• CFDA#

  • 93.323 - Epidemiological and Laboratory Capacity for Infectious Diseases (ELC).

  • Subrecipients shall comply with the requirements applicable to the federal program. This includes  OMB Circular A-133 and/or Uniform Grant Guidance.

• Who is this grant for?

  • Local Public Health Agencies. 

  • Personnel to perform critical containment activities, such as disease surveillance, case investigation, contact tracing, and testing, based on jurisdictional needs.

  • The project also supports local responses to COVID-19 outbreaks, infection prevention efforts at health care and other settings, and promotes health equity aspects of the response.

• What is the funding year?

  • June 17*, 2020 - November 19, 2022.

    • *This funding can backdate to January 20, 2020.

• What are allowable costs? 

  • Indirect costs will be approved based on current approved negotiated indirect cost rate agreement. 

  • Because  overtime costs are a very likely and reasonable expense during the response to COVID-19, CDC will allow recipients to include projected overtime in their budgets. Recipients should be careful to estimate costs based on current real-time needs and will still be required to follow federal rules and regulations in accounting for the employee's time and effort. 

• What are unallowable costs? 

  • Research.

  • Clinical care except as provided above in connection with Domain 4 activities.

  • Publicity and propaganda (lobbying) other than for normal and recognized executive-legislative relationships, no funds may be used for:

    • publicity or propaganda purposes, for the preparation, distribution, or use of any material designed to support or defeat the enactment of legislation before any legislative body. 

  • All unallowable costs cited in CDC-RFA-CK19-1904 remain in effect, unless specifically amended in this guidance, in accordance with 45 CFR Part 75 – Uniform Administrative Requirements, Cost Principles, And Audit Requirements for HHS Awards.

• Are gift cards allowed under ELC funds for volunteers helping with vaccination clinics?

  • These are not approved at this time.

• Can gift cards or cash incentives be purchased with this funding?

  • No, that is not allowable. 

• Can additional pay be provided to staff retroactively based on new agency policy?

  • No, per 2 CFR 200.430(f) and 45 CFR 75.430(f) compensation must be "pursuant to an agreement entered into in good faith between the non-Federal entity and the employees before the services were rendered". This means that the pay rate must be established prior to the work or services being done. New policies can only impact pay practices moving forward and must be consistently applied across all funding sources, Federal and non-Federal. 

• Could our 6-county West Central Public Health Partnership combine our ELC funds to help pay for a Regional Epidemiologist or Regional Planner to support our Partnership?"

  • Yes - would need to further discuss contracting/billing structure. The role would need to be focused primarily on COVID testing & CI/CT work.

• Is there a percentage of time that employees captured on the county budget need to meet in order to be covered by ELC funding?  I remember that with CARES funding there was the 51% rule where those captured in the county budget needed to be substantially dedicated to working on COVID and the cut-off was 51% or more.  Is this the same for ELC?

  • There is no specific requirement, they would charge the effort worked on ELC activities. For example if someone was budgeted on ELC 50%, but actually only spent 25% on ELC and 75% on other activities, they would charge 25% to the grant. The percent time for any given staff member should just reflect their true effort for ELC-related activities. 

• Our local deputies helped enforce the Public Health Orders and the Face Covering orders in all businesses sectors. Can this funding be used to pay for them and their overtime?

  • This grant cannot pay for overtime expenses and if the police are just doing their normal shift/job.

• Could I use ELC funds to pay for fringe benefits such as housing costs for this potential temporary replacement of my current nurse? 

  • Any bonuses would need to be in line with documented agency compensation policy, reasonable, and necessary for the project. Per 2 CFR 200.445, we would need CDC approval for any type of housing allowance. For consideration, please submit a prior approval request.

• Is paying our COVID-hired epidemiologist a $500 month housing stipend (due to the very high cost of living here, it's an incentive) - which is usually for one year. When I pull his payroll report, that is included. Is that allowable? This employee also had moving expenses, just over $2k, that the county reimbursed him for during this period.

  • Yes, this is allowed. 

• We want to ask if payroll expenses for Crisis/mental health Specialists are allowable ELC expenses. For context, we have external licensed specialist visit once or twice per week to hold both group and - if needed, one-to-one critical incident debriefing sessions with our staff. Our staff find these sessions extremely helpful in dealing with public interactions etc. which are often stressful. 

  • Unallowable. Not part of the SOW.

• Due to the continued difficulty in attracting and recruiting RNs in our county, we wanted to ask if it would be allowable to offer a sign-on bonus to entice suitable applicants.  It continues to be time-consuming and difficult trying to attract staff to our county and feel that in order to remain competitive with the larger, metropolitan LPHAs, we need to be able to offer some kind of inducement to attract skilled staff. To overcome this disadvantage, we wanted to ask if some kind of recruitment allowance could be used to assist in attracting applicants. 

  • Yes - I think this would be fine. I don't see anything in the CDC guidance disallowing this, and they do allow for overtime (I know it's not the same, but it is somewhat analogous). As long as they are following their county hiring procedures for offering hiring bonuses, I think this would work. Plus they have documentation of their struggles hiring a nurse.

• We have added two staff to our public health order enforcement team and we would like to know if we can charge the payroll expenses for these staff to ELC. Also, can we bill supplies (stamps) related to tasks performed for public health order activities to ELC as well. 

  • Yes, we are allowing LPHAs to charge staff time to mitigation/enforcement activities. Regarding the supplies, stamps are totally fine!

• We seek clarification on whether or not we can hire two full-time RNs - who are currently utilizing through the Traveling Nurses employment agency, using ELC funds. It was our understanding that LPHAs were prohibited from hiring staff from outside the agency with ELC funds. Recruiting and employing the two RNs directly as employees would lead to significant cost savings than recruiting through an expensive, third-party recruitment agency.

  • Totally fine to use contract staff (NC). They can hire contract staff! They should adjust their budget to reflect the change. 

• Can ELC Funds be used to hire a data entry person? The data entry person will support COVID-19 vaccine clinics by collecting and gathering data from people receiving vaccines for the LPHA and for state systems like CIIS. They will provide general data support related to COVID. If allowed, at what level of funding can ELC pay the employee?

  • NO, they should use their COVID IMM funding for CIIS entries. 

• I'm writing with a question regarding allowable ELC expenses. There are staff paid through funds other than the ELC grant who work on the COVID response. If these staff are interested in furthering training in support of their COVID response work (for ex: infection prevention and control training) is it allowable to use ELC funds for the training expense?

  • Yes, this would be fine, even if they aren't funded by ELC COVID funds normally. If the training is infection prevention-related, we would like to see that if it differs from what we put in our guidance (just to make sure it's a good quality training per our infection prevention team). If the training is on a different epidemiological topic, then we would also like a heads up about which training it is so we can ensure it's inline with the CDC ELC funding guidance, but if it fits within the ELC guidance, then this would be fine to use ELC funds. 

• We are exploring the possibility of using FEMA funding to cover some of the Personnel costs included in our ELC budget plan. However, a FEMA requirement is that we must provide a 25% match. We wanted to ask if CDPHE would allow us  to use ELC funds to cover that 25% match?

  • ELC cannot be used for FEMA match.

• Please confirm that overtime expenses are allowable? 

  • Yes, they are allowed. 

Supplies

• Is winter weather gear for our partner agencies for winter testing and containment allowed?

  • Per CDC, winter clothing such as jackets and yaktraks are not allowable on ELC funds.  They are only approving PPE to protect against Covid-19.

• Is it okay for recycle a number of empty propane gas cannisters which have been used at testing events. The propane gas was an approved ELC R1 expense. 

  • I would say this is ok as long as Denver is confident they will not need them again before the end of ELC R2.

• Is it allowable to use ELC funds to support testing in an LPHA lab? Specifically, would it be allowable to purchase supplies associated with testing and fund personnel to conduct testing along with an admin position to support data entry needs related to testing? We also wanted to ask about mass vaccination planning and what types of planning activities are allowable. Would it be permitted to use funding to purchase equipment (such as Ipads) for PODs or to fund personnel supporting PODs? 

  • Yes, ELC funds can be used for COVID testing and associated supplies such as computers/Ipads would be allowable. Funding lab staff and admin staff doing testing work is allowable. 

• Would wash stations be allowable under any of the funding? We could utilize them at many places for events, school activities outside, rodeo’s and fairs. 

  • Yes, this is allowable.

• We would like to know if a $400 expense covering an American Sign Language translation of COVID vaccination clinic scripts recorded as an ASL translation Video with both captioned and non-captioned versions is an allowable ELC expense. 

  • Yes, this is allowable.

Equipment 

• Can ELC round 1 funds be used for vehicle maintenance?

  • It may be allowable. If this is an agency owned vehicle, I would recommend allocating costs as a percentage of use for testing activities. If this is a personal vehicle, payment of travel mileage accounts for normal wear and tear, so maintenance would not be appropriate. Maintain documentation of allocation methodology if charged.

• Can these funds be spent on establishing IT equipment and services for remote PODS should they have to activate for COVID. Right now, they have some temporary buildings across the county which would allow them to operate remotely.  In order to equip them, they need to install a VPN and purchase computers and cell phones. We are receiving tech support from a third-party vendor and who are invoicing us for testing site tech/deployment support services. Our questions is the invoices received are in excess of $5K. We wanted to be sure that this not infringe upon the $5K asset limit? In summary, does the $5K approval limit apply to services? 

  • This is allowable. Contracted services do not apply to the prior approval requirements for capital expenses. 

  • Vendor agreements are not a specific prior approval item per Uniform Guidance. However, as with all expenses being charged to the ELC, they must be directly related to the scope of work and in line with Uniform Guidance. 

• Is it allowed to have a high-performance refrigerator with installation and alarms, etc. on a ELC 30-month budget? 

  • If they are using it for COVID testing purposes, then it can be covered (like to store samples until they are transferred to the lab). I'm not sure they are collecting COVID samples...if they are not, then ELC funds shouldn't be used to purchase this fridge. 

• Can testing machines (e.g. Abbott) be purchases using these funds?  

  • If this is over $5,000, prior approval from our federal partners to purchase is needed. It is an allowable expense, as long as it is approved by our federal partners. This can be routed through the Program Staff. 

• We’ve been having challenges reaching cases and contacts and our team would like to have the ability to use (SMS) text communications to see if this will increase call backs to our investigators. We found an option through Google voice that meets our needs. It would cost $32 per month per user.  We’d set up about 12 investigators, so the monthly expense would be about $384. Please let us know if this is an allowable expense for ELC. The cost breakdown is $12 for the required Google Workspace set up and $20 per month for Google voice.

  • Yes, this is allowable on ELC.

• Are software licenses allowable (Tableau, FME Data Integration) expenses? We hope to integrate program data with the Dr. Justina platform so we can automate our program surveillance data.

  • Tableau is yes for sure. I'm not familiar with FME but it sounds like a data integration software, and if they are using it for COVID surveillance data projects, that would be fine too.

• Do I need separate accounts for each award?

  • Yes, each award should be accounted for and reported separately.  Please refer to §200.302   Financial management. In addition, awards provided under separate agreements and scopes of work must be tracked separately. For example:

  • One CDPHE award with multiple Federal sources requires separate tracking for each Federal funding source. 

  • Multiple CDPHE awards from the same Federal funding source require separate tracking for each award number.

• Can indirect funds be applied to ELC COVID funding?

  • Yes, LPHA indirect funds can be applied to the ELC COVID funding received, each LPHA has a predetermined indirect rate set up. 

• It was not part of our original ELC budget that was submitted but could we use ELC funding to also support testing done at an outside facility?  Would we need to submit a budget change to the state in order to use these funds for that reason?

  • This is allowed, you can submit this change with the next quarterly report for ELC in January 2021.

• Is participating in the ICAR activities considered to be the training for Deliverable #7, or is the training a separate thing?

  • The training will be a separate activity for the person at the LPHA designated to receive the training.

• We received CDPHE’s reminder about the upcoming ELC Deliverables #7 and #9. Are you able to provide an example of the ICAR tool that will be used for the infection prevention assessment with the health care facilities as part of Deliverable #9?

  • Our infection prevention team at CDPHE performs the ICAR (infection control and response) assessments virtually; LPHA staff would have the opportunity to attend if they like. I can connect this agency with our IP team if they want to see the actual tool.

• I am following up on our LPHA’s deliverables for the ELC grant.  I am reviewing Objective 2 regarding the LTCF ICAR requirements. We do have 2 LTCF’s.  One of them I would like to include has had an ongoing COVID outbreak, but we have been quite involved with intervention and helping them to include ICAR and the use of CDPHE experts to assist.  Can I use this one in deliverable?  I would write up what we have done so far to intervene to assist.

  • Yes, this would be fine! And, we could schedule an ICAR with this particular facility sometime down the road (even in 2022) to see how things are going post-COVID (hopefully).

• I'm writing with a question about the infection prevention training for outbreak response staff recommended in the recent guidance update. The staff member would like to complete CIC certification. There is an option for this on the state's list (updated guidance) through this course: https://apic.org/course/epi-education-series-online/. We wanted to ask about a cheaper option the staff member found that includes the same certification. The link to this training is: https://www.cbic.org/CBIC/Get-Certified.htm Is this cheaper option an allowable cost under the ELC grant to fulfill the deliverable? Or does the course need to be the one listed in the updated guidance? 

  • Hi - from our IP team -- this option doesn't sound like a good fit: "I would say no. The CBIC certification is literally taking the certification exam.....there is no training offered. This link is to the CBIC website which is the national certification board that we seasoned IPs access to take our certification exams to be CIC certified - they offer no training and/or education. " If it turns out that this site does offer training, they can let us know and we'll reassess. thanks

  • FOLLOW-UP QUESTION - Thank you for the information from the IP team! The alternative site for certification does offer a training component. The training offered is webinars that prepare an individual for the certification exam. Would it be possible for the team to review the webinars and let us know if these might work ok for the training?  The link to the webinars is: https://www.cbic.org/CBIC/Exam-Prep-Webinars2.htm

  • FOLLOW-UP RESPONSE - Regarding the follow-up question -- per our IP team, this website and webinars are geared towards people with some IP experience (it's more advanced training, not basic/entry level). Our team would prefer that the other training options are utilized rather than this one, unless the person who is going through the training has prior IP experience, in which case these more advanced webinars might be beneficial. 

• Can you please clarify/provide additional info on how to document budget and staffing changes that have occurred since the budget plan submission part I in sept in anticipation report #2. Also, can you provide any additional guidance on how budget revisions should be reported i.e. format/metrics etc. Also, will we need to provide supporting documentation for budget revisions/changes in Q#2?  

  • We will be sending out guidance around this it will be a CDC-developed, online training that is self-paced. It is a new training that CDC just released, so likely lots of COVID-specific stuff.

• We wanted to know how to submit the ELC deliverable about LTC facilities since we are a county without LTC facilities.

  • There is still discussion from the Program team about how to handle LPHAs that do not have LTC facilities.  More to come.

• Can we can still submit changes to the ELC budget and how should do we that?

  • They can submit changes to the budget with the next quarter report. 

• In the Staffing Plan and Budget section questions 6-7 both "contractual" and "salaries" are options for expense categories. We wanted to reach out and clarify how to classify contract staff. Would contract (non FTE) positions paid with ELC funds be considered a salary expense or would this be considered a contractual cost? Considering these staff are not salaried employees we wanted to check-in and clarify.

  • This is considered a contractual cost.

• Are LPHAs going to have to report expense breakdowns for ELC funds at some later date? There does not appear to be any detailed expense reporting for ELC. 

  • The ELC funding was set up to distribute monthly fixed payments to elevate LPHAs to invoice. LPHAs must still maintain all supporting documentation. We will select a handful of LPHAs on a quarterly basis to review supporting documents based on their quarterly report response. 

• I am filling out the quarterly report for the ELC grant and am wondering if I should keep the scope of my response to what we included in the grant funding. In this case we have only two persons that were hired under the grant but there were several other CI/CT staff hired. Do you want me to report on all staff doing investigations or only the staff the grant paid for? 

  • They should report on activity and staff used for ELC, this should include staffing plan employees and any other staffing costs that they have incurred.