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EMS MATCHING GRANT APPLICATION FLORIDA DEPARTMENT OF HEALTH Bureau of Emergency Medical Services Complete all items unless instructed differently within the application Type of Grant Requested: Rural XX Matching ID. Code (The State Bureau of EMS will assign the ID Code — leave this blank) �J 1. Organization Name: City of Miami Fire -Rescue 2. Grant Signer: (The applicant signatory who has authority to sign contracts, grants, and other legal documents. This individual must also sign this application) Name: Robert Ruano Position Title: Grants Administrator Address: City of Miami City: State: Telephone: E-Mail Address: 444 SW 2 nd Ave, 5`" Floor Miami Florida (305) 416-1532 Dade Zip Code: 33130 Fax Number: (305) 416-2151 rruano@ci.miami.fl.us 3. Contact Person: (The individual with direct knowledge of the project on a day-to-day basis and responsibility for the implementation of the grant activities. This person may sign project reports and may request project changes. The signer and the contact person may be the same.) Name: Captain Allen Joyce Position Title: Executive Assistant to the Fire Chief Address: 444 SW 2 Avenue, 10m Floor City: Miami State: Florida Telephone: (305) 416-1610 County Dade Zip Code: 33130 Fax Number: (305) 416-1680 E-mail Address: ajoyceeci.miaml.fl.us DM Form 1767, Rev. June 2002 1 4. Legal Status of Applicant Organization (Check only one response): (1) ❑ Private Not for Profit (Attach documentation-501 (3) ©] (2) ❑ Private For Profit (3) XX City/Municipality/TownNillage (4) 0 County (5) ❑ State (6) ❑ Other (specify): 5. Federal Tax ID Number (Nine Digit Number). VF 596000375 6. EMS License Number: 2278 Type: XX Transport ❑Non -transport ❑Bath 7. Number of permitted vehicles by type: 47 BLS 37 ALS Transport 1 ALS non -transport. B. Type of Service (check one): ❑Rescue XX Fire ❑Third Service (County or City Government, nonfire) ❑Air ambulance: ❑Fixed wing ❑Rotowing ❑Both ❑Other (specify) 9. Medical Director of licensed EMS provider: If this project is approved, I agree by signing below that I will affirm my authority and responsibility for the use of all medical equipment and/or the provision of all continuing EMS education in this project. [No signature is needed if medical equipment and professional EMS education are not in this project.] Signature: f j r G• „Date: ,t;) kit) Print/Type: Name of Director Kathleen Schrank FL Med. Lic. No. ME 39896 Note: All organizations that are not licensed EMS providers must obtain the signature of the medical director of the licensed EMS provider responsible for EMS services in their area of operation for projects that involve medical equipment and/or continuing EMS education. if your activity is a research or evaluation project, omit Items 10, 11, 12, 13, and skip to Item Number 14. Otherwise, proceed to item 10 and the following items. 10. Justification Summarv: Provide on no more than three one sided, double spaced pages a summary addressing this project, covering each topic listed below. A) Problem description (Provide a narrative of the problem or need); B) Present situation (Describe how the situation is being handled now); C) The proposed solution (Present your proposed solution); D) Consequences if not funded (Explain what will happen if this project is not funded); E) The geographic area to be addressed (Provide a narrative description of the geographic area); F) The proposed time frames (Provide a list of the time frame(s) for completing this project); G) Data Sources (Provide a complete description of data source(s) you cite); H) Statement attesting that the proposal is not a duplication of a previous effort (State that this project doesn't duplicate what you've done on other grant projects under this grant program). DH Form 1767, Rev. 2002 2 10. Justification Summary A) Problem description Treating acute pulmonary edema is very challenging to EMS responders because of the life -threatening potential for many pre -hospital patients. Field treatments have been limited to initially supplying oxygen and administering vasodilators, diuretics, and morphine, but these are ineffective in a significant number of victims. Forced to resort to the aggressive therapy of endotracheal intubation and positive pressure, bag -valve -mask ventilation (BVM), EMS personnel must conduct a major team effort to physically coordinate the related treatment activities and prevent cardiopulmonary arrest. On top of its inherent difficulty and high degree .of risk, the approach is invasive, expensive, and distressing to the patient. Risks associated with the intubation process itself are hypoxia, failed or esophageal intubation, sedation, barotraumas, and nosocomiat infection. City of Miami Fire -Rescue (MFR) does not currently have electronic blood pressure devices to assist EMS personnel in a continuous monitor of the patient that could allow the crew to devote more hands to his or her needs. In the referenced 2002 study of continuous positive airway pressure (CPAP) efficacy, calls at which EMS responded regarding chronic obstructive pulmonary disease (COPD) and congestive heart failure (CHF) involved 32 patients in age range from 48 to 97, mean=78. This is a helpful qualifier of the age group that is most likely to be treated with the aggressive therapy, described above and further delineates why this is a grave problem in Miami at this time. Ranked 7th highest city in the U.S. for percentage of residents 65+, with 17% of its population 65 years and older, Miami is faced with an enormous challenge. Without the resources to provide improved medical equipment, it continues to subject increasing numbers of its most vulnerable residents to the antiquated medical procedures described above that risk their lives, create avoidable suffering, and inflict added burden on a struggling health care system. B) Present situation From Dec. 2002 to Nov. 2003, MFR received 63,041 EMS calls, 1,611 of which were runs to victims of asthma, near -drowning, edema (cardio pulmonary and non-) and COPDs (bronchitis, emphysema, pneumonia). MFR dispatched one of 24 ALS units to these 1,611 patients. Most received initial supply of oxygen, and/or administration of vasodilators, and/or diuretics, and/or morphine, and/or BVM, and/or intubation. A total of 70 received intubation, which has a high potential for infection and airway trauma and frequently requires patient sedation and/or paralysis that afterwards demands several hours in the Emergency Department (ED) after transport and days of hospital stay. 3 C) Proposed solution MFR wants to equip all its ALS vehicles with CPAP ventilation systems that are noninvasive alternatives to the former dangerous and distressful treatment and to train each paramedic in its use and importance. Used successfully for decades in hospitals for acute care, CPAPs quickly improve oxygenation and ventilation in acute edema or COPD patients. The pre -packaged devices are durable, compact, efficient, and cost-effective. In randomized controlled trials, CPAPs have been shown to deliver efficient treatment that avoids almost all need for performing endotracheal intubation with invasive ventilation. Records of CPAP use by EMS personnel in Delaware showed that of 800 CPAP uses in the field, only 10-15 (2%) patients required intubation. In addition, CPAP use reduced the need for medication, stabilized acute pulmonary edema, improved oxygenation and hypercapnioa, decreased respiratory laboring, and cut ED and hospital stay times. Hattestad (May 2002) states that paramedics reported significant improvement in patient condition from use of CPAP, going from initially being in so much distress they could barely speak, to reaching the hospital feeling tike they were ready to go home. To ensure successful treatment using the CPAP, patient vital signs and oxygen saturation must be carefully monitored. Watching for possible adverse effects must also be vigilant: hypotension, barotraumas, and regurgitation/aspiration. To make this process most efficient and to improve the quality of the initial assessment, a unit that combines the non-invasive monitoring of blood pressure with a pulse oximeter should be used by all EMS involved. Investment in such a precision device has the added advantages of a) quick and accurate treatment of unrecognized hypoxemia; b) improved assessments of all respiratory complaints; c) monitoring of intubated patients; d) valuable assistance on all respiratory/cardiac and stroke interventions. With the requested $149,552, Miami F-R will purchase 28 CPAPs, one for each of its 24 ALS trucks and 4 for back-up. To provide initial assessment and monitoring of patient condition white using the CPAP device, 42 Auto B/P cuffs/Pulse Oximeter Units will be procured, one for every emergency rescue vehicle in the MFR fleet and 4 as back-up. D) Consequences if not funded Without funding, MFR will lose its chance to provide its residents with a medical treatment alternative that is significantly better, safer, and money -saving all around. Substantial numbers of elderly victims of respiratory arrest will be over treated and exposed to a higher risk of medical complications and morbidity. 4 E) Geographic area to be addressed In the U.S., Miami is the poorest large city. It continues to be a gateway for poor immigrants, and its one-sided economy relies heavily on tourism. The 34.5 square miles of urban Miami are home to 362,470, but that number swells to over 750,000 during working hours, when commuters and business activities create significant congestion problems throughout the city. Low-income families and the elderly are the city's most vutnerable,groups. In 2002 Miami's median income was $20,883, and 31% of its residents lived in poverty. As mentioned, 17% of its population was aged 65 and older and 40% of them lived in poverty. Their special needs routinely put heavy demands on MFR's 911 system, which handled 63,041 EMS calls in the same year, F) Proposed time frames 1-3 months: present award notification for commission approval; research supply, meet with sales reps, write equipment specifications; develop the training curriculum; 3-5 months: purchase equipment and set up training; 9-10 months: set up training schedule; begin and document training; place CPAPs on rescues. G) Data Sources American Community Survey, 2002, from www.censussov City of Miami Department of Fire -Rescue Five Year Strategic Plan, last amended 6/9/03 City of Miami Department of Fire -Rescue Incident Report System, 2002 and 2003 data City of Miami Management Information System Hastings, D.; Monahan, J.; Gray, C..; Pavlakovich, D.; and Bartram, P. A supportive adjunct for congestive heart failure in the prehospital setting. JEMS, Sept. 1998 Hatlestad, D. Noninvasive positive pressure ventilation in prehospital care. EMS Vol 31, No. 5, May 2002 Mullin, J. We're number one! A special report - Part 2 Miami New Times Oct 3, 2003 Simpson, S., Robert, T., & Geeslin, J. A study of the efficacy of Continuous Positive Airway Pressure in selected patients in the pre -hospital setting. Unpublished report, Lake Sumter, Fla, June 2002 H) Statement attesting non -duplication The project to equip ALS trucks with CPAPs and all emergency responders with auto B/P -pulse oximeters is a new one by the City of Miami. it does not duplicate any previous effort or activity on another grant project under this grant program. 5 Next, only complete one of the following: Items 11, 12, or 13. Read all three and then select and complete the one that pertains the most to the preceding Justification Summary. 11. Outcome For Projects That Provide or Effect Direct Services To Emergency Victims: This may include vehicles, medical and rescue equipment, communications, navigation, dispatch, and all other things that impact upon on -site treatment, rescue, and benefit of emergency victims at the emergency scene. Use no more than two additional one sided, double-spaced pages for your response. Include the following. A) Quantify what the situation has been in the most recent 12 months for which you have data (include the dates). The strongest data will include numbers of deaths and injuries during this time. B) In the 12 months a er this project's resources are on-line, estimate what the numbers you provided under the preceding 'AA)" should become. C) Justify and explain how you derived the numbers in (A) and (B), above. D) What otheroutcome of this project do you expect? ,Be quantitative and explain the derivation. of your figures. E) How does this integrate into your agency's five year plan? 12. Outcome For Training Projects: This includes training of all types for the public, first responders, law enforcement personnel, EMS and other healthcare staff. Use no more than two additional one sided, double-spaced pages for your response. Include the following: A) How many people received the training this project proposes in the most recent 12 month time period for which you have data (include the dates). B) How many people do you estimate will successfully complete this training in the 12 months after training begins? C) If this training is designed to have an impact on injuries, deaths, or other emergency victim data, provide the impact data for the 12 months before the training and project what the data should be in the 12 months after the training. D) Explain the derivation of all figures. E) How does this integrate into your agency's five year plan? 13. Outcome For Other Proiects: This includes quality assurance, management, administrative, and other. Provide numeric data in your responses, if possible, that bear directly upon the project and emergency victim deaths, injuries, and/or other data. Use no more than two additional one sided, double- spaced pages for your response. include the following. A) What has the situation been in the most recent 12 months for which you have data (include the dates)? B) What will the situation be in the 12 months after the project services are on-line? C) Explain the derivation of all numbers. D) How does this integrate into your agency's five year plan? DH Form 1767, Rev, 2002 6 11. Outcome For Projects That Provide or Effect Direct Services To Emergency Victims A) Quantification of the situation in the most recent 12 months From Dec. 2002 to Nov. 2003, MFR received 63,041 EMS calls, 1,611 of which were runs to victims of asthma, near -drowning, edema (cardio pulmonary and non-) and COPDs (bronchitis, emphysema, pneumonia). Lasix was administered to patients experiencing pulmonary edema (PE) in 603 of these cases. A total of 70 PE patients eventually required intubation and BVM. (12%). B) Estimate of what the above numbers should become in the 12 months after this proiect's resources are on -tine During this time, it is anticipated that proper use of the CPAP device by trained personnel should result in a 74% decrease in the number of PE patients who require intubation. The previous total of 70 wilt be reduced to only 18 patients, meaning that 52 individuals would have a safe, effective, non-invasive alternative with all the advantages. C) Justification and explanation of how above numbers were derived Studies continue to indicate that intubation rates plummet when CPAP devices are introduced in EMS. Used in 1998 on CHF patients in Galveston (Hastings, et al) decreased the rate to 2.9%. EMS crews working with CHF and PE victims in Delaware yielded 2%. Lake Sumter, Fla reported 0% intubation in 2002 (Simpson, et at). Working with the highest rate from above of approx. 3% and applying it to MFR's last year total of 603 PE patients, we expect to reduce intubation to 18 incidences, realizing a 74% decrease. D) Other outcomes expected of this project Using this new CPAP with auto B/P cuff - pulse oximeter equipment instead of the intrusive intubation option currently being used will also: • Allow the patient to continue dialogue with the caregiver throughout the treatment • Free up crew to provide better patient care • Train firefighters to know when and how to use CPAP devices most effectively • Reduce the use of Lasix, nitrnalyrPrin, and morphine and the t rrc,.pcnd t- .,+• .. 4• �.r1.. .IFIYIIY 111� 1„La�> 7 • Realize savings in costs resulting from the decreased need for endotracheal tubes, endo Locks, disposable laryngoscope blades, CO2 measurement devices, and BVMs • Cut hospital costs because ED time and length of admission will be greatly reduced • Reduce the incidence of having to sedate or medication the patient, which will lower costs and raise patient comfort • Decrease the mortality of victims • Allow patient to adjust easily, quickly, and with minimal discomfort to the support oxygenation and ventilation, which Can be easily disconnected if there's a tolerance problem E) Integration into the agency's five year plan This project to equip EMS personnel with CPAP and auto B/P -pulse oximeters integrates well into the Five Year Strategic Plan of MFR. It corresponds to the Department's Goal #13 to "improve operations throughout the department by researching and implementing new techniques and/or equipment to affect better delivery of service and quality patient care." 8 Skip Item 14 and go to Item 15, unless your project is research and evaluation and you have not completed the preceding Justification Summary and one outcome item. 14. Research and Evaluation Justification Summary and Outcome: You may use no more than three additional one sided, double spaced pages for this item. A) Justify the need for this project as it relates to EMS. B) Identify (1) location and (2) population to which this research pertains. C) Among population identified in 14(B) above, specify a past time frame, and provide the number of deaths, injuries, or other adverse conditions during this time that you estimate the practical application of this research will reduce for positive effect that it will increase). D) (1) Provide the expected numeric change when the anticipated findings of this project are placed into practical use. • (2) Explain the basis for your estimates. E) State your hypothesis. F) Provide the method and design for this project. G) Attach any questionnaires or involved documents that will be used. H) If human or other living subjects are involved in this research, provide documentation that you will comply with all applicable federal and state laws regarding research subjects. I) Describe how you will collect and analyze the data. 15. Statutory Considerations and Criteria: The following are based on s. 401.113(2)(b) and 401.117, F.S. Use no more than one additional double spaced page to complete this item. Write N/A for those things in this section that do not pertain to this project. Respond to all others. Justify that this project will: A) Serve the requirements of the population upon which it will impact. B) Enable emergency vehicles and their staff to conform to state standards established by law or rule of the department. C) Enable the vehicles of your organization to contain at least the minimum equipment and supplies as required by law, rule or regulation of the department. D) Enable the vehicles of your organization to have, at a minimum, a direct communications linkup with the operating base and hospital designated as the primary receiving facility. E) Enable your organization to improve or expand the provision of: 1) EMS services on a county, multi county, or area wide basis. 2) Single EMS provider or coordinated methods of delivering services. 3) Coordination of all EMS communication links, with police, fire, emergency vehicles, and other related services. DH Form 1767, Rev. 2002 9 15. Statutory Considerations and Criteria: Justify that this project will: A) Serve the requirements of the population upon which it will impact Miami is a geographically small but densely populated urban area with a significant proportion of residents who are vulnerable and disadvantaged, as detailed in the description of the area on page 4. Because of the high poverty, many residents don't have health insurance or the resources to pay for health care, so they rely on MFR for their basic medical needs. Residents would be greatly served by this CPAP innovation, particularly the 17% aged 65+, 31% of whom live in poverty. They would gain a medical alternative for one of their common afflictions that would lower the inherent health risks of infection and airway trauma and the frequently required sedation and/or paralysis that afterwards demands several hours in the ED after transport and days of hospital stay. B) Enabte emergency vehicles and their staff to conform to state standards established by law or rule of the department. Covered in Florida Statute 401 and Chapter 64E•2.003 C) Enable the vehicles of your organization to contain at least the minimum eouipment and supplies as required by law, rule or regulation. Covered in Florida Statute 401 and Chapter 64E•2.003 D) Enable the vehicles of your organization to have, at a minimum, a direct communications linkup with the operating base and hospital designated as the primary receiving facility. NA E) Enabte your organization to improve or expand the provision of: 1) EMS services on a county, multi county, or area wide basis. NA 2) Single EMS provider or coordinated methods of delivering services. Providing for EMS personnel CPAP units and accompanying B/P cuff - pulse oximeter units with training will expand the advanced medical techniques that MFR can offer to its community at the same time it raises the quality of service. In so doing, MFR will be able to initiate a treatment for pulmonary edema, CHF, and COPD that is not only kinder and gentler to the victim, but significantly better, safer, and more cost-effective. 3) Coordination of all EMS communication links, with police, fire, emergency vehicles, and other related services. NA 10 16. Work activities and time frames: Indicate the major activities for completing the project (use only the space provided). Be reasonable, most projects cannot be completed in less than six months and if it is a communications project, it will take about a year. Also, if you are purchasing certain makes of ambulances, it takes at least nine months for them to be delivered after the bid is let. Work Activity Present award to the City commissioners for approval Number of Months after Grant Starts Begin End 1 2 Research supply and final prices, meet with sales representatives, and write specifications for the equipment to be purchased Develop training curriculum Purchase equipment. Set up training schedule Begin training 2 3 2 3 3 5 3 4 4 10 Begin placement of CPAPs with emergency personnel 4 10 17. County Governments: If this application is being submitted by a county agency, describe in the space below why this request cannot be paid for out of funds awarded under the state EMS county grant program. include in the explanation why any unspent county grant funds, which are now in your county accounts, cannot be allocated in whole or part for the costs herein. NA DH Form 1767, Rev. 2002 11 Salaries and Benefits: For each position title, provide the amount of salary per hour, FICA per hour, fringe benefits, and the total number of hours. Miami Fire -Rescue lieutenants to perform: curriculum development data recording research & meet with sales reps writing of equip. specifications purchase and distribution of equipment Training on how to use CPAP and brief review of auto B/P- pulse oximeter unit 18. Budget: Costs Justification: Provide a brief justification why each of the positions and the numbers of hours are necessary for this project. $ 9,900 salary $ 3,960 fringe $10,800 salary $ 4,320 fringe Various duties to be performed p/t over (largely) the first 4 months of the project that are essential to the implementation & success of project: total of 198 hrs x $50/hr = $9,900 x 40% = $3,960 1 instructor will train EMS; personnel at 6hr sessions; 36 sessions required to train 24 ALS crews per shift 6 hr x36=216 hr x $50 $10,800 x 40% = $ 4,320 TOTAL: $28,980 Expenses: These are travel costs and the usual, ordinary, and incidental expenditures by an agency, such as, commodities and supplies of a consumable nature excluding expenditures classified as operating capital outlay (see next category). Travel to training sites using F-R vehicle: Educational & record -keeping supplies; copies Indirect Cost - Fed. negotiated rate of 23.5% applied to total project expenses less operating capital outlay Costs: List the price and source(s) of the price identified. $ 144 $ 1,000 $ 7,079 Justification: Justify why each of the expense items and quantities are necessary to this project. Av round trip = 10 miles x .40/mile = $4.00/sess x 36 sessions = $144.00 Will provide training at area fire houses For training, and project evaluation $I00 x 10 mo = $I,000 For costs related to grant program but shared among other F-R functions $ 1 92,324 - $162,200 = $30,124 x 23.5% = 7,079 TOTAL: DH Form 1767, Rev. 2002 $37,203 r 12 Vehicles, equipment, and other operating capital outlay means equipment, fixtures, and other tangible personal property of a non consumable and non expendable nature, and the normal expected life of which is 1 year or more. 28 CPAP units, complete 42 auto B/P -pulse oximeter units 1000 Face masks for CPAPs TOTAL: Costs: List the price of the item and the source(s) used to identify the price, 28 @$700 = $ 19,600 42 @$2800 = $117,600 1000`@$25 = $25,000 Prices are per supplier quotations received by MFR within the past 3 months $162,200 Justification: State why each of the items and quantities listed is a necessary component of this project. A quantity of 28 will provide a CPAP unit for each ALS vehicle in the F-R fleet with 4 spares A quantity of 42 will provide a B/P -pulse oximeter unit for every F-R response vehicle in the fleet, with 4 back-up units A quantity of 1000 will provide a mask for an estimated 12 months of CPAP patient users. FINAL TOTAL: State Amount (Check applicable program) XX Matching: 75 Percent 0 Rural: 90 Percent Local Match Amount (Check applicable program) XX Matching: 25 Percent ❑ Rural: 10 Percent Grand Total DH Form 1767, Rev. 2002 $199,403 $1499552 . $ 49.851 $ 199,403 13 19. Certification: My signature below certifies the following. I am aware that any omissions, falsifications, misstatements, or misrepresentations in this application may disqualify me for this grant and, if funded, may be grounds for termination at a later date. I understand that any information I give may be investigated as allowed by law. I certify that to the best of my knowledge and belief all of the statements contained herein and on any attachments are true, correct, complete, and made in good faith. I agree that any and all information submitted in this application will become a public document pursuant to Section 119.07, F.S. when received by the Florida Bureau of EMS. This includes material which the applicant might consider to be confidential or a trade secret. Any claim of confidentiality is waived by the applicant upon submission of this application pursuant to Section 119,07,F.S., effective after opening by the Florida Bureau of EMS. I accept that in the best interests of the State, the Florida Bureau of EMS reserves the right to reject or revise any and all grant proposals or waive any minor irregularity or technicality in proposals received, and can exercise that right. I, the undersigned, understand and accept that the Notice of Matching Grant Awards will be advertised in the Florida Administrative Weekly, and that 21 days after this advertisement is published I waive any right to challenge or protest the awards pursuant to Chapter 120, F.S. certify that the cash match will be expended between the beginning and ending dates of the grant and will be used in strict accordance with the content of the application and approved budget for the activities identified. In addition, the budget shall not exceed, the department, approved funds for those activities identified in the notification letter. No funds count towards satisfying this grant if the funds were also used to satisfy a matching requirement of another state grant. All cash, salaries, fringe benefits, expenses, equipment, and other expenses as listed in this application shall be committed and used for the activities approved as a part of this grant. Acceptance of Terms and Conditions: if awarded a grant, I certify that 1 will comply with all of the above and accept the ached grant terms and conditions and acknowledge this by signing below. Signature of Authorized Grant Signer (Individual Identified in Item 2) DH Form 1767, Rev. June 2002 /z I,0103 MM/DD/YY 14 FLORIDA DEPARTMENT OF HEALTH EMS GRANT PROGRAM REQUEST FOR GRANT FUND DISTRIBUTION In accordance with the provisions of Section 401.113(2)(b), F. S., the undersigned hereby requests an EMS grant fund distribution for the improvement and expansion or continuation of pre -hospital EMS. DOH Remit Payment To: Name of Agency: Mailing Address: Citv of Miami Fire — Rescue 444 SW 2 Avenue, 10th Floor Miami. FL 33130 Federal Identification Number Authorized Agency Official: Sig ature VF6000375 /Za,43 Date Robert Ruano, Grants Administrator Type Name and Title Sign and return this page with your application to: Florida Department of Health BEMS Grant Program 4052 Bald Cypress Way, Bin C18 Tallahassee, Florida 32399-1738 Do not write below this line. For use by Bureau of Emergency Medical Services personnel only Grant Amount For State To Pay: $ Grant ID Code: Approved By: Signature of EMS Grant Officer Date State Fiscal Year: Organization Code EEO. OCA Object Code 64-25-60-00-000 N_ N2000 7 Federal Tax ID: VF Grant Beginning Date: Grant Ending Date: DH Form 17F7p� v4L Pc,:. Ju. 2CC2 • � 15