April 17, 2026
Quick recap
The meeting focused on challenges facing behavioral health providers, particularly regarding increased scrutiny from HHSC and funding issues. Providers discussed experiencing more detailed audits and questions about their match reports and in-kind donations, with several organizations reporting difficulties with quarterly reporting processes. The group extensively discussed the decline in residential treatment services, citing low payment rates compared to outpatient services and the closure of detox programs as contributing factors. Providers shared experiences with Medicaid billing challenges, including low payment rates and denial issues, with some organizations achieving only 57% collection rates on billed amounts. The conversation also covered the impact of buprenorphine prescriptions being provided in emergency rooms, which has reduced referrals to residential treatment programs. The conversation ended with a discussion about implementing a new online platform for member communication and feedback collection regarding service gaps and challenges.
Over the years, our auditors make sure that we follow federal regulations as published in the Uniform Grant Guidelines. We are very careful to document as follows:
Donated goods and materials fall under the Uniform Guidance’s treatment of “in‑kind contributions” and are primarily addressed in:
2 CFR § 200.306 – Cost Sharing or Matching
2 CFR § 200.434 – Contributions and Donations
Under the Uniform Guidance, donated goods and materials (for example, supplies... provided at no charge) are treated as third‑party in‑kind contributions.
Donated goods and materials can be counted only if all cost‑sharing conditions are met under 2 CFR § 200.306(b). Specifically, the contribution must:
Be verifiable in the recipient’s records
Not be counted toward another federal award
Be necessary and reasonable for accomplishing the project objectives
Be allowable under the cost principles in Subpart E
Not be paid by the federal government under another award
Be included in the approved budget when required
Conform to all other applicable provisions of Part 200
Donated goods and materials must be valued at their fair market value at the time of donation—that is, what a willing buyer would pay a willing seller in an arms‑length transaction. The recipient must use the same valuation methods it uses for its own purchased goods, ensuring consistency and auditability. [govinfo.gov]