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Wisconsin State PATH Provider Manual

Section 6: Financial Matters

PATH Financial Matters

Match funds

As specified in 42 U.S.C. Section 523(a) of the Public Health Service Act, as amended, cost sharing is required in the form of match.

  • All match funds must be from a non-federal funding source.
  • All match funds must be allowable under the terms and conditions of the PATH award and federal cost circulars.
  • The same match funds may never be used for more than one federal grant.
  • Match funds must be used for services approved by the state or territory and included in the intended use plan.
  • Each source of match funds, and how they will be used, must be submitted in the annual grant application.

States and territories must provide contributions from public or private entities. The required non-federal match is at least $1 for each $3 of federal PATH funds, meaning that the required match contributes 25% of all funds used to support the program. These two pools of funding are spent down concurrently.

Funds can be matched directly by the state/territory or through local public or non-federal contributions such as cash, in-kind services, or a combination of both. Match funds must be used for allowable expenses for PATH-enrolled individuals and services, according to 45 CFR Part 75.

States/territories and/or subrecipients must provide assurances that match funds will be available at the beginning of the grant period. If the state/territory, as grant recipient, does not meet the specified level of match or cost sharing reflected in the Notice of Award, the Substance Abuse and Mental Health Services Administration (SAMHSA) is allowed to make a downward adjustment in the federal award amount for current or future awards, according to 45 CFR § 75.371.

Types of match funds

Match funds can be classified as cash match funds or in-kind/non-cash match funds.

Cash

Only non-federal contributions can be counted as a cash? match. Common sources include:

  • State general funds.
  • Municipal general funds.
  • Direct donations from a foundation, United Way, homeless coalition, or other charitable association.
  • Program income or reimbursement for services and goods that are PATH eligible, such as insurance reimbursement or client fees.The Medicaid state portion may count as PATH match when a Medicaid reimbursement for a PATH-enrolled individual is subsequently re-spent for additional PATH-eligible services. Monies received from Medicaid for services performed by PATH-funded staff are considered program income to the PATH grant and may be used for match when the funds are re-spent in the PATH program. Medicaid match may also count as PATH match when a Medicaid reimbursement is for a PATH-enrolled individual receiving PATH-equivalent services
  • Subrecipient contributions from non-federal sources, including PATH providers and entities contracted for direct services.

In-kind/non-cash

In-kind/non-cash match is considered soft match for a grant. Common sources include the following if they were paid for using non-federal funds:

  • Donations of merchandise from stores, volunteer time, goods from food banks
  • SOAR services for PATH-enrolled individuals through local agencies funded by foundations, private donors, or businesses
  • Services such as medication management and résumé assistance for job preparation if that assistance is part of overall engagement efforts
  • Items to use for outreach and engagement to people who potentially meet PATH eligibility, such as bottled water, healthy snacks, mittens, hygiene kits, tents, and blankets
  • Utility security deposits, rent and rent security deposits, and rental application fees
  • Necessary household items essential to move into permanent housing, such as dishes, cookware, bedding, furniture, utensils, drinking cups, and bathroom supplies.
  • Survival supplies such as blankets, sleeping bags, or tarps for people enrolled in PATH.
  • Clothing such as pants, tops, jackets, socks, coats, and shoes.
  • Hygiene items such as soap, toothpaste, toothbrushes, and shampoo.
  • Non-perishable food items, such as canned meat, vegetables, fruit, or soup; bottled water; and Gatorade
  • Processing fees associated with documentation needed to apply for benefits
  • Bus passes (not discounts) for people enrolled in PATH
  • Cost of medication (including psychiatric), not discounts
  • HMIS licenses for PATH-funded staff
  • Rent and utilities for office space
  • Costs incurred for necessary office maintenance, janitorial services, repair, or upkeep of buildings and equipment that neither add to the permanent value of the property nor appreciably prolong its intended life, but keep it in an efficient operating condition
  • Copays or medical office visits for medical conditions

Assigning valuation to in-kind/non-cash match

  • The value assigned to donated supplies, equipment, and goods must be reasonable and cannot exceed fair market value of the supplies or equipment at the time of donation.
  • If any part of donated property was acquired with a combination of funding sources, only the non-federal share of the property may be counted as matching or cost sharing.
  • Rates for donated services must be consistent with those paid for similar work in the organization. When the required skills are not found in the provider’s organization, rates must be consistent with those paid for similar work in the labor market. Only the amount consistent with the function performed is allowable. For example, if a doctor serves as a receptionist, only the amount that would be paid for a receptionist is allowable as a contribution to match.
  • Fringe benefits consistent with those that would be paid by the employing organization that are reasonable, allowable, and allocable may be included in the valuation.

Unallowable forms of match

  • Federal funds
    • Community Development Block Grant
    • Community Mental Health Services Block Grant
    • Emergency solutions grants
    • Runaway and homeless youth grants
    • Rapid rehousing
    • Housing opportunities for persons with AIDS
    • Cooperative agreements to benefit homeless individuals
    • Grants for the benefit of homeless individuals
    • Continuum of care
  • Prohibited expenditures—support for emergency shelters, construction of housing facilities, inpatient psychiatric or substance use treatment costs, or cash payments to intended recipients of mental health or substance use services
  • Advertising and public relations costs that solely promote a nonprofit organization (examples: fundraising events, promotional items, activities to promote the organization)
  • Alcoholic beverages
  • Bad debts (including loss from uncollected accounts or claims) of the state or subrecipient
  • Entertainment costs (examples: social activities, tickets, meals, lodging)
  • Fines and penalties
  • Interest on borrowed capital
  • Selling and marketing costs

Housing maximum

PATH funds may be expended on allowable housing activities, per the statute in Title V, Part C of the Public Health Service Act (42 U.S.C. § 290cc-21), as amended, and Section 9004 of the 21st Century Cures Act (P.L. 114-255). Spending on housing-related activities must be kept at or below 20% of the total funds awarded. The amount spent for housing supports should be tracked separately to ensure that the maximum is not exceeded. This pertains to:

  • Minor renovation, expansion, and repair of housing.
  • Plans for housing.
  • Technical assistance in applying for housing assistance.
  • Improvement for the coordination of housing services.
  • Security deposits.
  • Costs associated with matching eligible individuals with appropriate housing situations.
  • One-time rental payment to avoid eviction.

Grant Enrollment, Application and Reporting System

The Wisconsin Department of Health Services uses the Grant Enrollment, Application and Reporting System (GEARS) to process contracts and reimburse expenses for local agencies. PATH providers submit monthly and final expenditure reports through GEARS. See reminders for accurate and on-time reports.

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