Colleen Meiman from the State Associations of Community Health Centers recently highlighted that the criteria for an acceptable “justification” for a PMS drawdown request are continually developing. Here are two recent developments:

  • New requirement to provide dollar totals by line-item: Starting last Friday, many CHCs and PCAs have received emails from DefendTheSpend stating that their PMS “justification” must now “specify each item, service, or expense, along with corresponding costs.” For more info on this new requirement, see Colleen’s email from around 8:45 PM Eastern on Monday.
  • New recommendations to include a certification and start-&-end dates: On Thursday, a CHC received detailed guidance from a SAMHSA grants officer about how to write an acceptable justification for a SAMHSA grant. While most of that guidance aligned with what HRSA grants officers are requiring, there were two notable additions:
  1. Add the start and end dates for the expenses for which funds are sought.
  2. Add the following “certification” statement:
    “We certify that all costs are allowable, allocable, reasonable, and necessary in accordance with the terms and conditions of the Notice of Award.”

As these expectations are likely to extend to HRSA grants soon, we encourage CHCs and PCAs to begin incorporating them into their drawdown requests.

Given these two developments, the most up-to-date recommended language for a PMS drawdown justification, as of Thursday 5/8, is below, with the most recent additions highlighted:

  1. This award is for providing primary medical, preventive dental, and behavioral healthcare to adults and children with limited access to health care in [describe your geographic area].
  2. Consistent with our approved budget for this [H80 or other] grant, we are requesting a payment of $insert total dollar amount] for the period [insert time period start and end]. The requested funds will be allocated as followed: [list specific line items from your SF-424A, and total expenses for each: e.g., “Personnel: $___ ; Fringe Benefits: $___; Travel: $___; Equipment: $____: Supplies $____; Contractual/ Subawards $____; Other $____; Indirect Costs $____]
  3. These funds are necessary to support the healthcare services required under our grant.
  4. We certify that all costs are allowable, allocable, reasonable, and necessary in accordance with the terms and conditions of the Notice of Award.

You can always find the most up-to-date recommended language for a PMS drawdown justification in the LINKS tab at the far left of the Online Resource Spreadsheet (under the heading “BPHC”).