Leveraged Resources And Match
Where Are The Overall Requirements • Office of Management and Budget (OMB) Cost Principles – all recipient share cost must be compliant • ETA, Solicitation for Grant Applications (ETA,SGA) – sometimes have limitations/prohibitions for the programs, including required match/other stipulations • Regulations – required match • Grant Agreements can require match • 29 CFR 97.24 – States, local governments, and Indian Tribal Governments • 29 CFR 95.23 – All other entities
Where Are The Overall Regulations • OMB cost principles (as appropriate to the organization)
What Are Leveraged Resources • Recipient Share/Cost sharing = leveraged resources • Non-federal Match is a subset of the requirement
Why should I Care • Larger portion of ETA discretionary grants require leveraged resources • ETA, Senior Community Service Employment Program (SCSEP) Grants • H-1B Training Grants • High Growth • Community Based Grants • Youthbuild Grants • May or may not be added to WIA regulations • Government-wide regulations propose to eliminate
Responding to an SGA(solicitation for grant applications) • Read carefully to determine whether required: • Do NOT promise • to provide more match than is required. • Include any excess over requirement • As leveraged resources
Budgets – Federal Level • Only required match is shown on the federal SF 424 or 424a • Do not include leveraged resources on the SF 424 a • Amounts shown on these standard forms • Will be considered as match • If not met, may lead to disallowance or grant reduction
Proposal Narrative • Leveraged Resources • Discuss as response to SGA element/factor • Cover nature sources and amounts • Discuss this relationship in the budget narrative • But, never in the budget • For Match • In addition to the bullets above, • [Must] include on the SF 424a –budget form and budget narrative
Mandatory DOL, ETA financial status report • Leveraged resources data element • Required data element that must be reported on the quarterly and final status report on the accrual basis of accounting.
Required Match/Non-Federal Share • No administrative cost limit • If used for questioned cost cannot violate cost limitations • All contributions must be: • Spent on allowable program activities • Spent in accordance with cost principles • Comply with the SGA • Comply with any grant program restrictions/prohibitions • Cannot be both double counted • Charged to the grant and reported as match
Federal, State and Local Reporting Requirements • Local and/or subrecipient Reporting Requirements must include this data element • Grantee Sub Roll-up report • Administrative level • collection of the quarterly and final data • Subrecipient level • collection of quarterly and final data
Recipient Share – Two Types • Required Match – meets SGA, program and cost principle requirements as allowable cost • Non-Match Allowable under cost principles (Reasonable, necessary, and allocable – benefit is received) • Amounts above matching requirements that are available for the program that don’t meet the criteria for allowable program cost but meet cost principle requirements • Provided by grant or sub • Provided by non-sub partner • Could be other federal if provided by non-sub partner
At A Minimum • Grantees and subs should issue reporting instructions and a format for subs to report the required feeder data elements to complete the DOL, ETA reporting requirements. • Titled “recipient share” on the DOL reporting formats and reporting instructions • Grantees can require additional reasonable reporting
Categories of Leveraged Funds Cash (non-federal cash from the general fund or other donations/outside funding, staff time, space or equipment and any other costs not charged that otherwise qualify as allowable cost to the grant) 3rd Party In-kind Contributions • Equipment or space (requires valuation or goods or services)
What Are The Reportable Leveraged Resources • Any cost not charged to the grant that benefits the program and are allowable under the cost principles • How Do I Determine Cost that are chargeable?
Match/Leveraged ResourcesCash Contributions Grantee/Sub • Paid Staff Space Cost – • allowable square footage using consistency of actual cost incurred • allowable use of space – cost principles
Match/Leveraged Resources Cash Contributions cont. • Allowable occupancy, ownership, maintenance, improvements, allowable depreciation costs, less than arms length agreements (limitation) • Paid Staff time – allowable staff cost in accordance with the market in your area for these salaries and benefits • Use Cost of Equipment You Purchased • That has not been fully depreciated • Charge allowable depreciation cost
Match - In-Kind Contributions29 CFRs 95.23(c-h) and 97.24(b)(7) • Not paid by grantee or sub-grantee/partner • Requirements for determining value • At the time of donation • Reasonable, necessary and allocable • Must be documented
In-kind Valuation • Personnel Services • Individual performing regular job activity • Regular rate of allocable pay and fringes • Individual performing other volunteer services • Rates consistent with recipient pay for like work or • Rates of other local are pay for similar work in the local market area
Why Not Full Value of Property • Purpose of grant is for activities that: • Require the use of equipment and/or space for limited time • Purpose of grant is not for: • Acquisition of buildings, land or equipment
Records • Source documentation • Actual document trails • Books of account • Available for audit and review • Support for 3rd party contributions • Same as above • Verifiable from contributor’s records or records maintained by grantee • Documentation of methods used for valuation
ETA – 9130 Quarterly Financial Report • Recipient share required • Recipient share provided (all amounts in excess of required match, as well) • Recipient share remaining (sets to zero when match is met – never a negative amount) • Other federal share provided (above match requirement, split out other federal funds used in support of the project)
State Quarterly Reports • Additional breakouts are required • Follow federal reporting instructions • Staff discussion
Quarterly Progress Report • Describe how all match and leveraged resources are provided including those on the financial report and those which are not covered on the financial report.
Stand-In Cost • If you have disallowed cost by the DOL Grant Officer, you can request to have amounts above match “stand in” for disallowed costs. • Requests do not mean approval. • Must receive approval. • Site review may be conducted to verify.
Stand-in Cost • If the cost have not been reported, they will be unallowable to propose as stand in cost • If cost were not included in the pool if audited cost, they will be unallowable to propose as stand-in cost • If the funds when used will violate a cost principle, they are unallowable to propose as stand in cost • Cost proposed for stand in must be identifiable by funding stream and funding year and by the entity with the questioned cost…all respects, e.g., documentation, books of account, financial reports
Closeout • If required Match is not met • Like amount of grant dollars will be unallowable • Reduce allowable grant expenditures by short amount • Non-compliance may result in closeout Initial Determination and/or final Determinations • When Leveraged Resources not met • The DOL Grant Officer will determine the penalty • Less likely to be unallowable cost • May impact future funding opportunities