You will probably recall that Powers asked the HRSA HIV/HIV/AIDS Bureau (HAB) for guidance recently on whether Ryan White program income may be used to purchase mobile vans to be used for screening and treatment. Heather Hauck, Deputy Associate Administrator of HAB responded that Ryan White program income may be used to purchase mobile vans, without prior approval, as long as the use of the van is consistent with the RWHAP. Here is what Heather said:
A van purchased for the purpose of providing mobile testing or other RWHAP-related services constitutes “equipment” under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards (UAR), 45 CFR 75.2, 75.320. Under the UAR, prior approval is required for the purchase of equipment using grant funds. 45 CFR 75.407(a)(7), 75.439. When program income funds are used rather than grant funds, prior approval is not required. However, as with the use of RWHAP funds for equipment purchases, if funds generated from the RWHAP award are made to make this purchase, the equipment may not be utilized for any purposes not related to the RWHAP, and the UAR provisions including title, use, management and disposition of the equipment apply.
This advice is consistent with some broader advice on uses of program income that we had received previously from Heather, and what we anticipated, but we are pleased with this clarification. Heather also confirmed that HAB does not intend to cancel any Part C grants due to excess program income, which is also consistent with prior HRSA statements.