N E HSA Non Federal Share Pre Conf

8/13/2019 N E HSA Non Federal Share Pre Conf

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PRESENTED BY:BELINDA RINKER, JD

SENIOR ADVISOR, OFFICE OF HEAD START

Non-FederalShare

[email protected]

Play as Slide Show to Use Hyperlinks


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Definition of Non-Federal Share

Non-Federal Share:That portion of thetotal costs of the program provided by thegrantee agency in the form of in-kinddonations or cash match received fromthird parties or contributed by the agency.In-kind contributions must be provided

and cash expended during the projectperiod along with Federal funds to satisfythe matching requirements.


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Importance of Non-Federal Share

Non-Federal Share:

Is a condition of the grant award required by theHead Start Act and applicable regulations.

Represents 20% of the programs capacity toprovide high quality services to children andfamilies.

Reflects the extent to which the program isengaged with and supported by the community.

Supports associated Federal funds making upthe other 80% of the total grant award.


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Sources of Non-Federal Share

In-Kind:Property or services that benefit a grant supportedproject or program and are contributed by non-Federal thirdparties without charge to the grantee. In-kind contributions mayconsist of the value of real property and equipment and the

value of goods and services directly benefiting the grantprogram and specifically identifiable to it. In-kind match iscounted for the period when the services are provided or whenthe donated goods are received and used.

Cash Contributions:The grantee's cash outlay, which is

generated by the grantee or donated by a third party, and isexpended to fund allowable program costs. Cash match countstoward the non-Federal share requirement when expended, notwhen donated to or generated by the grantee.


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45 CFR 1301.20 b): The non-Federal sharewill not be required to exceed 20 percent ofthe total costs of the program.

Head Start Act

Sec. 640(b) Financialassistance extendedunder this subchapterfor a Head Startprogram shall notexceed 80 percent ofthe approved costs of

the assisted programor activities, exceptthat the Secretary mayapprove assistance inexcess of suchpercentage if the

Secretary determinesthat such action isrequired infurtherance of thepurposes of thissubchapter.


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Fiscal and Non-Federal Share Citations

45 CFR Part 74.23 Institutions of Higher Education, Hospitals, Other Non-Profit

Organizations, and Commercial Organizations

45 CFR Part 92.24 States, Local Governments and Indian Tribal Governments

Performance Standards All Grantees

Mostly 45 CFR 1301

Improving Head Start for School Readiness Act of2007 All Grantees

Mostly in Sec. 642


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Method 1: 80/20) Method 2: General Federal Funds x .25 =

Non-Federal Share $2,000,000 (Federal

Funds) x .25 =

$500,000 (Non-

Federal Share)

Total Grant =

$2,500,000

Federal Funds FederalShare = Total Grant

Federal Funds =Non-Federal Share

$2,000,000 .85 =

$2,352,941 -

$2,000,000 =$352,941 Use with a waiver or Non-

Federal share over 20%

Calculating Non-Federal Share


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Criteria for Acceptable Non-Federal Share

To be accepted, all cost sharing or matchingcontributions, including cash and third party in-kind, shall meet all of the following criteria: Are verifiable from the recipient's records;

Are not included as contributions for any other federally-assisted project or program; Are necessary and reasonable for proper and efficient

accomplishment of project or program objectives; Are allowable under the applicable cost principles; Are not paid by the Federal Government under another award,

except where authorized by Federal statute to be used for costsharing or matching; Are provided for in the approved budget; and Conform to other provisions of this part, as applicable.

45 CFR Part 74.23


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MaximizingNon-FederalShare

The correctbalance ofcreativity andallowability.

Develop a written data informedstrategy for generation and useof non-Federal share.

Leverage from existing sourcesof non-Federal share.

Identify and develop new non-Federal share opportunities. Local

National

Maximize non-Federal sharealready contributed.

Convert un-allowable donationsto allowable match.


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Limitations on Fund Raising

Fund-raising activities allow the program togenerate additional resources that the programwould not otherwise be able to afford using only itsHead Start grant funds.

PI-06-06: Fund-raising Federal Policies.

Fund raising and investment management costs.

Costs of organized fund raising, including financial

campaigns, endowment drives, solicitation of giftsand bequests, and similar expenses incurred solelyto raise capital or obtain contributions areunallowable. Cost Principles, Appendix B(17).
http://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2006/resour_pri_00106_051706.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part230/fiscal_far_2003_050206_b.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part230/fiscal_far_2003_050206_b.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2006/resour_pri_00106_051706.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2006/resour_pri_00106_051706.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2006/resour_pri_00106_051706.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2006/resour_pri_00106_051706.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2006/resour_pri_00106_051706.html


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Cost Principle Citations

2 CFR Part 220 Cost Principles for Educational Institutions

2 CFR Part 225 Cost Principles for State, Local, and Indian Tribal

Governments

2 CFR Part 230

Cost Principles for Non-Profit Organizations 48 CFR 31 Cost Principles for For-Profit Organizations


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Allowable Cost Requirement

Allowable Cost:Third party in-kind contributionsshall count toward satisfying a cost-sharing ormatching requirement only where, if the partyreceiving the contribution were to pay for them, theywould be an allowable cost. Allowable costs aredetermined by the tests of reasonableness, necessityand allocability as defined in Title 2 of the Code of

Federal Regulations (2 CFR 220, 2 CFR 225, and 2CFR 230), commonly called the cost principles.


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Allowable Non-Federal Share Costs

Allowable Cost:Third party in-kind contributions shallcount toward satisfying a cost-sharing or matchingrequirement only where, if the party receiving thecontribution were to pay for them, they would be an

allowablecost. Cash Contributions:The grantee's cash outlay, which is

generated by the grantee or donated by a third party, andis expended to fund allowableprogram costs. Cash matchcounts toward the non-Federal share requirement whenexpended, not when donated to or generated by thegrantee. Donations, non-Federal program income, local and state funds,

foundation grants, corporate contributions


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Elements of an Allowable Cost

Reasonable for the performance of the award. Allocable to the award. Conform to any applicable limitations or exclusions. For

example:

Use of Head Start funds to assist, promote or deter union organizing.Head Start Act, Sec. 644(e). Alcoholic beverages. 2 CFR Part 230, Appendix B(3).

Consistent with policies and procedures that apply to bothFederally funded and other activities.

Accorded consistent treatment.

Meet generally accepted accounting principles (GAAP). Not included as a cost or cost sharing for any other

Federally funded program. Adequately documented.

2 CFR Part 230, Appendix A(2)


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Reasonableness of Costs

A cost is reasonable if, in its nature or amount, itdoes not exceed that which would be incurred by aprudent person under the circumstances prevailing at

the time the decision was made to incur the costs. Generally recognized as ordinary and necessary.

Exemplifies sound business practices, arms length bargaining,complies with laws, rules, regulations and grant awards.

Whether the individuals involved acted in meeting theirresponsibilities with prudence under the circumstances.

Significant deviation from established practices of theorganization.



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Allocable Costs

A cost is allocable to a particular cost objective, suchas a grant, contract, project, service, or other activity,in accordance with the relative benefits received. A

cost is allocable to a Federal award if it is treatedconsistently with other costs incurred for the samepurpose in like circumstances and:

Is incurred specifically for the award.

Benefits both the award and other work and can be distributed

in reasonable proportion to the benefits received, or Is necessary to the overall operation of the organization,

although a direct relationship to any particular cost objectivecannot be shown.



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Non-Federal Share Areas to Document

ParentIn-homeActivities

Professionaland Medical

Services


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Adequate Documentation Resources

Values for recipient contributions of servicesand property shall be established inaccordancewith the applicable cost principles.

45 CFR 74.23 and 45 CFR 92.24

PI 12-02: Non-Federal Share Issues Non-Federal Share Narrative on ECLKC

Philadelphia Parent Child Center, Inc., DABDecision No. 2297, December 31, 2009.

Applicable Cost Principles and Appendices 2 CFR 220, 2 CFR 225, 2 CFR 230
http://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part92/45CFRPart92.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2012/resour_pri_002_021012.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://www.hhs.gov/dab/decisions/dabdecisions/dab2297.pdfhttp://www.hhs.gov/dab/decisions/dabdecisions/dab2297.pdfhttp://www.hhs.gov/dab/decisions/dabdecisions/dab2297.pdfhttp://www.hhs.gov/dab/decisions/dabdecisions/dab2297.pdfhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/financial-mgmt/budgets/Non-Federal%20Share.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2012/resour_pri_002_021012.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2012/resour_pri_002_021012.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2012/resour_pri_002_021012.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2012/resour_pri_002_021012.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/standards/PIs/2012/resour_pri_002_021012.htmlhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part92/45CFRPart92.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part92/45CFRPart92.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part92/45CFRPart92.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part92/45CFRPart92.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htmhttp://eclkc.ohs.acf.hhs.gov/hslc/tta-system/operations/fiscal/regulations/part74/CFR82107.htm


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Volunteers

Volunteer services furnished by professional and technical personnel,consultants, and other skilled and unskilled labor may be counted ascost sharing or matching if the service is an integral and necessary partof an approved project or program. Rates for volunteer services shall beconsistent with those paid for similar work in the recipient'sorganization. In those instances in which the required skills are not

found in the recipient's organization, rates shall be consistent withthose paid for similar work in the labor market in which the recipientcompetes for the kind of services involved. In either case, fringebenefits consistent with those paid that are reasonable, allowable, andallocable may be included in the valuation.

Volunteer services shall be documented and, to the extent feasible,

supported by the same methods used by the recipient for its ownemployees, including time records.

The basis for determining the valuation for personal services shall bedocumented.


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Donated Space

The value of donated space shall not exceed the fair rental valueof comparable space.

Established by an independent appraisal of comparable space

and facilities in a privately-owned building in the same locality.

By a certified real property appraiser.

The basis for determining the valuation for buildings and land

shall be documented.

For related parties, may not exceed depreciation or useallowance.


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Equipment

The value of donated equipment shall notexceed the fair market value of equipment ofthe same age and condition at the time of

donation.

The basis for determining the valuation for

equipment shall be documented.


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Supplies

Donated supplies may include such items asexpendable property, office supplies, laboratorysupplies or workshop and classroom supplies.Value assessed to donated supplies included in the

cost sharing or matching share shall be reasonableand shall not exceed the fair market value of theproperty at the time of the donation.

The basis for determining the valuation for materialshall be documented.


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General Documentation Principles

When recording in-kind contributions, documentthe following: Who is the source be able to demonstrate that the contribution is

from an acceptable (non-Federal) donor source.

Whatwas donated be able to demonstrate that what is beingclaimed as match has been used for program purposes.

How was the valuedetermined the donor should generallydetermine the value and it should be based on standard objectivesources rather than best guesses. Document the basisfordetermining value of personal services (wage comparison), supplies,equipment, and donated space (must be independent appraisal).

Who verifiedthe information identify a responsible party who isprepared to sign a verification that the information is true andcorrect.

Link to Head Start or Early Head Start program requirements.


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Remember To

Develop written non-Federal share policies andprocedures.

Use standard processes and forms for collecting

information about donations and volunteertime.

Make sure to determine fair market value ofdonated goods and services.

Familiarize all staff with requirements.

Verify accuracy, completeness andreasonableness.


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DocumentCarefully and Completely Budget EffectivelyMonitor Monthly

Managing Non-Federal Share


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Disallowance of Non-Federal Share

Funded Federal Share: $ 800,000 Non-Federal Share: 200,000 Total Grant Award: $1,000,000

Actual Federal Share Spent: $ 800,000 Allowed Non-Federal Share: 180,000 Actual Grant Amount: $ 980,000

Maximum Federal Share $980,000 x .80 = $784,000

If waiver in place, multiplier changes to reflect actual federal share.

Disallowance $800,000 - $784,000 = $16,000


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Waivers of Non-Federal Share

Grantees must actively seek to generate Non-Federal Share through in-kind donations andcash match.

Grantees facing challenges in generatingnecessary Non-Federal Share can submit awritten request for waiver (reduction) of Non-Federal Share. Can be submitted with the proposed annual budget.

May also be submitted during the program fiscal year. Waiver only applies to one budget period.

Waiver requests can be re-submitted for subsequent budgetperiods.


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Waiver Criteria

The lack of resources available in the community that mayprevent the Head Start agency from providing all or a portionof the Non-Federal contribution that may be required.

The impact of the cost the Head Start agency may incur in

initial years it carries out such program.

The impact of an unanticipated increase in the cost the HeadStart agency may incur to carry out such program.

Whether the Head Start agency is located in a communityadversely affected by a major disaster.

The impact on the community that would result if the HeadStart agency ceased to carry out such program.

Head Start Act, Sec. 640(b)(1)-(5)


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Questions and Comments

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