Are the funds limited to allowable costs for WIC?
Positions or resources that are already funded with federal funds may not be charged as expenses to the grant. Thus, the grant cannot pay for staff time already funded through WIC operational funds. Also, funds cannot be used to shift existing staff from their regular duties paid with State Administrative Expenses/WIC funds to support the grant activities unless the reassigned staff are replaced with additional staff in the positions they vacate. The grant could pay for new staff and/or contractors hired to manage or work on the project, or for current part-time staff to work on the project for hours beyond their part-time hours funded via WIC operational funds.
If we are working as a consortium that spans four Telehealth Resource Centers, should we pick one center to work with or should each state coordinate with their own center?
Please fill out the TRC contact form and mention states involved in the ‘how can we help’ form field. The TRCs will then reach out about how to best provide their support.
Would additional TRC technical assistance be an allowable cost for the grant?
Yes. During the project implementation period, the TRCs are available to provide up to ten hours per year of free technical support to funded WIC SAs to advise on program planning, implementation, and/or evaluation. If your needs are beyond this level of support then you may use grant funds to have additional TRC technical assistance during the implementation phase of the process.
HIPAA doesn't apply to WIC but WIC confidentiality is similar. Will USDA accept “HIPAA compliant” for solutions?
No. HIPAA does not translate to WIC Confidentiality. Applicants must follow the WIC Federal regulatory requirements for confidentiality. Please see 7 CFR 246.4 (a)(26), 246.26 (d), and 246.26(h) for reference.
It sounds like the emphasis is on the development of the technology, versus being a study, is that correct? I understand there is an evaluation component?
THIS-WIC is supporting State Agencies (SA) to both implement and evaluate the use of telehealth solutions that supplement the nutrition education and breastfeeding support offered in the WIC clinic. A key goal of THIS-WIC is to generate robust evidence of effective strategies for implementing telehealth solutions in WIC. Learnings from THIS-WIC research will help improve WIC services for participating SAs and help them to ensure high-quality programming and program access. These applied research findings will also inform other WIC SAs and local agencies more broadly on ways to meet program needs of the evolving WIC participant population.
WIC is HIPAA exempt because we don’t bill but confidentiality/privacy issues still apply and can vary based on County Health Department legal opinions as well. Business associate doesn't apply here. But that leaves a lot questions to be answered about telehealth within much less between State WIC programs?
WIC State agencies (SAs) must follow WIC Regulations on participant confidentiality. These regulations explain how State agencies can share information with non-WIC partners. Please see 7 CFR 246.26 (d) and 246.26(h). A confidentiality agreement is required to share participant data with any non-WIC agency. Before signing the contract or agreement with 3rd party partners, WIC SAs can share with their regional Telehealth Resource Center (TRC) any federal/state confidentiality/privacy requirements that should be included in contract/agreement to ensure all clauses are accounted for. (TRC is funded by HRSA, and providing up to 10 hours TA to WIC state agencies at no cost). Fill out this form to connect with your regional TRC.
If the 3rd party vendors doesn’t have a Business Associate Agreement (BAA), how do we ensure WIC privacy?
At the point of signing a contract with a vendor, security requirements and expectations must be written into the contract and the contract should have an out clause if they are not met. State Agencies can work with TRCs to figure out exactly what the differences are compared to WIC requirements and can help investigate whether a given company would be willing to work with them to address WIC requirements. Fill out this form to connect with your regional TRC.
So the solution can be used by paraprofessionals and not just RDs and IBCLCs?
Solutions can be used by qualified professionals as defined in the RFP: “Qualified professionals include Registered Dietitians (RD) and/or breastfeeding experts (i.e., IBCLC) who meet State staffing requirements and can provide expertise in complex nutrition and breastfeeding topics that are in accordance with WIC guidance and with program scope.” The solution may not be used by a paraprofessional.
With certifications, what is USDA FNS stance regarding the presence requirement if telehealth used for certs?
The Telehealth Solution may not be used for certification activities. The Telehealth solution must be used to supplement the nutrition education and breastfeeding support offered in the WIC clinic.
If we apply as a consortium do all the states need to be trying the same approach, vs. different states trying different solutions?
All states in a consortium must use the same approach.
Will funds be provided to only one state if applying as a consortium or can they be divided among states?
Consortium applicants should propose a lead applicant with sub-grantees and should include a detailed budget for each proposed sub-grantee. Funding will flow from THIS-WIC to the lead applicant, and then to any proposed sub-grantee organizations. The lead SA will be responsible for managing funding disbursements to other state agencies within the consortium. The mechanism for awarding the funding to other state agencies within the consortium should be a cost-reimbursable sub-award.
Additionally, as part of the sub-award process, THIS-WIC will flow down to grantees a 10% re-budget limitation that is part of THIS-WIC’s prime award with the USDA. A budget deviation of 10% or more of the total budget will require prior approval from THIS-WIC for how the funds will be repurposed. This is true whether the deviation of 10% is with the lead Agency (grantee) or one of the other consortium agency budgets.
Please reach out to the THIS-WIC Financial Coordinator, Jessica Coté, CRA, for any financial related questions Jessica.Cote@tufts
Please reach out to the THIS-WIC Financial Coordinator, Jessica Coté, CRA, for any financial related questions Jessica.Cote@tufts.edu
Will grantees be required to ensure telehealth services are limited to WIC participants and not available to non-WIC participants?
Yes. Grantees are required to ensure telehealth solutions are limited to:
• supplementing nutrition education and breastfeeding contacts to WIC participants for identified complex nutrition and/or breastfeeding problems with qualified professionals
• providing effective counseling by WIC staff with tailored, up‐to‐date information (i.e., nutrition and/or breastfeeding talking points, take‐away messages, etc.) to facilitate productive and meaningful discussions with participants
• facilitating effective documentation, care planning, and appropriate follow-up
How will you handle different indirect cost rates for a consortium?
Indirect costs for the applicant organization should be proposed in accordance with the applicant organization’s current federally negotiated indirect cost rate agreement (NICRA). Applicants without a current NICRA are limited to a de minimus indirect cost rate of 10% of modified total direct costs. Should the application include sub-grantees as part of a consortium, each sub-grantee may apply indirect costs in accordance with the sub-grantees own NICRA. If proposed sub-grantee organization(s) do not have an approved NICRA, the 10% de minimus rate applies. In the case of consortium applications with sub-grantees, a detailed budget should be submitted for each proposed sub-grantee in addition to the overall application budget.
Please reach out to the THIS-WIC Financial Coordinator, Jessica Coté, CRA, for any financial related questions Jessica.Cote@tufts.edu
Will we need to enlist local universities to help with the evaluation?
No, not necessarily. THIS-WIC will lead the evaluation of the projects in collaboration with the funded WIC SAs. Applicants do not need to be research experts or have prior experience in evaluation, but will be expected to work with the THIS-WIC team to finalize the evaluation design for funded projects and to provide data necessary to evaluate the impact, feasibility, and acceptability of the intervention.
Academic organizations are allowed to support the proposal; however, academic organizations can only assist SAs and cannot lead any of the evaluation and/or data collection aspects of the process. Academic institutions are not allowed to apply on behalf of a SA.
Do you provide a list of platforms/vendors for grantees to review?
We do not. We encourage applicants to reach out to their regional Telehealth Resource Centers to identify vendors that will work best for their unique setting. Applicants may also review selected case studies to see how telehealth solutions have been used previously in WIC.
Connectivity is a big issue in some areas, can these funds be used to help with that?
Funding can be used to help address connectivity issues through resources and support; however, larger expenses (e.g., infrastructure) are not allowed to be purchased with grant funds. Applicants should identify telehealth solutions that are feasible for their staff and participants. Reach out to your regional Telehealth Resource Center for more information on how to address connectivity concerns. For example, in the past, TRCs have assisted organizations to apply for universal services funds to identify additional funding sources to support significant connectivity expenditures.
For the brief proposal, many of the details such as platform vendor, exact staffing will not be available. To what level of detail are you requiring for the brief proposal?
Please look over the brief proposal template example to see expectations for responses for each section. Applicants should address the following points regarding telehealth solutions in their proposal:
- Clearly describes the telehealth intervention in relation to Priority Area 1 or 2 and how it will build on participant assessment information to provide nutrition education and/or breastfeeding support and how the solution will be used to deliver only allowable WIC services by qualified professionals
- Includes discussion of potential barriers and proposed solutions to overcome those barriers including how privacy and safety of WIC participants will be maintained when interacting via the proposed technology
- Demonstrates compliance with Federal Program Regulations for all proposed strategies/solutions
You must submit your brief proposal responses using the online platform.
Would two-way texting for appointment reminders be ok?
No, grant funds may not be used for appointment reminders. This grant is for providing nutrition education and breastfeeding support for WIC participants by qualified professionals. Two-way texting is an allowable telehealth modality. This RFP supports WIC SAs to develop and/or implement telehealth strategies and tools that can enhance the WIC nutrition education and breastfeeding counseling component of WIC services.