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From: Papier, Joel (NIH/OD) \[E\]

Sent: Tuesday, January 29, 2008 2:56 PM

To: NIH Executive Officers

Cc: OD-Budget Officers Long; Stith, Kenneth (NIH/OD) \[E\]; Miers,
Kristy (NIH/OD) \[E\]; Adams, Linda (NIH/OD) \[E\]; Gottesman, Michael
(NIH/OD) \[E\]; Gallin, John (NIH/CC/OD) \[E\]; Wyatt, Richard G
(NIH/OD) \[E\]; Major, Chris (NIH/OD) \[E\]; Lenowitz, Phil (NIH/OD)
\[E\]; Pla, Karen (NIH/OD) \[E\]; D\'Ascoli, Nicholas (NIH/OD) \[E\];
Irick, Priscilla (NIH/OD) \[E\]; Coldsmith, Sam (NIH/OD) \[E\]; Michael,
Joseph Kirk (NIH/NLM) \[E\]; Rolfes, Ellen (NIH/NHGRI) \[E\]

Subject: OFM Transmittal No. 305C - Use of Appropriated Funds to Pay for
Professional Licensure

Importance: High

All,

This transmittal supersedes OFM Transmittal No. 305.

The NIH senior officials have decided as a matter of revised NIH policy
to pay the expense of one state license per fiscal year for the NIH
employees described below, when it is determined that the license is
essential to the individual's clinical program responsibilities and they
are credentialed at the Clinical Center or at another NIH Intramural
health care facility. (You should contact your IC Scientific Director to
see if you qualify for reimbursement). As a result, we present the
following revised question and answer guidance:

Q1) Under what statutory authority are ICs able to pay for an employee
to obtain his/her professional credentials?

A1) 5 U.S.C. 5757(a).

Q2) Which IC credentialed health care provider employees are covered?

A2) GS and prevailing rate (wage) employees, SES and equivalent
employees, and employees appointed under Title 42 except as noted in A3,
who are health professionals credentialed either at the Clinical Center
or at another NIH Intramural health care facility and who require
licensure in order to provide clinical care.

NOTE: Contractors, trainees \[VFs, IRTAs, CRTAs, etc.\] and volunteers
are NOT employees.

Q3) Which IC credentialed health care provider employees are excluded
from coverage?

A3) Commissioned Corps Officers and Schedule C employees or employees
seeking to qualify for Schedule C appointments are not covered under the
above statute.

Q4) Who has the delegated authority to approve payment for licensure of
the employees listed in A2 above?

A4) The Director, Office of Human Resources may approve full payment for
licensure for employees listed in A2, per the Memorandum from the HHS
Deputy Assistant Secretary for Human Resources to the HHS Human
Resources Center Directors, dated October 1, 2003 entitled "Delegation
of Human Resources Authorities". This authority may NOT be redelegated.

Q5) What sorts of professional licenses can be paid/reimbursed?

A5) Examples of health professions, which are credentialed by the CC and
other facilities and which require a license to perform clinical care,
include, but are not limited to: doctors, nurses, dentists, other
licensed independent practitioners, pharmacists, therapists, etc.

Q6) Can appropriated funds be authorized to pay for more than one
license for one employee?

A6) No. At this time, use of appropriated funds may be authorized to pay
for only one license per employee, per fiscal year. An employee may
identify the one license which he/she would like to have covered. The
payment may be for a new license, or for the renewal of a license that
expired.

Q7) If a qualified employee previously paid out of pocket to obtain
professional licensure, prior to October 1, 2007, can he/she be
reimbursed for this expense?

A7) No. There will be no retroactive reimbursements for purchases of
professional licensure that occurred prior to October 1, 2007.

Q8) For all requests for payments made after September 30, 2007 what
mechanism(s) is to be used when appropriated funds are authorized for
the payment/reimbursement of professional licensure fees?

A8) An IC will have three options for payment/reimbursement:

1\) Use of the Government Purchase Card for an acquisition before the
fact; or

2\) A Purchase Order for an acquisition before the fact; or

3\) Use of the SF-1034 for reimbursement after-the-fact (All SF-1034
reimbursements will be processed through the OFM Commercial Accounts
office.)

(For a copy - http//forms.nih.gov/adobe/procurement/SF1034.pdf)

NOTE: As per OFM Transmittal No. 305A, for all such payments and
reimbursements, you are to use the object class 25.2W "Registration and
Tuition Fees" (this translates into 25.232 in the UFMS). The Department
has confirmed that this code should be used for now and will keep us
apprised of further developments in this regard. For acquisition
purchases before the fact, current year funds must be applied; for
after-the-fact SF-1034 reimbursements, the following rules apply:

a\) All requests must be submitted applying funds in the fiscal year of
licensure benefit (Example: If the license is required during FY 2008 --
you have until September 30, 2008 to apply FY 2008 funds); or,

b\) Not later than 6 months following the date of the purchase of said
license (Example: If the license was required during FY 2008, but you
did not submit a request for reimbursement until some time during FY
2009, you have, not to exceed 6 months from the date of purchase of said
license to submit the request for reimbursement. In this case, you will
need to obtain management approval to apply FY 2008 prior year funds in
FY 2009. A request that is submitted more than 6 months after the
purchase of the license shall be denied.)

Q9) For the options listed in A8, what other procedures are to be
followed?

A9) Each IC must prepare a "Request for Approval of Appropriated Funds
to Pay for Professional Licensure". The Approval Memorandum must be
signed by the IC Scientific Director as the Recommending Official and
then forwarded to the Director, Office of Human Resources, for final
approval. The attached WORD document is to be used for this purpose and
can be accessed at the following web site address:

http://olao.od.nih.gov/Acquisitions/ImportantNotices/simplifiedacquisitions/mediallicenses.htm
\<http://olao.od.nih.gov/Acquisitions/ImportantNotices/simplifiedacquisitions/mediallicenses.htm\>

NOTE: Please be advised that this web site address will be changing in
the near future at which time an announcement will go out to the NIH
community.

NOTE: For auditing purposes, a copy of the Approval Memorandum with
signatures of the IC Scientific Director and Director, Office of Human
Resources must be inserted in the IC's procurement files or kept with
the SF-1034.

Should you or your staff have questions regarding the above policies and
procedures, you can contact me on 301-496-4379 or Ken Stith on
301-402-8831.

Thanks,

Joel

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