FAQs: MMHU

1

The NOFO states we are able to lease vehicles. Are we able to purchase vehicles? Here is the complete question: In terms of allowable costs, it appears that purchase of a vehicle is not allowable (only lease)? Also, it appears that capital expenses are not allowable, but will the grant cover DEA required modifications such as purchase and installation of medication safe and purchase and installation of security system linked to local law enforcement?

Per 2 CFR 200.439, purchase of a vehicle is a capital expenditure. Capital expenditures are not allowable costs. This funding can be used to lease vehicles such as vans/buses customized for the provision of services, staff/personnel, medication, and services that are not otherwise funded through health insurance, IDHS/SUPR or other government grants or correctional institutions/jails.” Vehicle purchases are not an allowable expense, but vehicle leases are permissible as long as the lease agreements are not “lease-to-own or rent-to-own”. The budget narrative must indicate number of staff per vehicle leased that will utilize the vehicle along with the purpose of the travel.

2

The NOFO states, in regards to licensure, “the licensure process should be initiated prior to submission of the plan. What does “initiation” mean? Here is the complete question: Task 3 states that “Licensing to enable the MMHU to dispense the three forms of U.S. Food and Drug Administration (FDA)-approved OUD medications (buprenorphine, naltrexone, and methadone). Please note further details on medication dispensation in Task 4; there is no set timeline for methadone. The licensure process should be initiated prior to submission of the plan.” Can you clarify (i) whether the licensure initiation process applies to methadone for providers who do not provide methadone at the time of applying but do provide buprenorphine and naltrexone and (ii) what “initiated” means?

Task 4 of the NOFO requires that “within 365 days of award, the subrecipient must launch the MMHU with capacity to: (a)Prescribe and/or dispense at least two of the three FDA-approved medications. NOTE: One of those medications must be methadone (dispense) or buprenorphine (dispense or prescribe). Due to the complexities associated with dispensation of methadone, no time frame is required. If prescribing, case management services must be provided to assist patient in obtaining medication, and receipt of medication must be confirmed in outcome measures.” The expectation is that an organization will be able to dispense all three medications as indicated in Task 3. However, there are complexities of dispensing methadone and a timeframe has not been designated for methadone. The process to obtain or renew any required licensures for these three medications must begin prior to the submission of the implementation plan as required under Task 3(a). If the organization chooses buprenorphine (dispense or prescribe) and naltrexone within the first 365 days of the award, rather than methadone and naltrexone, then the requirement of Task 4 would be satisfied. “Initiated” means that the process to obtain or renew any required licensures for the three required medications must begin prior to the submission of the implementation plan as required under Task 3(a).

3

Are organizations who already prescribe or dispense buprenorphine and naltrexone required to obtain licensure for methadone?

Yes, subrecipients must work to obtain licensing to, as noted in Section A.5., Task 3 of the NOFO, “dispense the three forms of U.S. FDA-approved medications U.S. Food and Drug Administration (FDA)-approved OUD medications (buprenorphine, naltrexone, and methadone).” However, “due to the complexities associated with dispensation of methadone, no time frame is required.” (See Task 4).

4

Can only current OTPs apply?

Opioid treatment programs (OTPs) directly licensed by IDHS/SUPR may apply independently or in partnership with primary healthcare organizations or in collaboration with community programs, including harm reduction organizations, medical providers, and community treatment providers.

5

In terms of allowable costs, it appears that purchase of a vehicle is not allowable (only lease)? Also, it appears that capital expenses are not allowable, but will the grant cover DEA required modifications such as purchase and installation of medication safe and purchase and installation of security system linked to local law enforcement?

“This funding can be used to lease vehicles such as vans/buses customized for the provision of services, staff/personnel, medication, and services that are not otherwise funded through health insurance, IDHS/SUPR or other government grants or correctional institutions/jails.” Certain equipment or supplies modifications may be allowable costs if consistent with the federal and Illinois grant regulations and requirements of this NOFO but may require prior written approval from that grantor. These costs must be supported with the appropriate supporting documentation.

6

In the MMHU NOFO, “personal use items, including expenses related to personal use of vehicles,” is an unallowable cost. Does this include mileage reimbursement for staff while traveling in their own vehicle for a program-related need?

Mileage for program-related needs would not be considered “personal use of vehicles.”

7

Is the $700,000 funding cap for the entire 21-month period or can you apply for up to $700,000 per funding period for up to $1,400,000 over the 21 months?

The $700,000 is per funding period for a total of $1,400,000 for both funding periods.

8

According to the MMHU NOFO, “Funding will ensure that patients within the priority populations receive immediate care for acute and chronic conditions, including SUD/OUD, wherever it is sought in the service area”. Is it an allowable expense and within the grant scope to lease a vehicle to transport new clients identified through mobile services to the brick-and-mortar for induction? Or is induction required to be provided in the community?

The services must be provided “where it is sought” in the service area.