American Rescue Plan Act: Medicaid HCBS Grants Questions and Answers

HCBS participants include people in one or more of the below groups:

• Individuals with intellectual and/or developmental disabilities
• Individuals with a serious mental illness
• Aging and older adults (generally age 65 or older, or age 55 and older for the PACE program)
• Individuals with physical disabilities

For the purposes of this grant, the HCBS population includes all Medicaid recipients with any indication that they use, or plan to use, HCBS services from one of the five Medicaid programs listed in the “Which Medicaid programs can the grant benefit?” section.

Grant funds may be used to support the following Medicaid programs:

• Children’s Long-Term Support
• Family Care
• Family Care Partnership
• IRIS (Include, Respect, I Self-Direct)
• Program of All-Inclusive Care for the  Elderly (PACE)

The grant program will direct new resources to some of the most pressing issues faced by Wisconsin residents who receive HCBS. Examples of eligible project activities these funds could support include:

• Supporting organizations and providers with workforce training and service delivery improvements as they recover from the impact of the COVID-19 pandemic.
• Developing and implementing specialized training for direct care workers and managers.
• Helping individuals with intellectual, developmental, and other significant disabilities find and retain work.
• Improving person-centered planning and implementation.
• Increasing specialized care, services, and engagement for individuals with dementia, autism, children’s long-term care needs, or persons with other disabilities.
• Expanding the use of technology and telehealth by assisting HCBS providers with supplies and equipment.
• Reducing disparities and improving access to a diverse and culturally competent pool of HCBS providers.
• Developing other innovative ideas to improve HCBS.
• Preparing educational materials—on public health and other topics—in accessible formats for individuals receiving HCBS.
• Promoting access to technology to facilitate human connection for individuals receiving Medicaid HCBS and their caregivers. Supporting quality initiatives that improve services and supports and increase community engagement.
• Funding recruitment and retention activities for direct service workers of Medicaid HCBS providers.
• Purchasing personal protective equipment and routine COVID-19 tests for direct service workers of Medicaid HCBS providers and people receiving Medicaid HCBS.
• Providing transportation services that enhance community integration.

This grant aims to improve HCBS in Wisconsin through funding projects that support these four target populations:

• Individuals receiving HCBS
• Families of individuals receiving HCBS
• HCBS providers
• Direct care workers of HCBS providers

Yes, only Wisconsin residents can benefit from this grant.

The following types of entities were allowed to apply for this grant:

• A provider whose work supports HCBS participants. Eligible provider types include: 
  • Community based residential facility (CBRF)
  • Residential care apartment complex (RCAC)
  • Adult family home (AFH)
  • Personal care agency
  • Supportive home care agency
  • Home health agency
  • Pre-vocational agency
  • Supported employment agency
• An MCO active with HCBS programs in Wisconsin
• An IRIS consultant agency
• A university whose work supports HCBS providers or participants
• An advocacy agency whose work supports HCBS participants
• An association whose membership comprises HCBS providers
• A local government agency whose work supports HCBS providers or participants

Entities not listed above may partner with an allowable applicant. The allowable applicant must be the lead entity and complete the application and any required follow up information.

The following were considered eligible providers for the purposes of this grant:

• Any provider that receives Medicaid funding to provide services to one of the five programs listed in the “Which Medicaid programs can the grant benefit” section would be considered eligible.
• If you are not sure if your organization provides Medicaid HCBS services or if it is Medicaid-funded, contact your funding administrator.

Grant funding can only be used to provide HCBS to people in eligible Medicaid programs. Any money requested should be for the Medicaid HCBS participants, not for any individuals who use private insurance or pay for services out-of-pocket. Within the application, you were required to account for the specific number of individuals in the HCBS system who will benefit from your grant-funded activities, as well as the specific number of people who will benefit outside of the HCBS system. This was to ensure that funding provides a strong benefit to HCBS participants or the overall system (participants, families, direct care workers, etc.). 

Example: You plan to provide training to all staff who serve HCBS participants. Some of those staff may serve non-HCBS clients as well, so there could be some benefit to those clients. As long as any staff or client receiving a benefit from the grant is directly affiliated with a Medicaid HCBS program, you can apply.

If a project will benefit non-Medicaid participants equally or more than Medicaid participants, applicants might have considered self-funding the portion of the project that would benefit non-Medicaid participants. Example: a 20-bed CBRF serves five people in Medicaid and 15 people with private pay. The $100,000 project will benefit all 20 residents equally. The applicant would need to self-fund $75,000 and request $25,000 in grant funding.

• If you are a Medicaid provider, you needed to provide a Medicaid ID number.
• If you are an entity that receives Medicaid funding to provide HCBS services but do not have a Medicaid ID number, you needed to share the contract organization and administrator contact information of the organization that provides your HCBS Medicaid funding and the contract organization’s tax identification number.
• If you are another eligible entity and do not have a Medicaid ID number, you needed to provide a tax identification number.

Examples of tax identification numbers include:

• Social Security number (SSN)
• Employer Identification Number (EIN)
• Individual Taxpayer Identification Number (ITIN)
• Taxpayer Identification Number for Pending U.S. Adoptions (ATIN)
• Preparer Taxpayer Identification Number (PTIN)

All applicants completed a pre-screening form on GrantsConnect, our online application portal. Refer to the “Application process” section below for more information. This determined eligibility before completing the application.

Project eligibility was based on guidance issued by the Centers for Medicare & Medicaid Services (CMS) in the CMS State Medicaid Director's Letter. We encouraged every applicant to review this letter to learn more about which projects are eligible. Of note:

• Page 19 (Appendix C) contains examples of Section 9817 of the American Rescue Plan (ARP) Activities to Support State COVID-Related HCBS Needs
• Page 22 (Appendix D) contains examples of Section 9817 of the ARP Activities to Support State HCBS Capacity Building and LTSS Rebalancing Reform
• States must use the federal funds attributable to the increased federal medical assistance percentage (FMAP) to supplement, not supplant, existing state funds expended for Medicaid HCBS. Find more information about supplanting state funds below.

Guidance on ineligible projects:

In addition to the guidance provided in the CMS letter, the following types of projects were considered ineligible per federal guidance or DHS:

• Building projects, including costs affiliated with building structures, leasing space for facilities, etc. 
• Room and board, including food
• Tickets for community activities
• Training for direct care staff (Using grant funding for required training for direct care staff which should be funded by Medicaid HCBS dollars would be considered supplanting and therefore ineligible.)
• Capital expenditures, including costs of assets that help create profits over long periods; money companies use to buy, upgrade, or extend the life of an asset; long-term investments; property, equipment (including accessible ramps), land, and furniture. 
• Projects not focused on Medicaid HCBS (The CMS Medicaid Director’s Letter states that funding could only be used to benefit Medicaid HCBS participants, their families, Medicaid HCBS providers, and their employees. Any project that was not mainly focused on one of the four groups was not eligible for funding.)
• Therapies available through Medicaid HCBS (Using grant dollars to fund therapies that are currently available and funded through Medicaid HCBS was considered supplanting and therefore ineligible)
• Wages for direct care staff (Using grant dollars to pay for wages for direct care staff who provide Medicaid HCBS services was considered supplanting and therefore ineligible. Incentive payments to recruit and retain home health workers and direct care staff were eligible expenses.)

Guidance on supplanting state funds:

As mentioned in the CMS State Medicaid Director's Letter, ARPA funding must be used to supplement—not supplant—existing state funds expended for Medicaid HCBS. A supplement adds to services or wages already funded through Medicaid HCBS. A supplant replaces Medicaid HCBS dollars already allocated for a service funded and administered through Medicaid HCBS. 

See below for a comparison of supplementing and supplanting using direct care staff wages already funded by Medicaid HCBS:

• Supplementing: Using grant funds to provide an incentive payment to recruit and retain direct care staff. The incentive payment is an addition to their current wage billed to and funded by Medicaid HCBS. This was allowable with grant funds.
• Supplanting: Using grant funds to pay direct care staff wages instead of billing them to and having them funded by Medicaid HCBS. This was not allowable with grant funds.

If your project was duplicative of one of DHS’ nine ARPA initiatives, it will likely not be awarded grant funding.

Background: Wisconsin’s commitment to home and community-based services (HCBS) received a boost, thanks to the American Rescue Plan Act (ARPA). An estimated $350 million in federal funding will help state residents who are elderly or have a disability receive much-needed services to allow them to live as independently as possible. This new funding supports improvements to Wisconsin’s HCBS programs that are unique to the needs and priorities of our residents. Nine strategic initiatives led by DHS and funded by ARPA represent much-needed investments to help our most vulnerable state citizens live their best lives and can be found on the DHS website.

• The first round of applications was open from August 11 to September 12, 2022.
• The second round of applications was open from February 21, 2023, to March 21, 2023.

The application was available on GrantsConnect, an online application portal. See Tips for Using GrantsConnect (PDF).

DHS provided various resources to support applicants throughout the application process, including:

• Two informational webinars, featuring:
  • Information about Round 2 | View the presentation slides (PDF) and watch the recording
  • Guidance for previous applicants on how to improve their application score from Round 1 | View the presentation slides (PDF) and the presentation companion document (PDF)
• Virtual office hours each Wednesday from 2–3 Central Time, February 22 – March 15, to answer questions about the grant process. 
• A Grants Opportunity Overview outlining general grant information
• Tips for Using GrantsConnect (PDF)
• Scoring Criteria (PDF)
• A dedicated email inbox where questions could be submitted: GrantsWIARPAHCBS@pcgus.com
• A call center with staff available to talk through any questions or issues, open from 8 a.m. – 4:30 p.m. Central Time. Call 833-660-2499.

• The upper funding request decreased from $2 million to $1 million.
• Any applications that were eligible in Round 1 but did not receive funding could reapply. All the original information remained in each application. Applicants, using the technical assistance available, could update each of the relevant fields to strengthen their application. 
• Applicants were limited to two (2) applications. 
• Additional guidance was developed about project eligibility, including supplanting Medicaid HCBS funds.
• We collected additional information in the application, including provider size and provider type (adult family home, personal care agency, etc.). 
• Applicants had the ability to upload community letters of support, if desired. 

A complete application package consisted of the following:

• Administration—Contact information, description of the organization, and diversity and inclusion practices.
• Project Overview—A project description, what the project will achieve, how the objectives will be met, and key personnel involved in the project work.
• Project Impact—A marketing strategy for outreach, who the project will serve, how the project will meet the needs of diverse populations, and partnerships (if applicable).
• Timeline—A detailed project timeline, including specific dates, key milestones, and deliverables.
• Budget—The total project cost, duration, and detailed budget.
• Evaluation—A logic model that illustrates how the project will be designed, implemented, and analyzed.
• Attestations—Signed attestation indicating that a program understands that this state-funded grant will not be adjusted beyond the indicated amount to account for additional expenses. Signing the attestation to accept this state-funded grant didn’t impact eligibility for other funding opportunities available through DHS.

Applicants had 30 days from when the application was released to complete and submit the application. Following the review, all applicants will be notified whether their application was selected for a grant award. This will occur by June 30, 2023, for the second round of funding. 

Applicants will be notified via email of the application decision. If selected to receive an award, grantees will have 10 days to log into their GrantsConnect account and complete the Award Notification Packet. It includes:

• Signing and uploading the Grant Agreement Form 
• Submitting W-9 information
• Providing banking information

Yes, applicants could submit up to two (2) applications, provided each application was for a different project.

Each organization should only have applied for their highest priority projects. Each application should have contained one project for the highest likelihood of being selected for funding.

Yes, you could apply for grant funding in the second round if your application was not funded in the first round. Before reapplying, you should have reviewed the Application Scoring Criteria (PDF) to look for ways you could improve your overall application score. Additionally, when reapplying from the first round, you could log in to your GrantsConnect account and revise your previously submitted application.

Because DHS wants to award grants to as large and diverse number of applicants as possible, it was unlikely that an agency who received a grant in Round 1 would receive a grant in Round 2 or that agencies will receive multiple awards. That being said, there was not a restriction from applying in Round 2. 

Each application will be scored according to the ARPA HCBS Grants Opportunity scoring system, shown below. For more information about application scoring, review the Application Scoring Criteria (PDF).

Extra credit is available if the project (up to five points per item):

• Is part of a governor’s appointed taskforce recommendation or part of the governor’s budget request.
• Has strong sustainability after the grant funding concludes.
• Will benefit underserved communities.
• Captures an innovative idea or concept.

As DHS reviews applications, Public Consulting Group (PCG), as the grant program administrator, may reach out to applicants on behalf of DHS for clarification if more information is needed. Therefore, it is important to make sure that your contact information in GrantsConnect is accurate and up to date.

PCG will send communication about the application, relay award notifications, provide support to applicants, and disburse payments.

Applicants can access assistance for logging into the GrantsConnect system by contacting the GrantsConnect support team. The team can be contacted through live chat or by submitting a ticket. In the Applicant Portal, click on the question mark icon next to My Account in the navigation bar. Then, select either Contact Support to submit a ticket or Live Chat to message a support team member.

See more Tips for Using GrantsConnect (PDF).

Applicants can locate their Medicaid ID or Secretary of State Business ID within the ForwardHealth Provider Portal. For help using the ForwardHealth Portal or finding your ID, visit the ForwardHealth Contact Information page.

If you serve Family Care members only, list the name of the managed care organization as the name of the contracting organization and the chief executive officer as the name of the contract administrator. Refer to the MCO contacts page for this information.

A provider agency may have several IRIS participants they are supporting and may be dealing with several different fiscal employer agents (FEAs).

If you:

• Serve Family Care members and also serve participants from IRIS and if you know the FEA, list that as the second contracting organization. Go to the FEA’s website to find their leadership team, usually under the “About” section. List one of those individuals as the contract administrator.
• Serve IRIS participants who have various FEAs, put “A number of IRIS participants” as the name of the contracting organization, and put the FEA webpage as the contract administrator.

Grant awards will range from $25,000 to $1 million. Awarded applicants will receive the full amount requested; DHS will not partially fund any awarded applicants. Applicants who request more than the maximum grant amount of $1 million will be rejected for requesting a excessive budget.

Successful applicants will receive an Award Notification Packet. In it, applicants will accept the grant, sign the Grant Agreement, share W9 information, and provide banking information. The Award Notification Packet must be returned within 10 days to receive grant funds.

PCG will submit funds on behalf of DHS to the bank account information included in the completed Award Notification Packet. Grantees must have a valid checking account to receive the ACH payment. 

Funding will be dispersed in two payments.

The first payment, which will be for half of the total award amount, will be disbursed to the applicant within one week of accepting the grant and uploading the additional documentation requested in the Award Notification Packet. Payment may be delayed if the banking information is entered incorrectly, for example, if two different routing or account numbers are provided or the account holder does not match the applicant’s name.

Throughout the grant program, grantees will submit quarterly reports. When a grantee has accomplished several key milestones and spent most of their first distribution payment, they can request payment of the second half of their award through the quarterly reporting process. More information about this process is listed below.

You can only spend funding on activities defined in the grant budget you submitted to DHS in the application. You must track detailed funding documentation and receipts. DHS may request document and receipts.

You should spend no more than 10% of funding on grant administration.

You must complete all grant work by September 2024.

Grantees are required to submit a quarterly report in GrantsConnect. View an example template of the quarterly report (PDF). A quarterly report summarizes progress made on the goals and outcomes of the original grant request. It details how your organization used the funds and the impact created in the community. The report also contains information on challenges or changes that may have occurred during the grant period.

Examples of questions and prompts grantees will report on include the following:

• What outcomes have been accomplished so far?
• What still needs to be accomplished?
• Have there been any changes to the original proposal? If so, what are the changes?
• Provide a brief budget showing how funds have been used to date.
• Provide a brief projected budget showing how you plan to spend funds in the future.
• Provide information on milestones that are accomplished, in progress, or not started.

Awardees are required to submit reports every quarter in GrantsConnect. Here’s the schedule:

Awardees should report information for the entire award period, not just for the current quarter.

Yes. PCG monitors awardees’ quarterly report submissions to check for adherence to the project plan, budget, and the grant program rules. Based on that monitoring, audits will be triggered in the following situations:

• When you request additional funding
• When you complete the project
• Certain project risks arise related to compliance, performance, finance, or reporting. These include:
  • You are behind schedule on project progress by three months or more unless you give a reasonable explanation
  • The expenditure documentation and milestone progress indicate that you are expending funds either significantly ahead or behind schedule
  • Spending is not in line with the approved project plan
  • Spending on any ineligible activities (building projects, room and board, wages for direct care staff, etc.)
  • Administrative expenses that are more than 10% of total grant award
  • Spending more than the approved budget for each milestone without prior DHS approval (spending may exceed the allotted total for each milestone by up to 20% of each individual milestone’s budgeted amount)
  • Inadequate or incomplete documentation to support expenditures (invoices, GL transaction listings, payroll reports) submitted with the quarterly report

Grantees should maintain documents like:

• Budgets
• Program reports
• Receipts for project-related expenditures
• Payroll information if project is funding bonuses, etc.

If a grantee does not meet the quarterly reporting or audit requirements, DHS may hold funds until reporting is current.

If you need to make any changes to your project plan, budget, or timeline, please submit a change form through GrantsConnect, You can access this by logging into your GrantsConnect account. This process facilitates transparency and accountability and ensures that modifications are properly reviewed and approved.

You do not need to submit small budget and timeline change requests for approval.

• Spending may exceed the allotted total for each milestone by up to 20%.
• A project can be up to three months behind schedule. If a delay   exceeds three months, you should give a reasonable explanation.

You should request additional funding on the quarterly report. You can request up to the full value of the remainder of your award. DHS will not grant additional funding beyond your approved award amount. When you request additional funding, you are required to upload documentation that verifies grant funding to date.

These grants do not require repayment. However, DHS may recoup funds if we determine funds were not expended according to the guidelines set by DHS.

If you spend less than your total award amount, you should   return any unspent funds to DHS or not request the full amount if all funding has not yet been distributed. DHS will not approve funding requests above your initial award amount.

Yes, these funds are taxable.