HHS-2021-ACL-AOA-INNU-0084 FAQs.pdf

Frequently Asked Questions

2021 Innovations in Nutrition Programs and Services - Statewide Research

HHS-2021-ACL-AOA-INNU-0084

Questions Related to Applicant Eligibility/Preference

1. Question: Who may apply for this funding opportunity?

Answer: Domestic public or private non-profit entities including state and local governments, Indian tribal governments and organizations (American Indian/Alaskan Native/Native

American), faith-based organizations, community-based organizations, hospitals, and institutions of higher education.

2. Question: Are for-profit companies or individuals eligible to apply?

Answer: No.

3. Question: Are other federal agencies eligible to apply?

Answer: No, but any federal agencies interested in exploring partnership opportunities with

ACL are encouraged to contact Judy Simon at judy.simon@acl.hhs.gov

4. Question: Are current or previous ACL INNU grantees eligible to apply?

Answer: Yes.

5. Question: Can we apply for both 2021 INNU funding opportunities (HHS-2021-ACL-

AOA-INNU-0084 and HHS-2021-ACL-AOA-INNU-0092)?

Answer: Yes. Applicants that meet the eligibility requirements may apply for both INNU funding opportunities, as they are competed separately.

6. Question: Can we apply for ACL’s National Resource Center on Nutrition and Aging

(HHS-2021-ACL-AOA-PPNU-0090)?

Answer: Yes. Applicants that meet the eligibility requirements may apply for any or all of the INNU and the PPNU funding opportunities, as they are competed separately.

7. Question: Can organizations that are not State Units on Aging apply for this grant on their own, if they have a letter of support from the State Unit on Aging?

Answer: Eligible applicants include: Domestic public or private non-profit entities, including state and local governments, Indian tribal governments and organizations (American

Indian/Alaskan Native/Native American), faith-based organizations, community-based organizations, hospitals, and higher education institutions.

mailto:judy.simon@acl.hhs.gov

8. Question: Are you interested in expanding funding to states or organizations that have never received funding from ACL (or have not been funded for a number of years)?

Answer: Preference is not given to current grantees, former grantees, or applicants who have never received funding from ACL. All applications will be reviewed and scored based on the criteria included in the funding opportunity announcement.

9. Question: Where can I find lists of previous INNU grant recipients?

Answer: On ACL’s website at https://acl.gov/programs/nutrition/innovations-nutrition-programs-and-services-0

Questions Related to Letters of Intent

10. Question: Are potential applicants required to submit a Letter of Intent?

Answer: Letters of Intent are not required but they are requested to help us in planning for the independent review process.

11. Question: Can you let us know who else from our state submits a Letter of Intent or application so we are better able to collaborate with other interested parties?

Answer: This type of information is considered “pre-decisional” and cannot be released publicly.

Questions Related to Proposal Format

12. Question: Is there a maximum page limit for the Project Narrative?

Answer: Twenty pages is the maximum length allowed. The Project Work Plan, Letters of

Commitment, Vitae of Key Personnel, Budget Narrative/Justification, and references are not counted toward the 20-page limit as long as they are clearly labeled as Appendices.

13. Question: Should applicants submit one comprehensive work plan that includes goals for all three years or should proposals include a separate work plan for each of the three years?

Answer: Applicants must provide a separate work plan for each year (year one, year two, and year three). The work plans for each year should match the separate budget plans for each year. The overall proposal should describe the goals or accomplishments that are expected over the three-year period.

14. Question: Do we need to create partner-specific work plans for our major contributing partners?

https://acl.gov/programs/nutrition/innovations-nutrition-programs-and-services-0 https://acl.gov/programs/nutrition/innovations-nutrition-programs-and-services-0

Answer: You do not need to provide any additional work plans for your partners.

However, in the work plan, you should indicate any lead persons at the partnering agencies that are responsible for tasks included in the work plan. Applications are reviewed to determine the extent to which the application narrative, work plan, and support letters reflect an adequate commitment from partners and description of their activities and areas of responsibility.

15. Question: Can we use a font size smaller than 11 for tables included in the narrative?

Answer: No. The entirety of the Project Narrative, including tables, graphics, and headings must be double-spaced, and of a standard font size of not less than 11. You can use smaller font sizes to fill in the Standard Forms and Sample Formats outside of the Project Narrative sections, such as the Project Work Plan and Budget Narrative/Justification.

16. Question: How should we list/cite references? Are references subject to the Project

Narrative criteria regarding page limit and double-spacing?

Answer: There is not a particular citation style that you are required to use with respect to references. You may include your references as footnotes, endnotes, or a separate appendix

(please be sure to clearly label). References may be single-spaced, and, if included as a separate appendix, are not subject to the 20-page limit for the Project Narrative.

17. Question: Which elements of the application can we include as an appendix?

Answer: The Project Work Plan, Letters of Commitment, Vitae of Key Project Personnel, Budget Narrative/Justification, Project Map, applicable references, and other supporting material (e.g. organization chart) can be uploaded as appendices.

Questions Related to Proposed Activities

18. Question: Is there an expectation that the program would be scaled/replicated during the grant period?

Answer: No, it is not expected that the program would be scaled/replicated during the grant period, however, scaling/replication may be included in the grant application. Network replication opportunities are intended to occur after the project is completed. Network replication occurs based upon the project’s evaluation results and the grantee’s creation of replication materials, both of which occur during the grant period.

19. Question: Can we include the expansion of the program to other localities as part of the workplan?

Answer: It is up to the applicant whether their proposed project will expand to other localities.

20. Question: The innovative new programs that our partners have implemented during COVID are continuing to evolve based on learnings from the initial implementation. Can these extensions of the programs that have been developed also be included in the submission since they are what the program is evolving to?

Answer: The purpose of this funding opportunity is to verify the effectiveness of SNP innovative programs or practices implemented during COVID-19 that positively impact participants. The programs may have been implemented at any time since the beginning of the

COVID-19 pandemic. Successful applicants must establish an evaluation framework to verify whether a program/practice is effective which would likely impact the approach to programmatic changes during the grant period.

21. Question: Our innovative programs could require policy changes (e.g., waivers) to Title III-

C in order to scale and sustain these programs. Is ACL looking for grantees to explore possible policy changes needed as a result of these innovations?

Answer: Proposed projects must have strong potential for replication by the aging services network and sustainability using OAA Title IIIC-1 funding. It is unlikely that widespread replication would be feasible if policy changes (eg waivers) were required.

22. Question: Would we be allowed to include congregate meals if they were not included in the policy during COVID-19 thus far, as well as a few other minor innovative components not yet pilot-tested?

Answer: The requirement for a policy to have been implemented does not preclude the opportunity for a new program or practice to be a component of an overall application, as long as the policy was implemented during COVID-19 and positively impacted participants.

Applications must state how the policy has strong potential for replication by the aging services network and sustainability using OAA Title IIIC-1 (congregate meals) funding.

23. Question: Must the proposed policy have been implemented and evaluated previously, or do we have the opportunity to create a new partnership or program?

Answer: A proposed policy must have been implemented and have undergone some degree of evaluation that demonstrates a positive impact on participants. The requirement for a policy to have been implemented does not preclude the opportunity for a new partnership to be proposed within an application.

24. Question: How much preliminary data is sufficient to have been gathered during a program’s COVID-19 implementation to meet the requirements of this funding opportunity?

Answer: The amount and type of preliminary data is not specified in the Notice of Funding

Opportunity. However, the application must describe the rationale and justification for proposing the particular innovation. In the application’s Problem Statement, the application should describe, in both quantitative and qualitative terms, the nature and scope of the

COVID-19 pandemic and recovery issue the proposed innovation is designed to address.

Lastly, data-informed analysis of the policy proposed may enhance the likelihood the project would have strong potential for replication by the aging services network and sustainability using OAA Title IIIC-1 funding, another key requirement

25. Question: Would an innovation that has been identified as a possible need during

COVID-19 but not yet implemented be an acceptable project?

Answer: Possibly. An innovation which has not yet been implemented may be a component of an application as long as the proposed project contains a policy implemented during

COVID-19 that positively impacted participants.

26. Question: The Notice of Funding Opportunity (NOFO) indicates the policy must “have been” implemented, but since the pandemic is still going on can you clarify whether the innovative program or practice must have previously been implemented?

Answer: The following phrases “during COVID-19” and “since the start of COVID-19” throughout the NOFO should be interpreted as meaning implemented at any time during the pandemic, to date.

27. Question: Our plan is to submit a proposal that includes two different coalition partners, not within the same organization/agency. Is this acceptable?

Answer: The Notice of Funding Opportunity does not specify the number or types of partnerships, except in the area of Universities and other academic/research partnerships, as listed on page 5 of the Notice.

28. Our innovation was led by the applicant organization [the State Unit on Aging] but was actually implemented by two partner agencies. Is this acceptable?

Answer: The policy innovation may have originally been implemented during COVID-19 at the local, AAA or state level.

29. Question: How does ACL define an “innovation”? Is it the same as a best practice?

Answer:

Applicants should ask themselves the question, "Is this policy truly innovative and has it improved service recipient outcomes?" when conceptualizing ideas. Innovation is a step further than a best practice - an innovation is a forward-looking approach which creates a program or practice in a novel way, whereas a best practice is high-quality application of a commonly implemented program or practice.

30. Question: Can we propose an evaluation measure that is not included in the Notice of

Funding Opportunity?

Answer: Yes. If an applicant wishes to use other measures, the application must explain and demonstrate the validity of those measures and why they are justified. The rationale for and validity of the respective selected alternative measures should be included in the narrative.

31. Question: The funding opportunity required that applicants commit to incorporating at least one evaluation measure from each category to show the benefit of the innovation, but what if our innovation only applies to either nutritional health, socialization OR health and well-being?

Answer: Applications must include incorporation of at least one evaluation measure for: a) food insecurity, malnutrition and hunger; b) social connection, AND c) health and well-being. Each of these three categories of participant impact match the intent of the Older

Americans Act’s Title IIIC senior nutrition program.

32. Question: Can an application propose an innovation that is not related to policies implemented during COVID-19?

REVISED Answer: Possibly. An innovation which has not yet been implemented may be a component of an application as long as the proposed project also contains a policy implemented during COVID-19 that positively impacted participants.

33. Question: Does the policy developed during COVID-19 have to be originally implemented at the statewide level?

Answer: No. The policy innovation may have originally been implemented during COVID-

19 at the local, AAA or state level.

34. Question: What does “statewide” policy mean?

Answer: “Statewide” Title IIIC-1 policy is defined as policy which impacts the Title IIIC-1 nutrition program services or operations of all senior nutrition program providers throughout a state, or territory, as applicable; statewide policies may address how Title III organizations coordinate with Title IV grantees to serve native elders.

35. Question: Who meets the definition of older adult?

Answer: For the purpose of this FOA and consistent with the definition in the Older

Americans Act (42 U.S.C. §3002(8)), we are defining an older adult as an individual who is

60 years of age or older. For tribes and tribal organizations, the age of older Indians is defined by the tribe and may vary.

36. Question: Is there a minimum number of participants served or participant outcomes measured each year?

Answer: There are no minimum targets regarding the number of participants served or participant outcomes measured, but you should include the number of participants you intend to serve and the number of outcome measurements as part of your Evaluation plan. You should also include the rationale for how you determined your targets. Targets should be realistic and achievable.

37. Question: The funding opportunity indicates we need to include a letter of support from at least one key partner that receives Title IIIC funds. How can I locate a list of

Title IIIC recipients?

Answer: Title IIIC recipient organizations include State Units on Aging (SUAs), Area

Agencies on Aging (AAAs) and local service providers (LSPs). To identify your state’s

SUA, go to: http://www.advancingstates.org/about-nasuad/about-state-agencies/list-members; to find your local AAA and LSP go to https://eldercare.acl.gov/Public/Index.aspx

38. Question: Our project aims to serve home delivered clients for the purpose of enhancing home delivered meals services. Is that an acceptable approach to include in an application?

Answer: No. Applications should include approaches to test and validate the effectiveness of policies developed during COVID-19 that support transitioning to and sustaining congregate meal programs (Title IIIC-1) and delivering impactful nutrition education. Proposed projects must have strong potential for replication by the aging services network and sustainability using OAA Title IIIC-1 funding. Examples of potential program ideas are included in the funding announcement.

39. Question: Does a proposed project need to include both a congregate meal AND a nutrition education focus?

Answer: Yes. Applications should include approaches for measuring test and validate the effectiveness of policies developed during COVID-19 that support transitioning to and sustaining congregate meal programs (Title IIIC-1) and delivering impactful nutrition education. Proposed projects must have strong potential for replication by the aging services network and sustainability using OAA Title IIIC-1 funding. Examples of potential program ideas are included in the funding announcement.

40. Question: In addition to the aging services network, can we collaborate with organizations such as YMCAs, health care organizations, faith-based organizations, etc.?

Answer: Yes. You are free to develop/propose formal or informal partnerships with a variety of organizations (i.e., senior centers, hospitals, etc.).

41. Question: With respect to geographic coverage area, can we focus on particular regions of the state or locality that are known to have a high level of need, even if the areas are not contiguous?

Answer: A contiguous geographic area is not required, though it is important to include data-driven rationale within your application to demonstrate why you have selected certain areas of focus within your state/locality.

42. Question: Are logic models required as part of this funding opportunity?

http://www.advancingstates.org/about-nasuad/about-state-agencies/list-members http://www.advancingstates.org/about-nasuad/about-state-agencies/list-members https://eldercare.acl.gov/Public/Index.aspx

Answer: No. However, if the policy relates to improving organizational capacity to provide services, an explanation of how this will be ultimately expected to improve client outcomes must be included. This explanation may be through visual representation (eg, logic model) or text (eg, narrative). Applicants should independently determine their research plan components and methodology.

In addition, the application should include periodic assessment of progress toward implementing the project and outline the extent to which the evaluation will be used to improve the performance of the project through the feedback generated by its periodic assessments.

43. Question: Must the application plan to distribute research results via peer reviewed journals?

Answer: Yes. The project’s results and findings should be disseminated in a timely manner, and in easily understandable formats which would encourage replication. In addition to a grant requirement of developing a "how to guide" for potential replication of this project, applications will be scored on their plans to publish their research in peer-review journal results that will be broadly disseminated

44. Health equity approaches are required. What resources are recommended for applicants to reference on this topic?

Answer: Innovations must align with health equity approaches which are described at the following CDC website: https://www.cdc.gov/chronicdisease/healthequity/index.htm

45. Question: Are there populations that should be targeted for this funding opportunity?

Answer: Yes. The Older Americans Act requires Title IIIC senior nutrition programs to target services to underserved older adults with greatest social and economic need, to permit such individuals to remain in home and community-based settings.

For this funding opportunity, the at-risk population should include older adults who formerly participated in the congregate nutrition program and other community-based programs, whose activity levels, access to healthy food, as well as opportunities to connect socially with others, grocery shop, obtain medical care, and exercise may have declined or changed significantly during COVID-19. These individuals, who previously were vigorous and independent, may have experienced declines in nutritional health, food security, physical capabilities, mental health and social connection.

46. Question: Can an applicant propose to give fiscal or other types of incentives, such as small amounts of money or gifts, to recruit program participants?

Answer: We do not recommend this approach, but in limited circumstances to meet programmatic goals, an applicant may propose some kinds of incentives. Monetary incentives such as cash would not be allowable. Gift cards in very small denominations ($5-

$10) signed for and properly accounted for can be an option.

https://www.cdc.gov/chronicdisease/healthequity/index.htm

However, if an applicant proposes to do so, it must present a compelling reason and evidence as to why it is necessary to do so and describe how this practice can be maintained after the grant period. An applicant needs to weigh its programmatic resources and fiscal costs against its ability to meet its targeted number of program completers. From a fiduciary perspective, every cost in the grant must meet the Federal Cost Principles, which include being reasonable, allowable and allocable. Additionally, from a programmatic perspective, grant expenditures should be developed within the context of sustainability.

47. Question: Can sites offering the programs charge participants a fee for participation?

Answer: Yes, as long as the process is in alignment with Older Americans Act reporting and implementation requirements. Specifically, cost-sharing is not permitted with Title IIIC meals. However, Title IIIC providers may establish a private-pay, fee-for-service meal program. For more information see the following resource:

https://seniornutrition.acl.gov/documents/EstablishingPrivatePayProgramTipSheet.pdf

Charging participants a reasonable fee is an acceptable part of a sustainability plan to offset costs. ACL considers any fees received to be program income and grantees would have to use those funds as they are earned to cover or further grant related activities. Grantees are expected to expend program income funds before drawing down additional Federal dollars.

Any program income remaining after the grant expires will require the grantee to contact the Federal agency for disposition instructions, which is generally to return the remaining balance.

Questions Related to Grant Administration

48. Question: What is the difference between a grant and a “cooperative agreement”?

Answer: In the United States, Federal grants are financial assistance issued by the U.S.

Government. A cooperative agreement is a variation of a grant, which is awarded when a grant provider anticipates having substantial involvement with the grantee during the performance of a funded project. These grants will be issued as cooperative agreements because they are significant and multifaceted endeavors in which AoA anticipates having substantial involvement with the recipients during performance of funded activities.

Therefore, throughout the project period of the grant award, AoA will furnish technical assistance, oversight, and support to each grantee to help ensure program success. The cooperative agreement structure will allow AoA to provide a higher level of technical assistance, oversight and support than a grant relationship offers. For more information, see the HHS Grants Policy Statement at https://www.hhs.gov/sites/default/files/grants/grants/policies-regulations/hhsgps107.pdf.

49. Question: Is the $400,000-600,000 funding available for each year of the grant, if awarded, or is it $400,000-600,000 for the entire 3 year project?

Answer: Under this competition, AoA/ACL will award cooperative agreements in the amount of $400,000-$600,000 for each of the three 12-month budget periods, subject to availability of funds. Successful applicants will receive grant awards totaling up to $1,200,000 over a 3 year period.

https://seniornutrition.acl.gov/documents/EstablishingPrivatePayProgramTipSheet.pdf https://www.hhs.gov/sites/default/files/grants/grants/policies-regulations/hhsgps107.pdf

50. Question: How do we calculate cost sharing/match requirements?

Answer: Under this cooperative agreement, ACL/AoA will fund no more than 75% of the project’s total cost, which means the applicant must cover at least 25% of the project’s total cost with non-Federal resources. In other words, for every three (3) dollars received in Federal funding, the applicant must contribute at least one (1) dollar in non-Federal resources toward the project’s total cost. A common error applicants make is to match 25% of the Federal share, rather than 25% of the project’s total cost.

There are two types of match: 1) non-Federal cash and 2) non-Federal in-kind. In general, costs borne by the applicant and cash contributions of any and all third parties involved in the project, including sub-grantees, contractors and consultants, are considered matching funds. Volunteered time and use of facilities to hold meetings or conduct project activities may be considered in-kind

(third party) donations.

51. Question: Can we subcontract some or all grant activities?

Answer: Yes. Grantees, not the Federal government, must decide whether it is in their best interest to subcontract grant activities. However, it is very important that grantees realize that the administrative responsibility and oversight of all grant activities remains with the grantee. Grantees must serve as the central, core, and active partner in the grant and not simply be a conduit for pass-through funding to sub-contractors. When subcontracting, the grantee should retain sufficient funding to adequately fulfill its administrative and oversight responsibilities. Applicants who propose to subcontract out a significant portion of their grant activities should provide a rationale in their proposal that justifies any additional overhead costs that affect the funding for programmatic activities.

52. Question: How are grantees able to access grant funds? Is payment based on cost reimbursement?

Answer: Grantees will draw down funds using the Payment Management System (PMS).

Costs are not reimbursed, but rather requests are made through PMS for the release of funds.

53. What are the reporting requirement associated with this cooperative agreement?

Answer: Awardees are responsible for submitting programmatic progress reports and financial reports. Applicant Notice of Awards will provide more detailed information.

Questions Related to Letters of Commitment

54. Question: To whom should letters of commitment be addressed?

Answer: Letters of commitment should be addressed to the applicant.

55. Question: Can a State Unit on Aging provide multiple letters of support if there is more than one applicant from the same state?

Answer: Yes. State agencies can make their own decisions regarding which/how many https://pms.psc.gov/ organizations they provide a letter of support for.

Questions Related to the Budget Narrative/Justification

56. Question: Should the budget include funds for traveling to meetings?

Answer: Yes. Applicants should plan and budget to send one to two representatives, once a year for the duration of the grant award, to an annual Innovations in Nutrition grantee convening identified by AoA as an appropriate grantee activity. Applicants should assume a

Washington, DC per diem amount. Further meeting details will be communicated upon grant award. It is possible that the meeting will be held remotely, in which case any funds budgeted for travel could be re-allocated to a different grant-related activity that is mutually agreed upon by the grantee and the ACL project officer.

57. Question: Does the budget range for each funding option include indirect costs?

What indirect rate can we use?

Answer: Any indirect costs charged by the applicant would be included in the amount of the federal award.

Indirect costs must be supported by an approved indirect cost rate agreement, which also defines the direct charges against which the rate applies. Indirect charges may only be requested if: (1) the applicant has a current indirect cost rate agreement approved by the

Department of Health and Human Services (DHHS) or another Federal agency; or (2) the applicant is a state or local government agency. State governments should enter the amount of indirect costs determined in accordance with DHHS requirements. If indirect costs are to be included in the application, a copy of the approved indirect cost agreement must be included with the application. Further, if any sub-contractors or sub-grantees are requesting indirect costs, a copy of the latest approved indirect cost agreements must also be included with the application, or reference to an approved cost allocation plan.

Indirect costs must be supported by an approved indirect cost rate agreement, which also defines the direct charges against which the rate applies. Indirect charges may only be requested if: (1) the applicant has a current indirect cost rate agreement approved by the

Department of Health and Human Services (DHHS) or another Federal agency; or (2) the applicant is a state or local government agency. State governments should enter the amount of indirect costs determined in accordance with DHHS requirements. If indirect costs are to be included in the application, a copy of the approved indirect cost agreement must be included with the application. Further, if any sub-contractors or sub-grantees are requesting indirect costs, a copy of the latest approved indirect cost agreements must also be included with the application, or reference to an approved cost allocation plan.

You should consult your organization’s financial representative to see if you should be charging indirect costs and if so, what the approved rate is. In the event you are looking to make an initial request, please contact the Project Officer and Grants Management

Specialist associated with this funding opportunity announcement.

NOTE: For indirect cost, applicants have two options: 1 – use the rate in their approved IDC agreement; or 2 – use the 10% di minimis rate, if no approved IDC agreement. If the applicant has an IDC agreement in place already, they would use this rate in the agreement until it expires. If an applicant doesn’t have an IDC agreement, they don’t have to have one to claim indirect cost; but can just use the

10% di minimis rate.

58. Question: Is there a cap on the indirect costs that will be permitted? Would an indirect cost rate of 45% be permitted?

Answer: There is no set limit on the indirect costs. Indirect costs can only be charged if the organization has an approved allocation plan or an approved federal indirect cost agreement.

Applicants should check with their fiscal staff for the amount that can be charged on the grant, as it is different for each organization. Also, see the HHS Grants Policy Statement at https://www.hhs.gov/sites/default/files/grants/grants/policies-regulations/hhsgps107.pdf.

59. Question: If our organization does not have a negotiated indirect cost rate, are we able to include these costs in the proposed budget?

Answer: Yes, per 45 CFR § 75.414(f) Indirect (F&A) costs, “any non-Federal entity (i.e., applicant) that has never received a negotiated indirect cost rate, may charge a de minimis rate of 10% of modified total direct costs (MTDC).”

60. Question: Regarding the budget template, can you clarify the difference between non-Federal cash versus non-Federal in kind?

Answer: These are both forms of match, and match is not required for this program. Non-

Federal cash is any cash from you or your partners; it does not include funds from the

Federal government. In kind includes any third party non-cash items that are program-related such as meeting room space that can be used as match for this program (please note, there is no match requirement in this funding opportunity). Applicants who voluntarily decide to add a match to their application will be held to that match and the match dollar amounts will be in their Notice of Award.

61. Question: Do funds need to be evenly allocated across the three-year project period?

Answer: No, however no more than $600,000 per year will be awarded. Funds do not need to be evenly allocated across the project period. Please be sure that your budget is aligned with your work plan with respect to project activities, outcomes, and outputs.

Miscellaneous Questions

62. Question: What is the make-up of the application review panels?

Answer: We recruit a variety of reviewers to participate in the review. We convene multiple panels comprised of individuals who may be former or current grantees (who are not applying for the current grant), representatives of various partnering agencies, academics, https://www.hhs.gov/sites/default/files/grants/grants/policies-regulations/hhsgps107.pdf and other people with expertise in nutrition and aging, research, public health and Senior

Nutrition Program implementation.

63. Question: Does the disclaimer noted in Section II. Award Information (Cooperative

Agreement Terms) impact grantee intellectual property rights?

Answer: No. The disclaimer noted in Section II. Award Information of the Funding

Opportunity Announcement (FOA) does not relinquish intellectual property of the grantee.

This disclaimer specifically emphasizes that the points of view or opinions of the grantee do not necessarily represent official Administration for Community Living (ACL) policy.

64. Question: Are we required to have an external evaluator for this grant?

Answer: No, you are not required to engage an external evaluator.