understanding?

   A: Eligible applicants will be States, (including territories) or their non-profit SDE’s who may apply as designated by the State. Either a state or a SDE may apply for cooperative agreements under this program. Multi-state or regional partnership efforts may apply; however one state or SDE must act as the primary grantee. States may also designate entities other than previous SDEs that were identified during the previous State HIE program. Any entity applying for a cooperative agreement must be either (1) a component of state government or (2) a not-for-profit entity, and be designated by the state through a letter from the Governor. For additional information please see the FOA Section III. Eligibility Information Part (A). Eligible Applicants on Grants.gov and the Frequently Asked Questions (FAQs) #7 and #19 located on HealthIt.gov.

4. Q: Is there a budget cap for applicants with 1 SDE or with more than 1 SDE?

   A: No. There is not a cap; however the budget must be reasonable, necessary, allowable, and allocable.

5. Q: Is there an expectation that for each target population and intervention identified in the grant proposal that we will have "adopt, exchange, and interoperability" milestones for each target population and each intervention?

   A: Grantees will (1) increase adoption of health information exchange technology, tools, and services; (2) increase the movement of electronic, secure, and standardized patient health information to improve care transitions, and; (3) increase the interoperability of health information exchange from external data sources used by individuals and care providers from unaffiliated organizations. Payments will be directly tied to these three milestones and they need not be sequential; however grantees must establish a current baseline and set a target goal for each milestone. For example, an applicant may have robust adoption across the EP population, and therefore elects to focus primarily on advancing exchange and interoperability to enable more effective care transitions. This applicant may elect to only focus on the exchange and interoperability milestones due to successful adoption efforts. Once awarded, the grantee will work with ONC to establish an appropriate process for validating each core programmatic milestone achievement.

6. Q: The FOA speaks clearly to education and technical assistance as eligible activities under the grant, but does not speak to whether technology design, development, or operations are eligible expenses. Can you please clarify whether technology design, development, or operations are eligible under the HIE program?

   A: Through the expansion and use of existing operational health information exchange infrastructure, grantees will seek to address workflow challenges and technical issues and improve the meaningful use of clinical data from external sources in accordance with the milestones outlined in the FOA. Applicants must describe in detail current adoption baselines and the supporting exchange infrastructure, approaches, and processes that exist to meet programmatic goals. Applicants must also clearly describe in detail the necessary changes, updates, or modifications to existing, operational exchange infrastructure and the proposed project plan, timeline, and costs required to ensure the ability of patient information to securely move between interoperable health information technology tools and services. Applicants must clearly describe how they will use this infrastructure to work with target provider groups to digest relevant information in order to achieve the milestones and programmatic goals of the program.

7. Q: Does an organization already have to have its state designation in order to submit the letter of intent?

   A: No. At the time of application submission, eligible applicants will be States, (including territories) or their non-profit SDE’s who may apply as designated by the State. Either a state or a SDE may apply for cooperative agreements under this program. Multi-state or regional partnership efforts may apply; however one state or SDE must act as the primary grantee. States may also designate entities other than previous SDEs that were identified during the previous State HIE program. Any entity applying for a cooperative agreement must be either (1) a component of state government or (2) a not-for-profit entity, and be designated by the state through a letter from the Governor.

8. Q: Is funding proportional to the targeted state or region (in multi-state applications) geography or population?

   A: Each applicant will identify their current adoption and exchange participation baseline by transport mechanism where applicable, and set a goal for the net new number of participants across the selected care provider groups that they will support during the program. Proposals will be evaluated based on the % increase in the number of clinical and non-clinical providers or individuals that will be supported across various care settings based on this baseline. As part of the application review process, reviewers will need to examine how ambitious and realistic your targets are. If your targets are too modest, you are at risk of not receiving the grant. If your targets are too ambitious, you are at risk of not getting paid during the period of performance. Please keep in mind that applications will also be weighted as follows: 20% for the Adoption of Health Information Exchange Technology or Services; 30% for Exchange and the demonstration of send, receive, find, and use of a common clinical data set that aligns with national content and format standards; and 35% for interoperability and integration of data from external sources.

9. Q: If two states plan to partner, must the Governor of each state recognize the intent to collaborate?

   A: Multi-state or regional partnership efforts may apply; however one state or SDE must act as the primary grantee or primary fiscal agent. Also, for multi-state applications, a letter from the Governor (or equivalent), designating the partnering state or SDE, must be received on behalf of each state participating in the proposed project.

10. Q: Is there a minimum number (target) for each milestone?

    A: Each applicant will identify their current adoption and exchange participation baseline by transport mechanism where applicable, and set a goal for the net new number of participants across the selected care provider groups that they will support during the program. Proposals will be evaluated based on the % increase in the number of clinical and non-clinical providers or individuals that will be supported across various care settings based on this baseline. As part of the application review process, reviewers will need to examine how ambitious and realistic your targets are. If your targets are too modest, you are at risk of not receiving the grant. If your targets are too ambitious, you are at risk of not getting paid during the period of performance. Please keep in mind that applications will also be weighted as follows: 20% for the Adoption of Health Information Exchange Technology or Services; 30% for Exchange and the demonstration of send, receive, find, and use of a common clinical data set that aligns with national content and format standards; and 35% for interoperability and integration of data from external sources.

11. Q: Please indicate whether support for the development of a HIE-hosted EHR solution would be eligible for funding under the HIE program, for example for use by non MU-eligible providers such as Long-term post-acute care providers.

    A: Applicants must describe in detail current adoption baselines and the supporting exchange infrastructure, approaches, and processes that exist to meet programmatic goals. Applicants must also clearly describe in detail the necessary changes, updates, or modifications to existing, operational exchange infrastructure and the proposed project plan, timeline, and costs required to ensure the ability of patient information to securely move between interoperable health information technology tools and services. Where applicable, applicants are encouraged to consider the adoption of open source or low-cost tools and solutions that could support the exchange of interoperable health information for non MU-eligible providers and those without EHRs. A description should be provided regarding plans to integrate these tools and solutions into existing infrastructure and the proposed timeline to enable use by target provider groups in order to meet the milestones and programmatic goals of this FOA.

12. Q: If an organization fails to submit a letter of intent, can they submit an application?

    A: Yes. The notice of intent was not a prerequisite for submitting a full proposal. Applicants were strongly encouraged to submit a non-binding e-mail notice of intent to apply for this funding opportunity to assist ONC in planning for the application review process by 11:59 P.M. Eastern Time March 2, 2015; however this does not preclude you from applying for the funding opportunity by April 6th.

13. Q: Can the SDE or entity approved by the Governor be a prime with most of the effort and costs going to subcontractors? Does the PD/PI need to be from the Prime or can it be from the Subcontractor?

    A: Applicants are encouraged, but not required, to enter into multi-state agreements or engage in regional partnerships; however one state or SDE must act as the primary grantee and responsible fiscal agent and submit the application on behalf of all the partners. Per the HHS Grants Policy Statement located here http://www.hhs.gov/asfr/ogapa/aboutog/hhsgps107.pdf the prime recipient or awardee must enter into a formal written agreement with each sub-recipient that addresses the arrangements for meeting the programmatic, administrative, financial, and reporting requirements of the grant, including those necessary to ensure compliance with all applicable Federal regulations and policies.

14. Q: Is there a restriction on the amount of funding that can be allocated to contracts and/or IT?

    A: There is not a restriction so long as the cost is reasonable to the project, allowable, allocable, and necessary.

15. Q: What type of certification do you need in order to prove that the applicant or subcontractors are free from COI?

    A: In accordance with 2 CFR 200.112 all applicants and Non-federal entities must disclose in writing any potential conflict of interest (COI) that they have with the HHS awarding agency and/or any other pass-through entities. The applicant must notify the HHS awarding agency and its respective grants management officer (GMO) when they believe a COI may exist. If after award, an awarded grantee discovers a COI, with respect to this cooperative agreement, it must make an immediate and full disclosure in writing to the grants management officer. The disclosure must include identification of the conflict, the manner in which it arose, and a description of the action the grantee has taken, or proposed to take, to avoid, eliminate, or neutralize the conflict. In the event the grantee was aware of an organizational COI prior to award of the award of the cooperative agreement and did not disclose the conflict to the GMO or becomes aware of an organizational COI after award of this cooperative agreement and does not disclose the COI within ten (10) days of becoming aware of such conflict, the Government may terminate the cooperative agreement and the grantee will not be entitled to reimbursement of any cost incurred in performing the cooperative agreement or payment of any fee there under. The rights and remedies of the Government provided in this clause must not be exclusive and are in addition to any other rights and remedies of the Government provided by law or under this cooperative agreement

16. Q: Can costs for infrastructure updates be included in Milestone #3 – Interoperability of data systems?

    A: Milestone 3 will address the need for electronic health information from outside care providers and individuals to be integrated and incorporated into health IT systems for population management, measurement reporting, and improvements in clinical care. Through the expansion and use of existing operational health information exchange infrastructure, grantees will seek to address workflow challenges and technical issues and improve the meaningful use of clinical data from external sources in accordance with the milestones outlined in the FOA. Applicants must describe in detail current adoption baselines and the supporting exchange infrastructure, approaches, and processes that exist to meet programmatic goals. Applicants must also clearly describe in detail the necessary changes, updates, or modifications to existing, operational exchange infrastructure and the proposed project plan, timeline, and costs required to ensure the ability of patient information to securely move between interoperable health information technology tools and services. Applicants must clearly describe how they will use this infrastructure to work with target provider groups to digest relevant information in order to achieve the milestones and programmatic goals of the program.

17. Q: As this is a deliverable based cooperative agreement, what is the process/timeframe for reimbursement based on the deliverables being met?

    A: While this is a cost-based reimbursable award, it is important to note, that progress must be made towards achieving the milestone as outlined in your approved budget and project narrative/work plan. Funding will be released pursuant to milestones established by each award.

18. Q: Can Balancing Incentive Program dollars be used for the match?

    A: All funding and funding streams under this announcement will be to support health information exchange and is not intended to support the IT infrastructure and structural reforms needed to meet the requirements of the Balancing Incentive Program. Work performed under the Balancing Incentive Program and this FOA must remain under two separate funding streams, and you may not draw down funding for duplicative work or duplicative efforts. You also may not draw down funding or match funding from one federal project to another.

19. Q: If two states with contiguous geographical borders intend to collaborate on a portion of the scope of work impacting the populations served by their respective health care providers, may each state submit an application for funding? Neither state intends to be the lead on the collaborated work, but each will benefit from the expansion of health information technology, tools and services adoption.

    A: Please note that while applicants are encouraged to enter into multi-state agreements or engage in regional partnerships, each award will be made for a specific target population in a defined geographic area, where the proposed target population does not overlap, or otherwise duplicate, any other award under this FOA.

20. Q: What is the expected ratio of interstate and intrastate funding?

    A: This FOA provides funding to states through two separate funding streams (interstate and intrastate). The associated cost for each program activity will have to be documented as interstate, or across state borders between unaffiliated organizations, and for the earmark, as intrastate, or within state borders. Post-award, the ONC Office of Programs and Engagement will provide guidance around the types of activities that will align with each funding source. It is the grantees responsibility to determine and appropriately document expenditures and provide justification of how and why they have utilized allocated Intrastate and/or Interstate funds.

21. Q: The Administration for Community Living sent out an email announcing this FOA yesterday which indicated the following: "This FOA offers community-based aging and disability organizations an important opportunity to participate in health information exchange activities in their state." Is there a particular focus on aging and disability organizations or any other type of partnerships for this FOA?

    A: This FOA is intended to engage both clinical and non-clinical care providers. For the purposes of this FOA, however, the general term “care providers” is broadly inclusive of the entire care continuum, reflecting primary care providers, specialists, nurses, pharmacists, physical therapists and other allied care providers, hospitals, mental health and substance abuse services, long- term and post-acute care facilities, home and community-based services, other support service providers, care managers, care support services, social service case workers, emergency medical services, and other authorized individuals and institutions. Applicants focusing on the Long-Term and Post-Acute Care (LTPAC) population must demonstrate proposed or existing infrastructure to work with long-term and post-acute care providers, nursing facilities, skilled nursing facilities, inpatient rehabilitation, long term acute care hospitals, hospice, and home health agencies.

22. Q: Does the $28M budget reflect what ONC is funding, or is it including the match required?

    A: The $28M being awarded reflects what ONC is funding, and does not include the match required.

23. Q: May a vendor pay the matching portion?

    A: There are two types of match: 1) non-federal cash and 2) non-federal in-kind. In-kind services may be counted as match from vendors, but not actual dollars. In general, costs borne by the applicant and cash contributions of any and all third parties involved in the project, including sub-grantees, contractors and consultants, are considered matching funds. Generally, most contributions from sub-contractors or sub-grantees (third parties) will be non-federal in-kind matching funds. Volunteered time and use of facilities to hold meetings or conduct project activities may be considered in-kind (third party) donations. Examples of non-federal cash match include budgetary funds provided from the applicant agency’s budget for costs associated with the project.

24. Q: Are public health transactions (e.g., ELR reporting to public health) considered eligible and within the scope of this FOA?

    A: Some examples of transmission of data to public health include, but are not limited to: (1) aggregate clinical data across providers to provide population level information to public health; (2) create bi-directional data sharing between public health and providers; and (3) streamline and simplify meaningful use submissions of immunizations, syndromic surveillance, electronic labs, and other registry data to public health agencies.

25. Q: Can a state HIE submit an application as an individual HIE and be part of a multi-state proposal?

    A: Yes, eligible applicants will be States, (including territories) or their non-profit SDE’s who may apply as designated by the State. Either a state or a SDE may apply for cooperative agreements under this program. Multi-state or regional partnership efforts may apply; however one state or SDE must act as the primary grantee. While applicants are encouraged to enter into multi-state agreements or engage in regional partnerships, ONC does not anticipate awarding any HIE cooperative agreement for a geographic service area that overlaps with another HIE cooperative agreement. Each award will be made for a defined geographic area that does not overlap or otherwise duplicate any other award under this FOA. Any entity applying for a cooperative agreement must be either (1) a component of state government or (2) a not-for-profit entity, and be designated by the state through a letter from the Governor.

26. Q: With regard to the requirement to include two non-eligible care providers, could we concentrate on several providers, all of the same type (e.g., two LTPAC providers)?

    A: Grantees must select at least one (1) eligible care provider and at least two (2) non-eligible care providers for their target population from the following categories in order to meet the funding requirements. Eligible care Providers category is Eligible Professionals (EPs) (as defined by the EHR Incentive Programs) or Critical Access Hospital (CAHs) (as defined by the EHR Incentive Programs). Non-eligible care provider’s category is Long-Term and Post-Acute Care (LTPAC), Behavioral Health (BH), Individuals, and/or Other care settings and care providers (e.g. safety net providers, public health, social services, and emergency medical services). This provides flexibility for grantees to work with other clinical and non-clinical care providers across the entire care continuum.

27. Q: Please define what you mean by the "entire" continuum of care.

    A: This FOA is intended to provide flexibility for grantees to engage both clinical and non-clinical care providers across the entire continuum. For the purposes of this FOA, the general term “care providers” is broadly inclusive of the entire care continuum, reflecting primary care providers, specialists, nurses, pharmacists, physical therapists and other allied care providers, hospitals, mental health and substance abuse services, long- term and post-acute care facilities, home and community-based services, other support service providers, care managers, care support services, social service case workers, emergency medical services, and other authorized individuals and institutions.

28. Q: Can program income can be used as match for this funding opportunity?

    A: Yes, program income can be used as match for this funding opportunity. Per 2 CFR 200.307(3) Cost sharing or matching. With prior approval of the Federal awarding agency, program income may be used to meet the cost sharing or matching requirement of the Federal award. The amount of the Federal award remains the same.

29. Q: Can the matching be in-kind? Or has to be hard cash?

    A: There are two types of match: 1) non-federal cash and 2) non-federal in-kind. In general, costs borne by the applicant and cash contributions of any and all third parties involved in the project, including sub-grantees, contractors and consultants, are considered matching funds. Generally, most contributions from sub-contractors or sub-grantees (third parties) will be non-federal in-kind matching funds. Volunteered time and use of facilities to hold meetings or conduct project activities may be considered in-kind (third party) donations. Examples of non-federal cash match include budgetary funds provided from the applicant agency’s budget for costs associated with the project.

30. Q: Can you provide more guidance around project income? For example, if an entity has already/or will start charging a yearly fee to providers, but proposes to include those providers in the services, how is that income handled? The fees would not be a result of this cooperative agreement, but past work.

    A: If this is being done as past work not associated with this new funding opportunity, then it would not be considered program income. However if this is a result of services provided by this funding opportunity, it would. If this funding opportunity is responsible for a portion of services, then only that portion would be considered program income. Please refer to 2 CFR Part 200.80 and 2 CFR Part 200.307.

31. Q: Under the HIE Cooperative Agreement Program, we submitted documentation for qualified match that exceeded the requirements. Could this match be applied to an award under this new FOA?

    A: Match from a previous award may not be applied to a new award.

32. Q: We would like your assistance in distinguishing between what is considered a consultant, contractor, sub-award, vendor, etc., and which line item of the Budget documents these anticipated costs should be entered.

    A: 2 CFR 200.330 states the following regarding subrecipient and contractor determinations:
    The non-Federal entity may concurrently receive Federal awards as a recipient, a subrecipient, and a contractor, depending on the substance of its agreements with Federal awarding agencies and pass-through entities. Therefore, a pass-through entity must make case-by-case determinations whether each agreement it makes for the disbursement of Federal program funds casts the party receiving the funds in the role of a subrecipient or a contractor. The Federal awarding agency may supply and require recipients to comply with additional guidance to support these determinations provided such guidance does not conflict with this section.

    (a) Subrecipients. A subaward is for the purpose of carrying out a portion of a Federal award and creates a Federal assistance relationship with the subrecipient. See §200.92 Subaward. Characteristics which support the classification of the non-Federal entity as a subrecipient include when the non-Federal entity:
    (1) Determines who is eligible to receive what Federal assistance;
    (2) Has its performance measured in relation to whether objectives of a Federal program were met;
    (3) Has responsibility for programmatic decision making;
    (4) Is responsible for adherence to applicable Federal program requirements specified in the Federal award; and
    (5) In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity.

    (b) Contractors. A contract is for the purpose of obtaining goods and services for the non-Federal entity's own use and creates a procurement relationship with the contractor. See §200.22 Contract. Characteristics indicative of a procurement relationship between the non-Federal entity and a contractor are when the non-Federal entity receiving the Federal funds:
    (1) Provides the goods and services within normal business operations;
    (2) Provides similar goods or services to many different purchasers;
    (3) Normally operates in a competitive environment;
    (4) Provides goods or services that are ancillary to the operation of the Federal program; and
    (5) Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons.

    (c) Use of judgment in making determination. In determining whether an agreement between a pass-through entity and another non-Federal entity casts the latter as a subrecipient or a contractor, the substance of the relationship is more important than the form of the agreement. All of the characteristics listed above may not be present in all cases, and the pass-through entity must use judgment in classifying each agreement as a subaward or a procurement contract.

Updated on February 24, 2015

1. Q: Could you clarify if county or state correctional facilities and/or jails are considered as part of the Other Settings and Care Providers section described on page 13 of the FOA?

   A: The "other providers and care settings" section is intended to provide flexibility for grantees to work with other clinical and non-clinical care providers and settings across the care continuum to support a more comprehensive, integrated patient record or care plan and facilitate the sharing of clinical and administrative health information. Please justify in your proposal how working with county or state correctional facilities and/or jails to provide technical assistance support will facilitate exchange to improve care coordination and support the sharing of essential health information such as clinical summaries, care plans, or medication lists with the entire care team.

2. Q: Are commercial and or Medicaid managed care health plans considered as part of the Other Settings and Care providers on page 13 of the FOA?

   A: The “other providers and care settings” section is intended to provide flexibility for grantees to work with other clinical and non-clinical care providers across the care continuum to support a more comprehensive, integrated patient record or care plan and facilitate the sharing of clinical and administrative health information. Please justify in your proposal how working with commercial and/or Medicaid managed care health plans and providing technical assistance support will facilitate exchange to improve care coordination and support the sharing of essential health information such as clinical summaries, care plans, or medication lists with the entire care team.

Updated in February 2015

1. Q: What is the title of the new Funding Opportunity Announcement (FOA)?

   A: The new Funding Opportunity Announcement is entitled: Advance Interoperable Health Information Technology Services to Support Health Information Exchange.

2. Q: What Federal Agency is releasing this FOA?

   A: Office of the National Coordinator for Health Information Technology (ONC), within the U.S. Department of Health and Human Services (DHHS or HHS), is the Federal Agency releasing the Funding Opportunity Announcement (FOA) titled, Advancing Interoperable Health Information Technology Services to Support Health Information Exchange.

3. Q: Under what authority is HHS releasing this program Funding Opportunity Announcement?

   A: The U.S. Department of Health and Human Services (DHHS or HHS) is releasing this FOA under the statutory authority of the American Recovery and Reinvestment Act of 2009 (ARRA or Recovery Act), Subtitle B—Incentives for the Use of Health Information Technology, Section 3013, State Grants to Promote Health Information Technology.

4. Q: When is the Notice of Intent to Apply Due?

   A: The Notice of Intent to Apply is due March 2nd 2015.

5. Q: When are applications due for this FOA?

   A: Applications are due April 6, 2015.

6. Q: When will award announcements be made?

   A: ONC anticipates making award announcements on June 12, 2015.

7. Q: How many new awards will be made under this FOA?

   A: This FOA will be a full and open competition. Ten (10) to twelve (12) new awards will be made in the form of two year cooperative agreements to states1, territories, or state designated entities (SDE)2.

8. Q: When is the anticipated project start date?

   A: The anticipated cooperative agreement program start date is June 12, 2015.

9. Q: What is the funding source of this FOA?

   A: This FOA uses funds remaining from the original State HIE Program which allocated $564,000,000 to support cooperative agreements to advance appropriate and secure HIEs across the healthcare system. This new opportunity announcement will be funded by a portion of the remaining amount. Total funding available under this FOA is $28,000,000.

10. Q: Who is the target population for this FOA?

    A: This project is utilizing categories of eligibility defined in the EHR Incentive programs to identify, in part, providers and hospitals with which grantees will work. For the purposes of this FOA, however, the general term “care providers” is broadly inclusive of the care continuum, reflecting primary care providers, specialists, nurses, pharmacists, physical therapists and other allied care providers, hospitals, mental health and substance abuse services, long- term and post-acute care facilities, home and community-based services, other support service providers, care managers, and other authorized individuals and institutions. Grantees must select at least one (1) eligible care provider and at least two (2) non eligible care providers for their target population from the list detailed in the FOA in order to meet the funding requirements.

11. Q: RAND recently issued a review of the usage and effect of health information organizations and found that the "principal findings of this systematic review are that the number of specific HIEs that have been evaluated for evidence of effects on quality, costs, efficiency, usage, and sustainability is few relative to the number of HIEs overall." How can you spend $28 million more for such a program?

    A: We encourage all to read RAND’s systematic review which concludes that there are simply not enough evaluation studies examining the usage and downstream effects of HIE to clearly identify “what does and does not work and in what context.” This FOA will continue to address this question under the same legislative intent. The primary focus of this new program is technical assistance provision to clinical and non-clinical care providers3 and individuals to increase the adoption and use of interoperable health IT tools and services to support health information exchange, improve care coordination, and enable send, receive, find, and use of a common clinical data set. This is an opportunity to address gaps, challenges, and scale promising practices and lessons learned from the last program. Ongoing evaluation information and updates on the previous State HIE program can be found on Healthit.gov.

12. Q: Do you expect that any of the previous State HIE grantees will apply for the new HIE grant?

    A: Yes. This FOA will be a full and open competition with ten (10) to twelve (12) new awards being made in the form of cooperative agreements to states, territories and/or state designated entities. It will not be limited to previous ONC grantees. Applicants are encouraged, but not required, to enter into multi-state agreements or engage in regional partnerships.

13. Q: How will the new HIE FOA differ from the previous one?

    A: While this FOA will continue under the same legislative intent, the primary focus will be technical assistance provision to clinical and non-clinical care providers and individuals to increase the adoption and use of interoperable health IT tools and services to support health information exchange, improve care coordination, and enable send, receive, find, and use of a common clinical data set.

14. Q: May states, territories, or SDEs accept the awards and pass them along to sub recipients?

    A: Applicants are encouraged, but not required, to enter into multi-state agreements or engage in regional partnerships; however one state or SDE must act as the responsible fiscal agent. Per the HHS Grants Policy Statement4, the prime recipient or awardee must enter into a formal written agreement with each sub-recipient that addresses the arrangements for meeting the programmatic, administrative, financial, and reporting requirements of the grant, including those necessary to ensure compliance with all applicable Federal regulations and policies.

15. Q: What is essential health information?

    A: The basic set of essential health information that builds from the common meaningful use (MU) data set incorporated into ONC’s health IT certification program as part of the 2014 Edition EHR Certification Criteria and currently used to support three MU objectives included in the Medicare and Medicaid EHR Incentive Programs. Ensuring that individuals and care providers send, receive, find, and use a basic set of essential health information across the health care continuum will enhance care coordination and enable health system reform to improve care quality.5

16. Q: How should we address the Learning Health System?

    A: Applicants will be required to clearly outline how their best practices and successes will be disseminated via informal learning networks, participation in communities of practices, or learning health collaboratives to spread learning across like organizations and other states/regions. This funding announcement will promote movement towards a robust learning health system where data may be leveraged securely and effectively to improve care coordination. Our ultimate goal is to have a learning health system where accurate and evidence-based information helps ensure the right individual receives the right care at the right time to increase health care quality, lower health care costs and improve population health.6

17. Q: Will we have to document interstate and intrastate funding for this award?

    A: Yes. The associated cost for each program activity will have to be documented as interstate, or across state borders between unaffiliated organizations, and for the earmark, as intrastate, or within state borders. Post-award, the ONC Office of Programs and Engagement will provide guidance around the types of activities that will align with each funding source.

18. Q: Can previous SDE’s be awarded or do states have to designate new SDE’s?

    A: This FOA will be a full and open competition with ten (10) to twelve (12) new awards being made in the form of cooperative agreements to states, territories and/or state designated entities. It will not be limited to previous SDE’s or ONC grantees; nor are former grantees prohibited from applying. Applicants are encouraged, but not required, to enter into multi-state agreements or engage in regional partnerships.

19. Q: What types of letters of support are required for application submission?

    A: A letter from the Governor designating the state or state designated entity (SDE) is required. For multi-state applications, a letter from the Governor (or equivalent) designating the partnering state or SDE must be received on behalf of each state participating in the proposed project. As applicable, applicants will submit a letter from the State HIT Coordinator (or equivalent) indicating plans to partner with the grantee and support the achievement of the programmatic goals of this FOA, while driving alignment across other federally funded HIT programs. Applicants must also submit letters of support from critical stakeholders, vendors, or other supporting entities who support efforts of applicant to achieve programmatic goals of this FOA. Where applicable, applicants will provide a letter of support from entities that will be responsible for generating reports based on transactional data (e.g. health information service providers, technology vendors, or others).

20. Q: How many cooperative agreements will be awarded per state?

    A: Each state or territory will receive a maximum of one (1) cooperative agreement; however states are encouraged to enter into state and regional partnerships.

21. Q: What is the email address for applicants to send letters of intent and questions about the HIE FOA?

    A: HealthInformationExchangeFOA@hhs.gov.

22. Q: How will our submitted baselines and targets be evaluated? Will we be rewarded for ambitious targets?

    A: Proposals will be evaluated based on the % increase in the number of clinical and non-clinical providers or individuals that will be supported across various care settings based on this baseline. As part of the application review process, reviewers will need to examine how ambitious and realistic your targets are. If your targets are too modest, you are at risk of not receiving the grant. If your targets are too ambitious, you are at risk of not getting paid during the period of performance. Please keep in mind that applications will also be weighted as follows: 20% for the Adoption of Health Information Exchange Technology or Services; 30% for Exchange and the demonstration of send, receive, find, and use of a common clinical data set that aligns with national content and format standards; and 35% for interoperability and integration of data from external sources.

23. Q: How should we demonstrate credible and reliable baseline information of our provider population?

    A: Applicants should clearly outline the data sources that will be used to establish credible baselines and why these data sources are to be trusted as reliable to establish achievement goals. Applicants must cite the data source and its location (i.e., university, federal, state or local government agency, or independent non-profit organization) which collects data specific to the population being served. If you have the infrastructure in place you should have the ability to report on some basic information related to adoption and use to establish this baseline. We are only expecting baseline measures on adoption and use since you may not be able to report baseline measures on interoperability.

24. Q: Will we be paid once we have reached a milestone or will it be cost-based reimbursement as long as we are progressing to the milestone?

    A: While this is a cost-based reimbursable award, it is important to note, that progress must be made towards achieving the milestone as outlined in your approved budget and project narrative/work plan.

25. Q: How much funding will be disseminated per milestone?

    A: The awards will be distributed according to the following thresholds: 15% for initial Programmatic Support and Engagement; 20% for the Adoption of Health Information Exchange Technology or Services; 30% for Exchange and the demonstration of send, receive, find, and use of a common clinical data set that aligns with national content and format standards; and 35% for interoperability and integration of data from external sources.

26. Q: Should awardees also target those that have not adopted EHR technology?

    A: Yes. Non-eligible care providers such as long-term and post-acute care (LTPAC), behavioral health, and safety net providers continue to lag behind national trends when it comes to adoption of health information technology, especially when compared to eligible care providers. Similarly, critical access and rural hospitals (CAH/RH) continue to struggle with limited resources to adopt health information technology.

27. Q: Are open source or low-cost tools available to assist those without EHRs exchange health information with their trading partners?

    A: Where applicable, applicants are encouraged to consider the adoption of open source or low-cost tools (e.g., IMPACT SEE Tool7, BEAT – ADT Tool, Transform8, Consent2Share9) that could support the exchange of interoperable health information for those without EHRs. A description should be provided regarding plans to integrate these tools into existing infrastructure and the proposed timeline to enable use by target provider groups.

28. Q: How will we attest to milestone performance for ONC and potential auditors?

    A: For EPs and EHs you would use MU documentation, successful attestation, and reaching high performance on health information exchange and patient engagement measures. For non EPs grantees will work with ONC to determine an appropriate and agreed upon process.

29. Q: Do we receive any initial funding for support or planning and what are the criteria? What funding may we use to get up and running and what is the timing for release?

    A: Program Support and Engagement Funding will be provided that is approximately 15% of your total award. This funding may be used to meet initial programmatic needs; travel to and from ONC meetings; peer learning and collaboration efforts (i.e. participation in CoP’s); documentation of initial challenges and bright spots; tweaking existing infrastructure; establishing evaluation processes; establishing financial and programmatic reporting requirements; and developing resources to conduct initial outreach, and education, implementation. This funding will be released quarterly pursuant to milestones established by each award.

30. Q: What does ONC mean when it says that "Milestone payments will be for these three categories, adoption, exchange, interoperability, and they need not be sequential?"

    A: For example, one grantee may achieve milestone payments just for increasing adoption of technology and services that enable health information exchange for their target population. Another grantee may just focus on interoperability, since their target population may have already adopted and enabled their technology, but needs technical assistance with interoperability.

31. Q: What is the role of the state HIT Coordinator?

    A: As applicable, applicants will submit a letter from the State HIT Coordinator (or equivalent) indicating plans to partner with the grantee and support the achievement of the programmatic goals of this FOA, while driving alignment across other federally funded HIT programs. State HIT Coordinators (or equivalent) should continue to serve as partners and strategic collaborators to provide boots on the ground perspective and assistance.

32. Q: What is role of previous HITECH grantees in this FOA?

    A: Previous HITECH grantees should serve as partners and strategic collaborators to provide boots on the ground perspective given their roles as trusted advisors in their service area. New awardees should build off of lessons learned from previous HITECH grantees and maintain a collaborative relationship to further health information exchange. Illustrating this partnership will be a critical component of the evaluation.

33. Q: Why does this FOA not focus on large practices, large organizations, or large systems?

    A: It is critical that this opportunity focus on continuing to engage small practice EPs as well as Critical Access Hospitals (CAH)/Rural Hospitals (RH), and provide opportunities for them to exchange interoperable information with their non-eligible care provider counterparts. Without a specific focus on these target populations during this 2 year program, the divide of MU attainment and interoperable exchange between well-resourced hospital organizations and small practice EPs with fewer resources will continue. Similarly, critical access and rural hospitals (CAH/RH) continue to struggle with limited resources to adopt health IT technology.

34. Q: Should applicants prioritize direct or query?

    A: No. Our intent is to have an adequate spread or distribution between direct and query.

35. Q: May states designate more than one entity to apply for funding?

    A: Applicants are encouraged, but not required, to enter into multi-state agreements or engage in regional partnerships; however one state or SDE must act as the responsible fiscal agent and submit the application on behalf of all partners.

36. Q: For previous State HIE awardees, would it have to be the same agency that applied before?

    A: No. This could be a separate agency or whomever the Governor’s Office decides is best suitable.

37. Q: What constitutes as a "state" for the purposes of this program?

    A: For the purposes of the FOA, "state" shall be understood to mean any of the 50 United States, the District of Columbia, Puerto Rico, US Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands.

38. Q: Are we allowed to overlap territories with other awardees?

    A: While we encourage multistate agreements and regional partnerships, each award will be made for a defined geographic area and should not overlap or otherwise duplicate any other award under this FOA. Cooperative agreements will include terms and conditions reserving the ability of ONC to negotiate during the course of the awarded project period further modifications in the best interest of the program.

39. Q: Will all ten (10) to twelve (12) new awards to grantees be made on a rolling basis similar to the REC program or will they be made in one batch?

    A: Ten (10) to twelve (12) new awards will be made at one time.

40. Q: Is there a cost-sharing requirement associated with this announcement?

    Yes. The HITECH Act requires a match to federal monies awarded to states for the duration of the project period of performance. ONC and Congress also recognize that securing commitment and funding from other sources will strengthen a state’s sustainability plan and lead to greater success. The applicant’s match requirement is $1 for every $3 federal dollars. In other words, for every three dollars received in federal funding, the applicant must contribute at least one dollar in non-federal resources toward the program's total cost. This "three-to-one" ratio is reflected in the following formula that can be used to calculate minimum required match:

    Federal Funds Requested / 3 = Minimum Match Requirement

    For example, if $100,000 in federal funds is requested for the period of performance, then the minimum match requirement is $100,000/3 or $33,333. In this example the program's total cost would be $133,333. If the required non-federal share is not met by the grantee, ONC will disallow any unmatched federal dollars. Demonstration of this match will be shown in annual federal financial reports. In preparing the application budget, applicants should consider these cost-sharing requirements and account for a match on their best estimate of expenditures.

 

1. For the purposes of the FOA, "state" shall be understood to mean any of the 50 United States, the District of Columbia, Puerto Rico, US Virgin Islands, Guam, American Samoa, and the Northern Mariana Islands.

2. For purposes of this program, to be a qualified State-designated entity, with respect to a State, an entity shall-
"(1) be designated by the State as eligible to receive awards under this section;
"(2) Be a not-for-profit entity with broad stakeholder representation on its governing board;
"(3) Demonstrate that one of its principal goals is to use information technology to improve health care quality and efficiency through the authorized and secure electronic exchange and use of health information;
"(4) adopt nondiscrimination and conflict of interest policies that demonstrate a commitment to open, fair, and nondiscriminatory participation by stakeholders; and
"(5) conform to such other requirements as the Secretary may establish.

3. The term "care providers" is broadly inclusive of the care continuum, reflecting primary care providers, specialists, nurses, pharmacists, physical therapists and other allied care providers, hospitals, mental health and substance abuse services, long- term and post-acute care facilities, home and community-based services, other support service providers, care managers, and other authorized individuals and institutions

4. http://www.hhs.gov/asfr/ogapa/aboutog/hhsgps107.pdf

5. Connecting Health and Care for the Nation: A 10-Year Vision to Achieve an Interoperable Health IT Infrastructure

6. http://www.healthit.gov/buzz-blog/from-the-onc-desk/developing-shared-nationwide-roadmap-interoperability/

7. MeHI, "LAND and SEE architecture" web page. http://mehi.masstech.org/what-we-do/hie/impact/land-and-see

8. http://transform.keyhie.org/

9. http://www.healthit.gov/policy-researchers-implementers/consent-management

 

*Due to program nuances, ONC reserves the right to amend the language of any proposed or answered Frequently Asked Questions (FAQs), to reflect the best interest of this program.