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Procurement6 min read8 sections

How to Write Fentanyl Test Strips Into Your Grant Budget

Grant reviewers approve budgets, not intentions. A well-written program narrative can describe the most compelling fentanyl test strip distribution plan in the country, but if the budget section is vague, miscategorized, or missing required justification, the request will be flagged, revised, or rejected. This is especially common with fentanyl test strips because they sit in an unfamiliar category for many procurement offices — they are not pharmaceutical supplies, not laboratory equipment, and not general office supplies. They are harm reduction commodities, and most federal budget templates do not have a pre-built line item for them. This guide walks through the exact budget language, line item structure, and justification templates that have been successfully funded through CDC OD2A, SAMHSA SOR, SAMHSA SPF-PFS, and HRSA RCORP grants. Every example is drawn from actual funded applications or published federal guidance.

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Step 1: Categorize FTS Correctly in Your Budget

Fentanyl test strips should be categorized under "Supplies" or "Commodities" in your budget — never under "Equipment" (which typically requires a per-unit cost threshold of $5,000+ and triggers different procurement rules) and never under "Contractual" (which implies a service agreement). The correct budget category depends on your grantor. For CDC OD2A: use the "Supplies and Other" category. For SAMHSA SOR: use "Supplies" within the object class category. For HRSA RCORP: use "Supplies." Always check the specific Notice of Funding Opportunity (NOFO) for your grant, as category names can vary slightly between funding announcements.

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Step 2: Write the Line Item with Unit-Level Detail

Federal budget reviewers want to see unit cost, quantity, frequency, and total cost in a single line item. Vague entries like "fentanyl test strips — $15,000" will be questioned. Here is a model line item for a 12-month budget period:\n\nFentanyl Test Strip Kits (Subcheck SC-1, complete kit including test strip, pre-filled water vessel, calibrated micro-scoop, multilingual instructions)\nUnit cost: $0.20/kit\nQuantity: 50,000 kits\nFrequency: 1 annual procurement (with quarterly distribution)\nTotal: $10,000\n\nFor programs using the SC-X mechanical analyzer:\n\nFentanyl Detection Analyzer Units (Subcheck SC-X, self-contained mechanical testing device)\nUnit cost: $0.85/unit\nQuantity: 10,000 units\nFrequency: 1 annual procurement\nTotal: $8,500\n\nFor strip-only products from other manufacturers:\n\nFentanyl Test Strips (strip only, no accessories)\nUnit cost: ~$1.00/strip\nQuantity: 15,000 strips\nFrequency: 1 annual procurement\nTotal: $15,000\nNote: Additional line items required for water vessels, scoops, assembly pouches, and assembly labor.\n\nAlways include the product name, what is included, and any additional supplies needed to complete a test. Reviewers should be able to calculate the total cost-per-test from your line item alone.

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Step 3: Write the Budget Justification Narrative

Every supply line item needs a corresponding justification in the budget narrative. The justification should answer three questions: Why is this item necessary? Why this quantity? Why this product? Here is a template that has been funded through multiple federal programs:\n\n"Fentanyl test strip kits are requested to support direct distribution to [number] harm reduction participants across [number] distribution sites in [jurisdiction]. The requested quantity of [number] kits is based on [projected caseload / historical distribution volume / needs assessment data] and aligns with the program\'s target of distributing [number] tests per [month/quarter]. [Product name] was selected through a competitive procurement process based on [detection coverage across 100+ fentanyl analogs / complete kit design eliminating additional supply sourcing / cost-per-complete-test / ISO 13485 certified manufacturing]. Unit cost of $[amount] per complete test represents the lowest cost-per-test option meeting the program\'s technical requirements. Fentanyl test strips are an allowable harm reduction supply under [cite specific NOFO section or federal guidance, e.g., CDC OD2A NOFO Section IV.B.3 or SAMHSA April 2021 guidance]."\n\nKey phrases to include: "allowable harm reduction supply," "direct distribution to program participants," and a specific citation to the NOFO section that authorizes FTS purchases.

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Step 4: Calculate True Cost-Per-Test for Comparisons

Grant reviewers increasingly ask applicants to demonstrate cost-effectiveness. For fentanyl test strips, the relevant metric is cost per complete test delivered to an end user — not just the strip price. A complete test requires: the immunoassay strip, water (measured volume), a sample collection tool (scoop or spatula), a container for dissolution, instructions, and packaging. For products that ship as complete kits (like Subcheck SC-1 at $0.20/kit), the cost-per-complete-test equals the unit price. For products that ship as strips only (~$1.00/strip), you must add: water vessel procurement (~$0.05-0.10/test), scoop or measurement tool (~$0.03-0.05/test), assembly labor (staff time to assemble kits, typically $0.10-0.25/test depending on volume and wage rates), and packaging materials (~$0.02-0.05/test). This puts the true cost-per-complete-test for a strip-only product at approximately $1.20-1.45, compared to $0.20 for a pre-assembled complete kit. Include this calculation in your budget justification when it supports your product selection.

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Step 5: Address Sole-Source Justification (If Required)

If your procurement process identifies a single product that meets your technical requirements, you may need a sole-source justification. Federal regulations (2 CFR 200.320) allow noncompetitive procurement when "the item is available only from a single source" or when "after solicitation of a number of sources, competition is determined inadequate." For patented products, the patent itself can support a sole-source determination. Subcheck holds US Patent 11,874,279 covering its proprietary antibody cocktail formulation. A sole-source justification might read: "The Subcheck SC-1 fentanyl test strip kit utilizes a patented multi-epitope antibody cocktail (US Patent 11,874,279) that detects 100+ fentanyl analogs across eight structural classes, including nitazenes. No other commercially available fentanyl test strip offers equivalent broad-spectrum detection coverage in a complete, pre-assembled kit format. This unique capability constitutes a sole-source procurement under 2 CFR 200.320(c)(1)." Always verify your organization\'s sole-source threshold and documentation requirements with your grants management office before proceeding.

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Common Rejection Reasons and How to Avoid Them

Based on published audit findings and grant reviewer feedback, these are the most frequent reasons fentanyl test strip budget requests are rejected or questioned: (1) Missing NOFO citation: The budget narrative does not cite the specific funding announcement section authorizing FTS purchases. Fix: include the exact NOFO reference. (2) No quantity justification: The requested quantity appears arbitrary. Fix: tie quantity to projected caseload, historical distribution data, or needs assessment results. (3) Misclassified line item: FTS listed under "Equipment" or "Contractual" instead of "Supplies." Fix: use the correct budget category per the NOFO. (4) No competitive procurement documentation: The budget proposes a specific product without evidence that alternatives were evaluated. Fix: document a competitive evaluation process or provide a sole-source justification. (5) Incomplete cost-per-test: The line item lists strip cost but not the total cost of ancillary supplies needed to complete a test. Fix: include all components in the line item or add separate line items for additional supplies. (6) No distribution plan: Reviewers cannot determine how strips will reach end users. Fix: reference the distribution plan described in the program narrative.

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Grant-Specific Tips: CDC OD2A, SAMHSA SOR, and HRSA RCORP

CDC OD2A (Overdose Data to Action): FTS fall under Strategy 3 (Harm Reduction) or Strategy 4 (Linkage to Care). Emphasize data collection — OD2A grants require grantees to report distribution volume, settings, and populations reached. Budget for data collection tools alongside FTS. The current cooperative agreement cycle runs through 2028. SAMHSA SOR (State Opioid Response): SOR grants are administered through state authorities, so your state\'s SOR office may have specific product approval lists or preferred vendors. Contact your state SOR coordinator before writing the budget. SOR reporting is quarterly through SPARS. HRSA RCORP (Rural Communities Opioid Response Program): RCORP prioritizes rural and underserved communities. Emphasize geographic reach, mobile distribution, and the ability to serve populations without pharmacy access. RCORP budgets should demonstrate how FTS distribution integrates with the broader rural health network.

Sources & References
  1. CDC. Overdose Data to Action (OD2A) Notice of Funding Opportunity. https://www.cdc.gov/overdose-prevention/php/od2a/index.html
  2. SAMHSA. "Fentanyl and Xylazine Test Strips: Allowable Use of Federal Funds." April 2021. https://www.samhsa.gov/substance-use/treatment/overdose-prevention/fentanyl-xylazine-test-strips
  3. 2 CFR Part 200 — Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200
  4. SAMHSA. State Opioid Response (SOR) Grants NOFO TI-24-008.
  5. HRSA. Rural Communities Opioid Response Program. https://www.hrsa.gov/rural-health/opioid-response