Bona Fide Needs Rule and Activation of a hospital

[cblack20]

We are currently activating a medical center, the first large scale activation for our agancy in over 25 years. Construction of the facility is underway, with completion due in 2012. We are currently procuring items needed for our hospital and clinics. The problem we are currently facing is that some of our purchasing is beginning now for items needed in 2011. Because the need is outside the FY purchased, it would seem that we are in violation of the Bona Fide Needs rule.

Does anyone know of an exeception when activating a medical center or other activation situations? We are purchasing items in advance due to the fact of incremental funding. Procurement of everything required for a medical center cannot possibly be accomplished in one year prior to the opening of whole Medical Center.

Any guidance is greatly appreciated.

[brian]

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In addition to needing a fully built, equipped and staffed hospital in 2012, when you go "live," I think there are intervening milestones that are also bona fide needs. For example, way before you hire all the staff, you gotta get accreditation. For that, you've got to have all the major equipment and procedures and protocols in place. That might make any particular piece of equipment a bona fide need in 2011.

Also, even though your hospital won't be done for 2 years, your agency mission for health care delivery is not being met today, presumably (why else the new hospital ?) So, even though some of the pieces won't be in place for a while, the need for the facility, with all its furnishings, is a need that has existed last year, exists this year, and will exist when the hospital finally opens.

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