Section E: Match Requirements
In this section...
- Match Requirements for Acquisition, Rehabilitation, and New Construction
- Match Requirements for Supportive Services
- Match Requirements for Operating Costs
- Match Requirements for HMIS
|Activity||Acquisition, Rehabilitation, New Construction||Supportive Services||Operating Costs|
Track match requirements with the Match Worksheet in Supportive Housing Program Self-Monitoring Tools.
Match is a cash payment for acquisition, new construction, rehabilitation, the provision of supportive services (including HMIS) and operating costs. During the technical submission phase of the SHP application process, grantees are required to submit documentation of firm commitments for the cash match to cover acquisition, new construction and rehabilitation activities, as well as match for the first year of the grant term for operations and supportive services. For operations and supportive services, if the grant is more than one year, grantees must sign a certification that the cash match will also be provided in subsequent years. The form and content of this required documentation and certification are described in the technical submission application. Grant agreements will not be executed until this documentation is provided.
Match requirements are to be made by cash and paid by the end of each operating year. Grantees will be required to report on matching funds used in their APR at the end of each operating year. Cash match must be provided by the grantee or the entity that operates the project. While HUD will hold the grantee responsible for unmet match whenever a project sponsor actually operates the project, the grantee can protect itself by enforcing the requirement against the project sponsor to ensure that the match is provided. In that situation, the project sponsor’s cash source can be from itself, the Federal government, state government, local government or private contributions. It is important to note that some Federal sources of funding outside of HUD do not allow their funds to be used as match; grantees need to confirm with each source of funding whether the use of such funding for match purposes is permitted. The applicable requirements are found at 24 CFR 84.23 for nonprofits and 24 CFR 85.24 for government entities. Grantees can reference two published guides on this topic:
- The Corporation for Supportive Housing’s Financing Supportive Housing Guide; and
- AIDS Housing of Washington’s Combining Affordable Housing Funding Sources Guide.
These guides provide useful tools for grantees and sponsors blending different sources of funding to meet match requirements.
Grantees are required to list the sources and amounts of cash match in the Annual Progress Report at the end of each operating year. During monitoring, field offices review the supporting documentation on site or remotely.
You can find match requirements in the regulations at 24 CFR 583.145, in the statute at Section 11383, and in annual NOFAs and appropriate acts.
Match Requirement for Acquisition, Rehabilitation, and New Construction
SHP funds provided for acquisition, rehabilitation, and new construction must be matched by the recipient with an equal amount of funds from other sources. The cash source may be the recipient, the Federal Government, State and local governments, or private resources, including commercial mortgages.
The matching funds must be committed during the second phase, or technical submission, of the application process. The commitment must be in the form of a letter submitted on letterhead stationery, signed by an authorized representative and dated. Each letter must contain the name of the organization providing the cash resource; the amount; the type of activity for which the funds will be used (e.g., acquisition, rehabilitation, or new construction); the name of the project sponsor organization and/or the name of the project; and the date the funds will be available.
The application and technical submission budgets indicate that match compliance for acquisition, new construction and rehabilitation funding is based on the overall development costs of the project, not specific budget line items.
Match Requirement for Supportive Services
Beginning in the Appropriations Act for fiscal year 1999, Congress has required SHP grantees to match supportive services funding. The match provision applies to all recipients of SHP funds, regardless of whether the grantee originally received funds before the provision was instituted. SHP grantees can request no more than 80% of the total costs for the provision of supportive services in a project in their application for funding. Grantees must match the remaining 20% of the total costs with funds from other sources. All matching funds must be used for eligible service costs identified on the supportive services budget, and included in the application and/or the technical submission.
Match Requirements for Operating Costs
Beginning with grants made in the FY 2000 competition, SHP funds can be used to pay up to 75% of the operating cost in each year of the grant term. See the Match Worksheet in SHP Self-Monitoring Tools for guidance.
Resident rent and fees may be used to meet the cash match requirement for transitional housing, safe haven, and permanent housing providers (24 CFR 583.315(b)). However, match requirements must be met by funds used to cover costs associated with eligible SHP activities. If resident rents are used to fund ineligible SHP costs, then other sources must be used to meet the annual SHP match obligations.
If the program match obligation is met through other means, then resident rents can be used for other program costs, and may cover activities that are not eligible under SHP. For example, funds could be used to support administrative costs beyond those eligible under SHP. Note that resident rents are considered program income, and must be accounted for and reported appropriately on annual reports.
For more guidance on using resident rent, see Section K Calculating Resident Rents.
Match Requirements for HMIS
Cash match is actual dollar resources contributed and spent on eligible HMIS project costs by the grantee or project sponsor. Cash match must be actual money spent by the grantee or project sponsor. In order to understand the difference between cash match and leveraging dollars, leveraged resources are all those additional resources, both cash and in-kind, raised by the project (e.g., data analysis conducted by outside researcher). Leveraging includes cash match resources.
Activities related to the implementation and operation of an HMIS. These activities may be hard costs or consumable items, such as software licenses, hardware, and services, or they may be personnel-related costs, such as salary and fringe benefits.
Cash match documentation occurs during the technical submission process as well as the operation of the project. If a renewal project is not required to submit a technical submission, the match should be documented at the end of the program year. Documentation of cash match is required for Year 1 of all projects while only signed certification of cash match is required for any additional years. Project sponsors are required to maintain detailed fiscal records during each year of the project to ensure adequate documentation of all expenditures related to the grant, including those paid through the use of cash match sources.
Grantees or project sponsors are required to submit documentation of the source of the cash match (contracts, award letters, etc.) for Year 1 and indicate for which activities the cash match funds are being used. The documentation must indicate:
- The type of funds;
- Amount of available funds;
- Approved use of funds; and
- The time period the funds are available.
See Section I Grantee Responsibilities for more information on recordkeeping requirements.