American Rescue Plan (ARP) Act Awards Maternal, Infant, and Early Childhood Home Visiting (MIECHV) Program Frequently Asked Questions (FAQs)

Purpose

This Frequently Asked Questions (FAQs) webpage serves as a resource for MIECHV awardees in developing responses to the MIECHV Program American Rescue Plan Act (ARP) Award Instructions and in implementing their ARP projects. This comprehensive FAQ resource reflects both rounds of ARP grant awards. We are advising awardees to read ARP award Instructions in their entirety for complete information.

Additional Resources

• FY 2022 American Rescue Plan (ARP) Act Round 2 Award Instructions (PDF - 204 KB)
• FY 2021 American Rescue Plan (ARP) Act Award Instructions (PDF - 98 KB)
• Data, Evaluation, & Continuous Quality Improvement webpage
• ARP Reporting Instructions
• Centers for Disease Control and Prevention Coronavirus Disease 2019 webpage
• Important Home Visiting Information during COVID-19
• MIECHV Program Technical Assistance
• Information for Non-Construction Programs (SF-424)

Categories

• General Questions
• Allowable Use of Funds Category 1 – Service Delivery
• Allowable Use of Funds Category 2 – Hazard Pay or Other Staff Costs
• Allowable Use of Funds Category 3 – Home Visitor Training
• Allowable Use of Funds Category 4 – Technology
• Allowable Use of Funds Category 5 – Emergency Supplies
• Allowable Use of Funds Category 6 – Diaper Bank Coordination
• Allowable Use of Funds Category 7 – Prepaid Grocery Cards

General Questions

What is the intent of these funds?

Section 9101 of the American Rescue Plan Act of 2021 (P.L. 117-2) (ARP), added section 511A of the Social Security Act and appropriated $150,000,000 to support Maternal, Infant, and Early Childhood Home Visiting (MIECHV) Program recipients’ response to the COVID-19 public health emergency. HRSA issued $40 million in ARP awards to 56 current MIECHV recipients to address the needs of expectant parents and families with young children during the COVID-19 public health emergency.

This award provides flexibility in how recipients may use the funding to respond to COVID-19 as needs evolve. ARP identifies seven categories of allowable uses of ARP funding. HRSA encourages recipients to focus on those activities that will support current home visiting services participants and the immediate response to the COVID-19 public health emergency, as well as planning activities related to future service expansion.

HRSA intends for these funds to support activities related to the immediate and ongoing needs of families in response to the COVID-19 public health emergency. HRSA awarded an additional round of ARP funds in December 2021 to support ongoing COVID-related needs, including expansion of services to families.

How much funding was issued for the MIECHV ARP awards?

HRSA issued $40 million in May 2021 and $82 million in December 2021 in ARP awards to 56 current MIECHV grant recipients to address the needs of expectant parents and families with young children during the COVID-19 public health emergency. Recipients have the opportunity to relinquish funds if they choose to decline part or all of their awards; for more information see question on relinquishing funds.

How were MIECHV ARP award amounts calculated?

HRSA distributed the MIECHV Program ARP Round 2 awards on December 1, 2021 among eligible entities based on the following formula approach:

• Need Funding – One-half of the grant allocation available under this funding opportunity was distributed based on the number of COVID-19 cases and the number of children living in poverty in each state. 
  • Twenty-five percent of the award was distributed across states and 5 territories based on the proportion of total U.S. COVID-19 cases as calculated by the Centers for Disease Control and Prevention (CDC) and available through the CDC COVID Data Tracker retrieved on August 18, 2021. 
  • Twenty-five percent of the award was distributed across states based on the proportion of children under 5 years of age living in poverty in the U.S. as calculated by the Census Bureau’s Small Area Income and Poverty Estimates (SAIPE). SAIPE data from 2019 was used to the extent available, and these data may vary from previous year’s SAIPE data. The Puerto Rico Community Survey (PRCS) data was used as a proxy to determine child poverty data for Puerto Rico.
  • A $200,000 minimum need-based award for recipients was applied.
• Base Funding – One-half of the grant allocation available under this funding opportunity was proportionally distributed based on each recipient’s base funding portion of the FY 2021 MIECHV Formula grant award ceiling amount.

Unlike the formula approach that is used to award annual MIECHV formula funds, guard rails and deobligations were not included in the formula for the ARP awards. Funds were distributed similarly for the May 1, 2021 Round 1 awards.

(Updated December 2021)

What are the allowable uses for ARP funds?

ARP identifies seven categories of required uses of funding:

Service delivery. Funds may be used to serve families with eligible service delivery model(s) to provide in-person or virtual home visits and other program activities. This includes service expansion to new families and/or new at-risk communities, as identified in your current statewide needs assessment update.

Hazard pay or other staff costs. Funds may be used for hazard pay or other additional staff costs associated with providing home visits or administration for programs. Examples of this could include:

• Compensation for performing hazardous duty or work involving physical hardship;
• Purchase of personal protective equipment for staff;
• Purchase of technology for staff;
• Hiring costs, including incentive or overtime pay; and
• Efforts related to service expansion and family engagement and support, such as planning, hiring and onboarding additional staff, administrative supports, and other activities related to building staff and program capacity.

Home visitor training. Funds may be used to develop, conduct, and evaluate the training of home visitors that are employed by the recipient in:

• Conducting a virtual home visit;
• Emergency preparedness and response planning for families;
• Safely conducting intimate partner violence screenings; or
• Safety planning for families served to improve family outcomes in the MIECHV benchmark areas.

Technology. Funds may be used to acquire the necessary technological means, for enrolled families, to conduct and support virtual home visiting, and to address digital access and equity concerns. Examples might include: 

• Making available tablets, laptops, and cell phones to enable enrolled families to participate in virtual home visits; and
• Providing necessary auxiliary supplies and services, such as prepaid phone cards and/or data plans, chargers, mobile hot spots to support internet access, and program-specific software.

Emergency supplies. Funds may be used to provide emergency supplies to enrolled families. If you choose to budget funds for emergency supplies, you are required to coordinate with local diaper banks to the extent practicable. Some examples of emergency supplies that may be provided to eligible families include:

• Diapers and diapering supplies, including diaper wipes and diaper cream, necessary to ensure that a child using a diaper is properly cleaned and protected from diaper rash; 
• Infant formula; 
• Face masks and other personal protective equipment; 
• Food and water; and
• Hand soap and hand sanitizer.

Diaper bank coordination. Provide enrolled families with emergency supplies from diaper banks, through reimbursement to, or purchase from, diaper banks, when feasible.

Prepaid grocery cards. Funds may be used to provide prepaid grocery cards to an enrolled family for the purpose of meeting the emergency needs of the family.

(Updated December 2021)

Can I use ARP funds for multiple activities, even if they fall under more than one of the seven categories of allowable uses of funds?

Yes, you may use your ARP award to fund activities under one category or multiple categories of allowable uses of funds.

Does each ARP award need to be budgeted and tracked separately?

Yes, each ARP award has a grant number and operates as a separate award. The ARP awards—Round 1 issued in May 2021, and Round 2 issued inon December 1, 2021—need to be budgeted and tracked individually, and also separately from MIECHV formula awards. Recipients should review 45 CFR §75.302 related to financial management standards and requirements.

(Updated December 2021)

What is the period of performance for the ARP awards?

The Round 1 ARP award period of performance is May 1 – September 30, 2023. The Round 2 ARP award period of performance is December 1, 2021 – September 30, 2024.

(Updated December 2021)

How do ARP funds differ from the new authorities provided by the December 2020 Consolidated Appropriations Act, 2021 (P.L. 116-260)?

Some allowable uses of funds are similar between the Consolidated Appropriations Act authorities and the American Rescue Plan Act, but there are key differences. These differences include funding, allowable use of funds, requirements, and the applicable time period.

Consolidated Appropriations Act (CAA)

P.L. 116-260 included statutory language providing new authorities to MIECHV awardees to assist in their response to the COVID-19 public health emergency. The law allows for MIECHV funds to be used for certain training, technology, and emergency supplies cost (see HRSA’s FAQs on the Consolidated Appropriations Act for more information). Awardees can utilize FY 2021 MIECHV formula grant (X10) funds, as well as choose to rebudget FY 2019 and FY 2020 MIECHV formula grant funds for those purposes, pending the continuation of the COVID-19 public health emergency. These additional authorities are only available “during the COVID-19 public health emergency period” and therefore will be discontinued after the declared COVID-19 public health emergency. At that time, any unobligated formula grant funds budgeted for activities related to the COVID-19 specific CAA authorities must be rebudgeted for other allowable activities.

American Rescue Plan Act (ARP)

P.L. 117-2 includes supplemental appropriations to current MIECHV awardees for seven categories of use. These funds will be awarded separately from MIECHV formula grant funds. They will have specific periods of availability that conclude with the end of the 2nd succeeding federal fiscal year after the funds are awarded. They will not be discontinued at the conclusion of the COVID-19 public health emergency period.

This chart briefly summarizes the differences:

	Consolidated Appropriations Act, 2021 (P.L. 116-260)	American Rescue Plan Act of 2021 (P.L. 117-2)
Type	Additional authorities for existing awards	New awards
Period for Allowable Use	Until the conclusion of the declared COVID-19 public health emergency.	Through the end of the second succeeding fiscal year after the award.
New Funding Provided	No	Yes
Allowable Use of Fund Categories	Certain training for home visitors Technology for virtual home visits for enrolled families Emergency supplies to enrolled families	Certain training for home visitors Technology for virtual home visits for enrolled families Emergency supplies to enrolled families Service delivery Hazard pay or other staff costs Diaper bank coordination Prepaid grocery cards

Is prior approval for rebudgeting necessary for ARP awards?

You must submit a budget outlining your intended uses of ARP funds. After that budget is approved, you do not need prior approval to rebudget X11 funds if the proposed use of funding aligns with the X11 funding intent and MIECHV formula grant (X10) scope of project, avoids ineligible uses of funding as outlined in this notice of award, and complies with 45 CFR part 75 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for HHS Awards. If the amount of the costs to be rebudgeted exceeds 25 percent of the total federal award or shifts funds to a line item in your approved budget that previously had no federal funds, you must submit a prior approval rebudgeting request for review and approval by HRSA.

Can I rebudget funds under an existing MIECHV formula grant award (X10), if I would prefer to use ARP funds for certain activities?

Yes, MIECHV recipients should consider the impact to their MIECHV formula grant awards (X10) during the planning and budgeting for ARP grant award (X11) funds. Recipients may rebudget FY 2020 and FY 2021 MIECHV formula grant funds, including those previously budgeted for CAA allowances.

What are some considerations I can incorporate when planning for this ARP project?

When planning for ARP projects, consider how the allowable uses of funds for these awards might best support activities directly related to the COVID-19 public health emergency response in your state, territory, or jurisdiction. Examples of areas you might explore are:

• Addressing immediate needs of parents, children, and families related to the COVID-19 public health emergency.
• Advancing equity. HRSA encourages recipients to promote equity by allocating ARP funds to at-risk communities disproportionately impacted by COVID-19, including communities of color.
• Coordinating with local diaper banks to acquire emergency supplies and reimburse them for those supplies. Recipients of ARP funds must ensure coordination with local diaper banks when using funds to provide emergency supplies to enrolled families, to the extent practicable.
• Determining if any current LIAs have capacity to increase caseload.
• Evaluating current implementation to assess community readiness in new service areas as indicated by the most recently approved needs assessment. 

(Updated December 2021) 

How can states and communities advance health equity with these funds?

HRSA encourages recipients to promote health equity by allocating ARP funds to at-risk communities disproportionately impacted by COVID-19, including communities of color.

Additional strategies could include:

• Centering the voices and lived experiences of families to address their needs and to promote advisory and collaborative opportunities;
• Engaging in health equity action planning processes that address inequities in key areas of home visiting program implementation and performance; 
• Coordinating and integrating efforts with community and statewide multisector systems;
• Ensuring culturally responsive services are available to all families; 
• Utilizing continuous quality improvement tools and resources to address disparities in program outcomes; 
• Identifying social and structural determinants of health that lead to inequities; and 
• Integrating these priorities within existing agency strategic equity plans.

For additional information, please see the Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government dated January 21, 2021.

(Updated December 2021)

Are we able to use ARP funds to provide supplies and technology to families not supported with MIECHV funds?

No. ARP awards are subject to applicable MIECHV Program requirements and should be used to support home visiting activities that address the needs of parents, children, and families related to the COVID-19 public health emergency. Funds may not be used to support non-MIECHV activities and personnel or families that are not enrolled in your MIECHV program.

How can my organization prepare for planning and implementing our ARP project?

To prepare, consider some of the following examples:

• Review the HRSA Award Instructions and your Notice of Award. Ensure your understanding of the allowable uses of funds and due dates for deliverables and reporting requirements.
• Establish your “team”. Once you have identified allowable activities and expenditures that fit the needs of your program, identify any key partners that are critical to your plan. Common key partners are staff from finance and budget offices, procurement offices, and leadership that are part of the approval chain.
• Plan your process as early as possible. Communicate your project plan and critical information to your team, including that this funding is intended to address immediate needs of parents, children and families related to the COVID-19 public health emergency, and discuss potential challenges and opportunities. Key partners may be aware of expedited processes or alternative solutions that could reduce your timelines and help support to enrolled families faster.
• If you will be coordinating with local diaper banks for emergency supplies, reach out, or encourage subrecipients to reach out, to begin discussion on coordination and anticipated needs. This will help you confirm the supplies available from the diaper bank, and it will help the diaper bank ensure that they have or can obtain the type and quantity of supplies needed to support eligible families enrolled in your program.

What resources are available to me as I plan for my ARP project and prepare to spend these funds?

In addition to these FAQs, some additional resources available to support you are:

• The MIECHV Program Technical Assistance webpage
• Rapid Response Virtual Home Visiting collaborative
• The MIECHV Awardee Learning Library (MALL)
• Your HRSA Project Officer and Grants Management Specialist are available to respond to your questions

Are ARP awards subject to the 10 percent limit (“cap”) on administrative expenditures related to grants administration?

Yes, ARP awards are subject to applicable MIECHV Program requirements, including the restriction that no more than 10 percent of the award may be spent on administrative expenditures related to administering the grant. Recipients must follow their procedures to determine and monitor these costs to ensure they do not exceed the 10 percent cap.

However, programmatic administrative costs outside of the grants administration expenditures are not subject to the 10 percent limitation. So programmatic activities such as work to support allowable training and service delivery, diaper bank coordination, and procurement of technology, supplies, and prepaid grocery cards for enrolled families would not be subject to the 10 percent limitation.

Please note that the 10 percent cap on expenditures related to administering the grant does not flow down to subrecipients, and is not a cap on the negotiated indirect cost rate.

What if I think I will not be able to use some or all of these funds?

If you encounter or anticipate challenges in utilizing ARP funds for allowable purposes, please reach out to your HRSA Project Officer. HRSA is committed to providing technical assistance to MIECHV awardees to ensure ARP funds can be fully utilized to support the immediate and ongoing needs of families and communities impacted by COVID-19.

If you still anticipate that you will be unable to use all of the funding provided, please review your Notice of Award for instructions on the relinquishment process.

If we are funding a community with FY 2020 funds and that community was not identified in the most recent needs assessment, is the community allowed to receive ARP funds?

No. According to the ARP statute, to be eligible to receive funding, awardees must "reaffirm that, in conducting the program, the entity will focus on priority populations (as defined in section 511(d)(4))." This means that ARP funds may only be used to provide services to at-risk communities as identified in your current statewide needs assessment update. This applies across any of the seven allowable uses of ARP funding, including training, emergency supplies, technology, service delivery, etc.

If you want to use MIECHV funds to purchase emergency supplies or technology for virtual home visits for enrolled families living in communities that are currently served and were NOT identified in the 2020 needs assessment update, you can consider using MIECHV formula funds (FY 2020 MIECHV formula awards) for these expenses. The Consolidated Appropriations Act, 2021 provides MIECHV awardees with explicit authority to use grant funds for these purposes. Please contact your project officer to determine the best option for your state/territory.

Are the ARP funds limited to current LIAs, or can they be allocated to new LIAs in communities identified in the needs assessment?

ARP funds are not limited to current LIAs. You may use ARP funds to expand services to new communities identified in your most recent approved statewide needs assessment.

What if we plan to reduce funding to an LIA based on long-term performance or to reflect shifting needs in our state? Will that impact our eligibility for ARP funds? How should we represent that in our ARP award submission?

No, that would not impact your eligibility to receive ARP funds. In the Assurances section of your project narrative, you must provide a statement of assurance that funding and/or staffing levels will not be reduced on account of reduced enrollment in the program. If you anticipate reducing funding and/or staffing levels for other reasons, including as a result of shifting needs in the state or long-term performance issues, provide the required assurance and state the reason for any anticipated reduction in funding or staffing levels at an LIA. You may also wish to describe how this has been documented by your program over time and note any technical assistance you have received to address the reduction and when.

Can ARP grant funds be used to provide supports and services to non-MIECHV families enrolled in home visiting?

No, ARP funds must be used to provide services and supports to eligible families participating in the MIECHV program.

Can indirect costs be charged under ARP awards?

Yes, the same requirements related to indirect costs for MIECHV formula awards apply to ARP awards. With a current indirect cost rate agreement or cost allocation plan, indirect costs are allowable, just as they are under the MIECHV formula awards. Please refer to the FY 2021 MIECHV Formula Notice of Funding Opportunity for more information on HRSA's MIECHV Program expectations and requirements related to indirect costs.

What are the performance reporting requirements associated with ARP awards?

Recipients are required to submit Quarterly Performance and Progress Reports.

Quarterly Performance Report submissions (Form 4) are unique to the ARP grant (X11) and distinct from quarterly performance reports required for MIECHV formula grant (X10) awards. In other words, recipients must submit separate quarterly performance reports for their X11 and X10 awards.

Quarterly Progress Report submissions are narrative reports that include descriptions of the scope of activities across the seven categories of allowable uses of funds, including updates on progress in achieving project goals and objectives.

Also, families served using ARP funds must be included in your Annual Performance Report (Forms 1 and 2), which includes demographic, service utilization, and select clinical indicators and performance indicators and systems outcome measures. Data across all active grants (X10 and X11) must be consolidated into one Annual Performance Report submission, due in October of each year.

Specific reporting requirements, including deadlines and instructions for submitting reports, can be found on the MIECHV Data, Evaluation, and Continuous Quality Improvement Technical Assistance webpage. MIECHV ARP Reporting FAQs are also available to support awardees.

Instead of detailing our planned allowable uses of funds in our submission narratives, can we distribute funding to LIAs and later ask them to submit a proposal to us with how they intend to use the funds?

No. Awardees must provide the required documents in the submission, which includes the project narrative, budget form (SF-424), budget narrative, and work plan timeline. This submission should include the plans for use of funds at the LIA level across the seven allowable cost categories. HRSA will not be able to approve submissions without specific detail about LIAs’ use of funds.

(Added December 2021)

Can ARP funds be used to purchase at-home COVID-19 test kits?

Yes. ARP funds may be used to purchase at-home test kits for families. Recipients are encouraged to follow or establish policies to ensure that at-home test kits provided to families are for the families’ independent use. Home visitors may not administer nor oversee the results of the test, unless required to maintain fidelity to a model, as this would generally be considered a direct medical service (not allowable under MIECHV). Recipients should consult with model and state policy regarding test results to determine if it is safe to resume in-person visits.

ARP funds may also be used to purchase at-home test kits for home visitors. Recipients are encouraged to follow or establish policies to ensure at-home test kits are provided and used by home visitors in accordance with model and recipient policy.

(Added December 2021)

As an awardee, how should I address requests from my LIA for rebudgeting of ARP funds?

Whether an LIA can rebudget or use funds for certain allowable purposes under ARP is determined by the state, territory, or jurisdiction awardee as part of its contractual relationship and subrecipient oversight. However, if you have questions regarding whether a cost or activity would be considered allowable under ARP, HRSA can provide information regarding the use of funds under the ARP award.

(Added January 2022)

Since awardees do not have to submit separate quarterly reports for ARP 1 and ARP 2, do we need to ask that LIAs report separately for ARP 1 and ARP 2?

HRSA does not require separate quarterly reporting for ARP 1 and ARP 2 awards. However, it is up to the awardee to determine the most appropriate reporting requirements for LIAs that they contract with. It is important to note that because ARP 1 and ARP 2 awards are different grants, grant-specific reporting may be preferable to support documentation for appropriate subrecipient monitoring for each grant. This would allow for separate tracking of use of funds, performance metrics, or other required data elements specific to each grant.

(Added January 2022)

Service Delivery

What are some examples of allowable service delivery costs?

Funds may be used to serve families with eligible service delivery model(s) to provide in-person or virtual home visits and other program activities. This includes service expansion to new families and/or new at-risk communities, as identified in your current approved statewide needs assessment update. Service expansion may be critical to reaching those families and communities disproportionately impacted by the pandemic, including communities of color, and addressing their needs.

Specific examples of activities might include:

• Providing virtual or in-person home visits to families.
• Supplementing home visiting services that were decreased due to COVID-19 impacts.
• Expanding home visiting services to additional families and at-risk communities.

Am I able to use ARP funds to expand to new communities?

Yes, you may use ARP funds to expand services to new families and/or new at-risk communities, as identified in your current statewide needs assessment update.

What are some considerations for allowable service delivery costs?

ARP awards are subject to applicable MIECHV Program requirements. To be eligible for ARP, recipients must reaffirm that, in conducting the program, the recipient will focus on priority populations listed in MIECHV statute. To be allowable, funds must be used for services provided under an eligible service delivery model and provided to families living in at-risk communities, as identified in your current approved statewide needs assessment update.

ARP awards are intended to support home visiting activities that address immediate needs of parents, children and families related to the COVID-19 public health emergency. HRSA encourages recipients to promote equity by allocating ARP funds to at-risk communities disproportionately impacted by COVID-19, including communities of color.

Recipients should consider sustainability when planning for service expansion, including the period of program activities in relation to the ARP Round 1 funding period of performance (5/1/2021 – 9/30/2023) and ARP Round 2 period of performance (12/1/2021 – 9/30/2024). When planning program expansion or coordination of services, you may want to budget for additional necessary costs under this allowable use of funds, such as model certification costs and other planning activities.

Are we required to expand services, especially given that this is one time funding and may be difficult to sustain? 

No. HRSA does not require that these funds include service expansion. HRSA understands that not all recipients will be able to expand services. We encourage recipients to consider approaches to increasing caseload capacity in existing LIAs, recruiting and retaining home visitors to serve existing or expanded caseload, assessing readiness to expand to other communities, and exploring sustainability of efforts using Medicaid or other state funding.

(Added December 2021)

Can I shift caseload from the MIECHV Formula (X10) grant to the ARP (X11) grant?

Yes, generally, this would be allowable. Recipients have flexibility to move LIA contracts from X10 to X11 budgets in an effort to utilize both funding sources. However, when considering rebudgeting for this purpose, recipients must continue to ensure stability of caseload after the end of the ARP project period, and should also consider administrative expenditures and recipient level infrastructure costs. Coordinate with your HRSA Project Officer and Grants Management Specialist to document any changes involving contracts.

(Added December 2021) 

Hazard Pay or Other Staff Costs

What are some examples of “hazard pay or other additional staff costs”?

Funds may be used for hazard pay or other additional staff costs associated with providing home visits or administration for programs. Examples of this could include:

• Additional compensation for performing hazardous duty or work involving physical hardship.
• Additional staff costs associated with providing home visits or administration for MIECHV programs, such as hiring costs, or incentive or overtime pay.
• Efforts related to service expansion and family engagement and support, such as planning, hiring and onboarding additional staff, administrative supports, and other activities related to building staff and program capacity.
• Costs associated with recipient and subrecipient staff performing grant duties in support of service delivery while teleworking, such as for remote access (monitors, hot spots, data plans, keyboards, webcams, etc.). 
• Staff efforts for service expansion and family engagement and support, such as participant recruitment and retention activities, provided that the recipient connects these activities to planned delivery of services and allocates them in proportion to the benefit received by the MIECHV program, where applicable. These activities may include: 
  • Outreach for participant retention and recruitment, such as to increase awareness of MIECHV services and referrals;
  • Work to support MIECHV centralized/coordinated intake systems; and
  • Activities to support community engagement and community readiness in connection with planned expansion to new communities.

Please note that ARP awards subject to the 10 percent limit (“cap”) on administrative expenditures. Please refer to the question related to the cap for additional information.

(Updated December 2021)

What are some considerations for hazard pay or additional staff costs?

Hazard pay or additional staff costs should be in alignment with your organizational policies and federal requirements. 45 CFR §75.430 provides general provisions related to compensation for personal services for HHS awards.

The U.S. Department of Labor has prepared questions and answers related to COVID-19 and the Fair Labor Standards Act, including certain questions related to hazard pay.

Funds may be used for hazard pay or other additional staff costs for both recipient and subrecipient staff. For recipient costs, note that ARP awards are subject to applicable MIECHV Program requirements including the restriction that no more than 10 percent of the award may be spent on administrative expenditures associated with administering the grant award. Please refer to the question above for additional information.

Can this funding be used to recruit and retain home visitors?

Yes. Some examples of strategies to support the home visitor workforce in the short-term using ARP funds could include:

• Increase staff wages or provide one-time incentives, such as hiring or retention bonuses.
• Fund home visiting training, including necessary time off for enrollment in educational coursework, apprenticeships, or other practice-based learning. 
• Provide employee benefits including paid leave, health insurance, wellness and mental health support, child care, and retirement benefits for home visitors.

(Added December 2021)

The ARP award submission instructions require that applicants identify staff responsible for key project activities. What if project staff are already listed in MIECHV formula grants or funded by other sources?

Per the ARP instructions, in your submission please identify staff responsible for key project activities. If the services of the Project Director or other staff are in-kind or grant-funded, per grant requirements, recipients must identify the individual(s) by name, level of effort and annual salary, federal amount requested (if applicable), and also the source of in-kind funding. The total percent of effort for each personnel funded under this award must not exceed a sum of 100 percent FTE on all federally-funded projects. 

(Added December 2021)

Can we use ARP funds to pay individuals while they are furloughed or assigned to non-MIECHV duties?

No, if MIECHV-funded staff are furloughed or reassigned to support non-MIECHV state and/or local emergency response efforts, they may not continue to be paid with MIECHV ARP or formula funds. HRSA recognizes that many state and local programs are facing disruptions to service delivery, including staff reassignments and temporary closings of MIECHV-funded LIAs during the COVID-19 public health emergency. HRSA remains committed to ensuring MIECHV-funded activities continue with the least disruption possible to mothers, children, and families during this time, including the use of alternative service delivery strategies, in alignment with model fidelity standards. ARP funds must be used to support approved MIECHV activities.

Approved MIECHV activities may include funding for staff salaries and benefits for staff performing work under the grant, including compensating staff to continue working who may otherwise be furloughed. However, ARP award funding cannot be used to support salary costs for MIECHV-funded staff that is reassigned to non-MIECHV duties.

Can we use ARP funds for costs recipient or subrecipient staff need when teleworking?

Yes, ARP funds can be used for allowable costs to support staff performing grant duties in support of service delivery while teleworking. Please see the HRSA COVID-19 Grantee Frequently Asked Questions page for details on allowability and cost considerations.

Home Visitor Training

What type of training is allowable using ARP funds?

Funds may be used to develop, conduct, and evaluate the training of home visitors who are employed by the recipient or subrecipient. Training topics might include:

• Conducting a virtual home visit.
• Emergency preparedness and response planning for families.
• Safely conducting intimate partner violence screenings.
• Safety and planning for families served to improve family outcomes in the MIECHV benchmark areas.

What are some considerations for training?

Training costs charged to the ARP award must be for home visitors supported by MIECHV funds. Training provided to a broader audience should be allocated to the ARP award in accordance with the relative benefits received, per 45 CFR §75.405.

For instance, training fees for individual participants should be charged for MIECHV home visitors only. In another example, if the cost is per training (regardless of the number of participants) and is provided to a broader audience of home visitors across funding sources, the cost of the training should be allocated based on MIECHV-funded participants or other reasonable allocation basis.

Is reflective supervision or reflective practice considered training and allowable using ARP funds?

Conducting trainings on reflective supervision or reflective practice are allowable as a training cost under ARP. 

Providing reflective supervision and reflective practice are not considered training. However, they may be allowable under ARP using categories such as “Hazard Pay or Other Staff Costs” or “Service Delivery” if they are within the scope of the ARP award. HRSA encourages the use of reflective supervision or practices aligned with infant early mental health consultation (IECHC), consistent with model fidelity, for home visiting staff funded through the MIECHV grant as components of high-quality supervision.

(Added December 2021)

Does home visitor training include training for enrolled families?

No, “home visitor training” does not include training for enrolled families.

(Added December 2021)

Technology

What are some examples of “technology”?

Funds may be used to acquire the necessary technological means, for enrolled families to conduct and support virtual home visiting, and to address digital access and equity concerns.

Examples might include:

• Tablets, laptops, and cell phones to enable enrolled families to participate in virtual home visits.
• Necessary auxiliary supplies, such as prepaid phone cards and/or data plans, chargers, mobile hot spots to support internet access, and program-specific software.

What are some considerations for technology costs?

Consider anticipated allowable costs after initial technology purchases, such as additional phone cards and data plans, and replacement items for lost or broken supplies.

For telecommunications, video surveillance services and/or equipment, costs please see HRSA Standard Term number 15, Prohibition on certain telecommunications and video surveillance services or equipment does exist.

IT-related expenditures for recipients, such as infrastructure improvements to recipient systems, would not be allow ARP funds. However, allowable improvements to technology systems necessary to meet MIECHV program requirements are generally allowable under MIECHV formula (X10) awards.

What does HRSA require related to supplying and monitoring technology purchased using ARP funds?

In general, costs should be in alignment with your organizational policies and federal requirements. Recipients must maintain adequate financial management systems and effective internal controls (see 45 CFR §75.302-303).

Most allowable technology purchased with ARP funds will be subject to federal cost considerations for supplies, as outlined in 45 CFR §75.453.

Recipients or subrecipients should have a mechanism for tracking and documenting technology provided to enrolled families.

If your organization or subrecipient organization has specific usage limitations for purchased technology such as tablets, one example practice to address this could be to create a form outlining requirements and usage expectations, signed by the participant when the technology is provided to them, and retained for your records.

Should we give technology to families permanently, or loan it?

ARP does not dictate the terms of provision of technology to families. Recipients should consider your MIECHV program needs related to the COVID-19 public health emergency and follow your organizational policies where applicable when making determinations on mechanisms for providing technology to enrolled families.

Other considerations may include the type of technology and reasonableness. For example, higher cost laptops or tablets may have utility related to reuse, while more inexpensive supplies may not.

Does HRSA have a list of approved technology?

No. ARP funds used for technology must be used to acquire the necessary technological means, for enrolled families, to conduct and support virtual home visits. Recipients should plan the type and quantity of technology in alignment with the unique needs of your MIECHV program and response to the COVID-19 public health emergency.

Are we (recipients) required to purchase technology, or are LIAs allowed to purchase and distribute them?

Funds can be used by recipients to purchase technology directly, or may be provided to subrecipients for LIAs to purchase and distribute the technology.

In alignment with HRSA’s intent for these funds to support home visiting activities that address immediate needs of parents, children, and families related to the COVID-19 public health emergency, you could consider the needs of your MIECHV program and possible expedient solutions for providing technology when determining how best to structure procurement and distribution.

If you provide funds to subrecipients to purchase and distribute technology directly to enrolled families, you should ensure that all requirements and expectations for the purchase, distribution, and related retention of records are communicated when the funds are provided.

Am I able to use ARP funds to purchase technology for staff who are performing activities under the grant, such as virtual home visits with enrolled families, virtual training of home visitors, or subrecipient monitoring and site visits?

Yes, ARP funds may be used to purchase supplies necessary for the performance of program work by both recipient and subrecipient staff, including technology.

Please note that these costs would generally be classified under the "service delivery" or "hazard pay or other staff costs" categories, as support for the delivery of services and program administration. The “technology” use of funds category in ARP is specific to purchases for enrolled families, to conduct and support virtual home visiting.

Emergency Supplies

What are some examples of “emergency supplies”?

Funds may be used to provide emergency supplies to enrolled families. If you choose to budget funds for emergency supplies, you are required to coordinate with local diaper banks to the extent practicable. Some examples of emergency supplies that may be provided to enrolled families include:

• Diapers and diapering supplies, including diaper wipes and diaper cream, necessary to ensure that a child using a diaper is properly cleaned and protected from diaper rash.
• Infant formula.
• Personal protective equipment.
• Food and water.
• Hand soap and hand sanitizer.

Does the item have to be on the bulleted list under “Emergency Supplies” in the ARP Round 2 Award Instructions to be allowable?

No, items not included in the examples provided in the instructions may be proposed, provided the awardee includes rationale for why the item qualifies as an emergency supply and why it is within the scope of the ARP award.

(Added December 2021)

Are gas cards, taxi vouchers, or other travel vouchers allowable expenses under “emergency supplies”?

Yes. Gas cards, taxi vouchers, or other travel vouchers are allowable if provided to eligible families in response to the COVID-19 public health emergency and are within the scope of the MIECHV program. Examples might include use of gas cards in order to utilize grocery cards, or transportation support for attending well-child or pre-or-postnatal visits.

(Added December 2021)

Are we able to buy medical or health equipment with ARP funds?

ARP allows for use of funds for emergency supplies to be provided to enrolled families in response to the COVID-19 public health emergency. The MIECHV Program generally does not fund the delivery or costs of direct medical, dental, mental health, or legal services; however, some limited direct services may be provided (typically by the home visitor) to the extent required to maintain fidelity to an evidence-based model approved for use under MIECHV.

Recipients may coordinate with and refer enrolled families to direct medical, dental, mental health, or legal services and providers covered by other sources of funding, for which non-MIECHV sources of funding (to the extent available and appropriate) may provide reimbursement.

Please note, emergency supplies for enrolled families are allowable, such as personal protective equipment (e.g., masks) necessary to participate in home visits.

Does HRSA require a limit on amount of emergency supplies provided to enrolled families using ARP funds?

No. Recipients budgeting for emergency supplies should assess the types and amounts of supplies based on the needs of your MIECHV program and enrolled families.

Are we (recipients) required to purchase the emergency supplies, or are LIAs allowed to purchase and distribute them?

Recipients are not required to purchase emergency supplies directly and do have flexibility to provide funds to subrecipients for purchase and distribution.

In alignment with HRSA’s intent for these funds to support home visiting activities that address immediate needs of parents, children and families related to the COVID-19 public health emergency, you should consider the needs of your MIECHV program and possible expedient solutions for providing supplies when determining how best to structure procurement and distribution.

If you provide funds to subrecipients to purchase and distribute supplies directly to enrolled families, you should ensure that all requirements and expectations for the purchase, distribution, and related retention of records are communicated when the funds are provided.

Are gift cards an allowable expense under the “Emergency Supplies” category?

Yes, gift cards for enrolled families to purchase emergency supplies are an allowable expense under “emergency supplies”.

The use of gift cards necessitates adequate policies and procedures to ensure extra precautions to safeguard the amounts and distribution and address the risk of theft. You must follow your organizational policies, maintain effective internal controls (see 45 CFR §75.303), and maintain appropriate records and cost documentation (see 45 CFR §75.302 and 45 CFR §75.361).

Gift cards may not be used for unallowable purposes, such as for the purchase of alcoholic beverages (45 CFR §75.423). Gift cards may only be provided to families enrolled in the MIECHV program.

A best practice for compliance with the use of gift cards is to obtain a signed statement by the enrolled family acknowledging and agreeing to the purpose(s) of and restrictions on gift card use. HRSA does not require, nor does it encourage, recipients to collect further usage information (such as receipts) from enrolled families.

(Added January 2022)

Diaper Bank Coordination

What is meant by “diaper bank coordination”?

ARP funds may be used to purchase and/or reimburse diaper banks for emergency supplies for enrolled families when feasible. If you choose to budget funds for emergency supplies, you are required to coordinate with local diaper banks to the extent practicable and to the extent that the supplies are available within local diaper banks.

What is a diaper bank? How can I locate a “local” diaper bank?

A diaper bank is an organization that provides free diapers to address diaper needs. Many diaper banks also provide diapering supplies, training pants, menstrual supplies, and adult incontinence supplies.

You can search diaper bank network directories, such as the National Diaper Bank Network , for local diaper banks.

What are some considerations for coordinating with local diaper banks?

If you will be coordinating with local diaper banks for emergency supplies, reach out, or encourage subrecipients to reach out, to begin discussion on coordination and anticipated needs. This will help you confirm the supplies available from the diaper bank, and it will help the diaper bank ensure that they have or can obtain the type and quantity of supplies needed to support eligible families enrolled in your program.

In alignment with HRSA’s intent for these funds to support home visiting activities that address immediate needs of parents, children, and families related to the COVID-19 public health emergency, you should consider the needs of your MIECHV program and possible expedient solutions for providing supplies and reimbursing diaper banks when determining how best to structure purchase and distribution.

Are we (recipients) required to reimburse diaper banks directly, or are LIAs allowed to coordinate with and reimburse diaper banks for supplies?

Recipients are not required to reimburse diaper banks directly and have flexibility to provide funds to subrecipients for purchase or reimbursement.

Are states required to coordinate with diaper banks?

If you choose to budget ARP funds for emergency supplies for families, you are required to coordinate with local diaper banks to the extent practicable. If you determine it is not practicable to coordinate with local diaper banks (for example, if there are no diaper banks that serve MIECHV communities) but choose to budget for emergency supplies, describe the identified barriers to coordination with local diaper banks in your ARP award submission.

Can ARP funds be used to create or build capacity to create a local diaper bank if one does not already exist?

No, ARP funds cannot be used for the creation of local diaper banks. 

(Added December 2021)

Prepaid Grocery Cards

What are some considerations for prepaid grocery card costs?

The use of prepaid grocery or grocery gift cards necessitate adequate policies and procedures to ensure extra precautions to safeguard the amounts and distribution and address the risk of theft. You must follow your organizational policies, maintain effective internal controls (see 45 CFR §75.303), and maintain appropriate records and cost documentation (see 45 CFR §75.302 and 45 CFR §75.361).

Prepaid grocery cards may not be used for unallowable purposes, such as for the purchase of alcoholic beverages (45 CFR §75.423). Prepaid grocery cards must only be provided to families enrolled in the MIECHV program.

A best practice for compliance with the use of prepaid grocery cards is to obtain a signed statement by the enrolled family acknowledging and agreeing to the purpose(s) of and restrictions on prepaid grocery card use. HRSA does not require, nor does it encourage, recipients to collect further usage information (such as receipts) from enrolled families.

Does HRSA require a limit on amount or specific stores when purchasing prepaid grocery cards?

No. Recipients budgeting for prepaid grocery cards should assess the amounts based on the needs of your MIECHV program and enrolled families. ARP does not place restrictions on specific stores or amounts of funding. Recipients should consider accessibility and other factors affecting enrolled families when determining the most appropriate prepaid grocery card for enrolled families and communities.

If the grocery store sells items that are unallowable uses of prepaid cards, such as alcohol, are we prohibited by HRSA from purchasing prepaid grocery cards from that store?

No.

Are we (recipients) required to purchase the prepaid grocery cards, or are LIAs allowed to purchase and distribute them?

Recipients are not required to purchase prepaid grocery cards directly and do have flexibility to provide funds to subrecipients for purchase and distribution.