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]

Current System Gaps and Challenges

• What are the most significant service gaps today in the mental health and substance use treatment system in Texas? SDOH supports required to adequately address treatment needs. Patient access to a full continuum of care. Adequate funding for treatment of indigent populations. Gulf between MH and SUD, despite SUD being a MH diagnosis.

• Which populations or regions are most impacted by these gaps, and why? Indigent populations (funding for treatment and availability of services), pregnant women, mothers (need for specialized care and childcare), Spanish speaking and other marginalized groups (access to ESL care, access to culturally competent care)

• Where do you see the most significant breakdowns in the statewide continuum of care? Piecemeal approach to services and outcomes measures that only increase the piecemeal nature of funding. Wildly complex braid of funding sources required to keep a facility in operation. Heavy administrative burden with no capacity building funding.

• What policy or funding barriers most hinder statewide mental health and substance use treatment service delivery? Structure of fee-for-service grants, piecemeal and conflicting funding opportunities, loss of direct service funding to administrative bloat with “trickle down” award structures, lack of clarity on the role of LMHAs for specialty services, outdated and burdensome nature of CMBHS

• What do you believe are the fundamental causes of these challenges? Failure/Unwillingness to understand at the state level that failure to treat Texans’ behavioral health issues costs taxpayers exponentially in terms of law enforcement, hospital, jail, DFPS, etc. costs. Poor understanding of SUD and other behavioral health issues (you can fix a broken leg and then the leg is fixed, but you can’t “fix” heart disease anymore than you can “fix” lifelong behavioral health disorders, treatment and long-term social supports are required) Poor understanding of the landscape on behalf of HHS, extremely outdated and inefficient systems for both assessing the needs and tracking progress on awards, clunky fee-for-service processes.

Solutions and Innovations

• What models, programs, or innovations have you seen meaningfully improve access, outcomes, or efficiency? Cost-reimbursement grants requiring meaningful outcomes measures. Modernizing data infrastructure AND allowing providers to submit data outcomes from their own data systems without requiring duplicative state managed systems.  Prioritizing funding care providers with proven models, balancing that with funding novel models. Prioritizing funding a full continuum of care over piecemeal elements. Funding capacity expansion, or models that allow providers to consolidate common functions like training.

• What solutions do you recommend Texas consider adopting or scaling? All of the above.

• What funding or funding incentive structures are needed to support implementation or expansion? Capacity expansion, cost-reimbursement grants instead of fee-for-service.

Supporting Documentation and Additional Insights

• What data, examples, or evidence can you share to support your recommendations? Staff cost for administration of CMBHS, HHS authorization and  billing. Texas CAC model for funding.

• What have we not asked that you believe is important for the statewide behavioral health strategic plan and its implementation? 

Implementation Considerations

• What barriers might Texas face in implementing these reforms? How might they be mitigated? Inertia, stigma about substance use, concern about fraud if there’s not today’s extremely detailed service billing process, and a lack understanding of failing to treat as a significant waste of taxpayer resources on law enforcement response, hospitals, jails and prisons, and DFPS. Lack of understanding regarding the additional administrative costs of layering funding through multiple administrative agencies. Ensuring that this knowledge is un-ignorable may help.