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Circular 05-06


DEPARTMENT OF HEALTH AND HUMAN SERVICES
Indian Health Service
Rockville, Maryland 20852

Refer to: GPS/OMS

INDIAN HEALTH SERVICE CIRCULAR NO. 2005-06

Effective Date:  10/19/2005

GRANT PROGRAMS INCENTIVES POLICY

  1. PURPOSE.  The purpose of this issuance is to establish the Indian Health Service (IHS) grant programs incentives policy.

  2. DEFINITIONS.

    1. Incentives.  Items purchased with IHS grant funds, not to exceed $30 each, to encourage patient participation in various IHS grant programs in order to adequately fulfill the goals and objectives of the project.

  3. AUTHORITIES.

    1. Office of Management and Budget (OMB) Circular A-87

    2. Public Health Service Grants Policy Statement, Rev. 4/1/94.

  4. POLICY.  The incentives policy applies to all IHS grant programs. Previously, this policy applied only to the Special Diabetes Program for Indians (SDPI) and was found in the SDPI Non Competing Application Kit for fiscal year 2005.

  5. PROCEDURES.  Incentive items are allowable costs and may be purchased with IHS grant funds.  Incentives may be used to support participants in such activities that include, but are not limited to, health fairs, and fitness programs.  The items purchased by grantees must have a reasonable value, not to exceed $30 each, and may include, but are not limited to, vouchers for the purchase of fruits and vegetables, exercise garments, water bottles, coupons for fitness activities, workout equipment (bar bells and jump ropes, etc), pedometers, duffle bags, stress balls, calendars, and other reasonable items that can be associated with the programmatic goals and objectives of the project.  Any item requested by the grantee that exceeds the $30 threshold will require prior approval from the Grants Management Officer (GMO) within the Division of Grants Operations.  All incentive costs must be justified and carefully listed so the appropriate grants specialist and the GMO can conduct a thorough cost analysis.  Each incentive item must be an allowable, reasonable, and necessary cost to the grant project.

    The incentive funds should be reflected under the “other expenses” category of the budget.  This policy requires grantees to justify the costs, in accordance with the applicable OMB circulars, to the Division of Grants Operations in the budget justification during the application process.

    There are various items that do not meet the definition of an incentive and, therefore, will be considered unallowable costs that will not be supported under IHS Federal grant funds.  Generally, items that are not considered incentives include, but are not limited to, gifts, cash and/or cash prizes, door prizes, or any type of entertainment (e.g., movie passes).  Any exception to this general policy requires prior approval from the program official and the GMO.  As previously stated, any item that cannot be associated with the overall goals and objectives of the program will not be approved.

  6. RESPONSIBILITIES.

    1. Grants Management Officer.  The GMO reviews and approves all requests from the grantee that exceed the $30 threshold.

    2. Grants Specialist.  The grants specialist, in conjunction with the GMO administers a detailed cost analysis on the grant to ensure that the incentive costs outlined in the budget are allowable, allocable, and reasonable.

    3. Grantee.  The grantee will submit a budget and a budget justification for all incentive costs.  These costs are usually included in the non-competing continuation application.  If the incentive request exceeds the $30 threshold, the grantee must request prior approval from the GMO to obtain a waiver from the dollar threshold that is outlined within this policy.

  7. SUPERSEDURE.  None.

  8. EFFECTIVE DATE.  This circular becomes effective on the date of signature.

/Charles W. Grim, D.D.S./
Charles W. Grim, D.D.S., M.H.S.A.
Assistant Surgeon General
Director, Indian Health Service


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