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allowable use of funds RESADM-L Member 18 Nov 2003 14:03 EST

RESADM-L'ers, especially those of you at hospitals,

our hospital has just received a grant agreement from the state to award
some federal funds from the HRSA Bioterrorism Grant. The State agency is
administering the federal dollars as the primary grantee and has crafted
agreements to subaward the dollars to hospitals at various levels in the
State's tier of emergency resource hospitals.

We have not developed a proposal for these dollars. But we have been asked
to sign the grant agreement, which has several problems. Beyond the question
of whether or not the agreement terms are reasonable, a question has arisen
whether or not one of terms directs us to do something that we cannot
legally do.

The grant agreement directs the hospital to "correct priority deficiences"
of "pre-hospital" providers (emergency medical services providers, ambulance
companies) by providing them with needed personal protection equipment.
Ignore, for the sake of this question, the issue that the grantee is
directed to correct another organization's deficiency, and consider the
question of conflict of interest. Can the hospital legitimately use grant
(or any other) funds to purchase equipment for EMS providers?  Our
Foundation VP has compared this to a situtation we backed away from a few
years ago when we wanted to raise funds to buy 12-lead EKG equipment for
ambulance companies. Even though we proposed treating all ambulance
companies in our region equally for the EKG program, it was squashed on the
basis that we would be "buying influence" with the ambulance companies and
thus violating... I don't know, an Anti-Kickback law?

I'm not sure the same argument would apply to the flow-through federal funds
from the State because the State is directing the federal dollars to other
hospitals, geographic boundaries apply, and our competitor hospitals would
presumably also be receving funds to assist pre-hospital providers of
emergency services.

Your thoughts?

Molly Daniel
Grants Specialist
Planning Dept.
Sarah Bush Lincoln Health Center
1000 Health Center Drive
Mattoon, IL 61938-0372
tel. 217-258-2195
fax 217-258-4135
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