On October 22, HAB revised its Policy Clarification Notice (PCN) 16-02, Ryan White HIV/AIDS Program Services: Eligible Individuals & Allowable Uses of Funds, which was originally released in 2016.  PCN 16-02 describes the core medical and support services that HRSA considers allowable uses of Ryan White grant funds and the individuals eligible to receive those services.

The revised policy includes a number of substantive changes, as well as some minor rewording.  A copy of the revised PCN 16-02 is available at this link.

• HAB expanded the list of “unallowable” grant costs, although some of these restrictions are well-known.  Unallowable costs include: PrEP/nPEP; materials “designed to promote or encourage, directly, intravenous drug use or sexual activity”; international travel; the purchase or improvement of land; and the purchase, construction, or permanent improvement of any building or other facility.  (p. 4.)

 

• The revised policy states that “Core Medical Services” standards must be consistent with HHS Clinical Guidelines for the Treatment of HIV, as well as other pertinent clinical and professional standards.  (p. 5.)  On October 25, 2018, HHS released updated Guidelines for the Use of Antiretroviral Agents in Adults and Adolescents Living with HIV, available at https://aidsinfo.nih.gov/guidelines/html/1/adult-and-adolescent-arv/0 .

 

• Service standards related to Support Services may be developed using evidence-based best practices, the most recent HRSA Ryan White Parts A and B National Monitoring Standards, and guidelines developed by the state and local government.  (p. 5.)

 

• HAB revised the description of outpatient medical settings to include use of telehealth technology and urgent care facilities for HIV-related visits (in addition to clinics and medical offices).  Previously, HAB did not allow Ryan White services to be provided in an urgent care facility.  HRSA states that costs for emergency room visits and non-HIV related visits to an urgent care center are not allowable.  (p. 15-16.)

 

• HAB struck language under the description of Emergency Financial Assistance that stated that RWHAP is the payor of last resort.  Presumably, HAB now recognizes that an emergency situation may require use of Ryan White funds before other financial resources can be researched and accessed.

 

• Under Housing, HAB struck language stating that housing that does not provide care medical or support services must be essential for the HIV/AIDS patient or family to gain or maintain access to care.  Presumably, HAB will allow housing assistance even if the Ryan White Clinic cannot document that it is essential to gain or maintain access to care.

 

• HAB clarified that Non-Medical Care Management Services includes employment and vocational services and may be provided through telehealth.  (p. 20.)

 

• HAB’s revised policy on Outreach Services states that these services must use data to target populations and places that have a high probability of reaching people living with HIV and who (a) have never been tested and are undiagnosed, (b) have been tested, diagnosed as HIV positive, but have not received their test results, or (c) have been tested and know their HIV positive status, but are not in medical care.  HAB also clarified that outreach services may be provided through community and public awareness activities that include clear links to, and information about, available services.  HAB also revised its policy that funds may not be used to pay for HIV counseling or testing under the Outreach service category.  HAB now allows funds to be used for HIV testing when resources are available and where testing costs would not supplant other funding.  (p. 22.)

 

• HAB clarified that Rehabilitation Services include speech and vocational therapy. (p. 23-24.)