Non-Federal Share

Non-Federal Share

Match/Cost Sharing

While the term “match” and non-Federal share are used in the VR regulations, the process described in statute is “cost sharing.” As defined in 2 CFR §200.1, Cost sharing means the portion of project costs not paid by Federal funds or contributions (unless authorized by Federal statute). This term includes matching, which refers to required levels of cost share that must be provided.

See also 2 CFR §200.306 and 34 CFR § 361.60.

The VR program is administered through a Federal and State partnership, with the Federal government contributing no more than 78.7 percent of the total program expenditures. In recognition of this Federal-State partnership, each State must contribute a non-Federal share equal to at least 21.3 percent of total VR program expenditures (34 C.F.R. § 361.60(a)(1) and (b)(1)). By contributing the required non-Federal share through State-appropriated funds or other allowable sources, States are able to receive approximately $3.69 Federal VR dollars for every non-Federal dollar to pay for the costs of administering the VR program and, most importantly, providing critical services to individuals with disabilities, including individuals with the most significant disabilities, as they pursue employment.  

The matching requirement is a State requirement. In instances when a State has both a blind and general VR agency, determination of whether a State met the required non-Federal amount for total Federal funds received is assessed on a State basis. This means that both agencies should partner, when possible, to review State goals and measure progress.

The unobligated balance (the amount of Federal funds that VR agencies have not obligated to pay for contracts, services, activities, etc.) of authorized Federal funds that a grantee may obligate and expend in a subsequent FFY provided the grantee has met the matching requirements by the end of the FFY of appropriation as outlined in Section 19 of the Rehabilitation Act of 1973, as amended Rehabilitation Act and 34 CFR § 361.64.

Non-Federal share can only be credited as matching when obligated, in accordance with 34 CFR § 76.707, during the FFY of appropriation for an award. VR agencies must report all allowable non-Federal expenditures incurred under the VR program, regardless of the source of funding, even if the amount reported exceeds the amount of non-Federal share required to match the total Federal funds awarded. This information is necessary for RSA to assess whether the State has met its maintenance of effort requirement under Section 111(a)(2)(B) of the Rehabilitation Act and 34 CFR § 361.62.

Additionally, third-party in-kind contributions are not an allowable source of non-Federal share under the VR program and, therefore, should not be reported as non-Federal expenditures (34 CFR § 361.60(b)(2)). Program income cannot be used to meet the non-Federal share requirement 34 CFR § 361.63(c)(4).

Non-Federal share expected from third-party cooperative arrangement (TPCA) certified expenditures of public agency staff salaries, when the TPCA staff has not yet completed the work, may not be included as an unliquidated obligation (or expenditure) because these expenditures cannot be certified until after the staff works the requisite number of hours. Pursuant to 34 CFR § 76.707(b), an obligation for services performed by State agency employees, including TPCA staff, is incurred at the time the work is performed.

All non-Federal expenditures and obligations used for match purposes must be incurred during the FFY of appropriation. The VR agency must liquidate all unliquidated obligations reported as having been incurred by the end of the FFY of appropriation but not liquidated by that time. All unliquidated obligations reported for match purposes, incurred prior to the end of the FFY of appropriation, must be liquidated within the liquidation for that award (i.e., 120 days after the end of the period of performance, regardless of whether the award qualifies for carryover). Allowable unliquidated obligations incurred during the FFY of appropriation that are cancelled during the carryover period, or otherwise not liquidated after the FFY of appropriation, may not be used toward satisfying the match requirement for the FFY of appropriation for that particular award because those obligations never came to fruition for the VR program.

Resources

Technical Assistance Circular, RSA-TAC-23-01, Allowable Sources of Non-Federal Share for the State Vocational Rehabilitation Services Program 

Carryover of Federal VR Grant Funds

Non-Federal Share and Carry Over Requirements - SE-A and SE-B 

Non-Federal Share/Carry Over - CAP, PAIR, IL-OIB

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Maintenance of Effort

Maintenance of Effort (MOE) outlines a grantee’s administrative requirement to maintain a specified level of non-Federal expenditures (effort) to avoid a reduction levied against a future Federal grant.

VR agencies must report all allowable non-Federal expenditures incurred under the VR program, regardless of the source of funding, even if the amount reported exceeds the amount of non-Federal share required to match the total Federal funds awarded. This information is necessary for RSA to assess whether the State has met its MOE requirement.

For purposes of the VR program, a State must report all non-Federal expenditures in the FFY in which those expenditures are incurred for purposes of satisfying the MOE requirement because MOE is determined on an FFY basis, not on the basis of a period of performance for an entire grant award.

Non-Federal obligations and expenditures incurred during the carryover year do not count toward the prior FFY of appropriation’s match requirement but will count toward the current FFY’s MOE requirement.

Non-Federal expenditures for the purpose of establishing a facility for a community rehabilitation program (CRP) will not be counted toward the State’s MOE (34 CFR § 361.62(b)); however, these non-Federal expenditures, if obligated or liquidated within the period of performance, count toward satisfying the State’s match requirement. Additionally, Non-Federal expenditures for the purpose of constructing a facility for a CRP will not be counted toward the State’s MOE (Section 101(a)(17)(C) of the Rehabilitation Act and 34 CFR § 361.62(b)).

MOE waivers, allowable under 34 CFR § 361.62, are requested for an amount of non-Federal funds to be waived, it is not a waiver of the entire requirement. In order to sufficiently determine the amount of funds requested in a waiver, grantees must wait until the end of the period of performance of an award, due to the fact that obligations satisfy the non-Federal share requirement. Only after all expenditures have been completed can the grantee adequately determine the amount of funds necessary to request via the waiver.

MOE waivers may be requested when a State VR agency has a decrease in non-Federal funding due to exceptional or uncontrollable circumstances, such as a natural disaster or serious economic downturn.

Resources

4.13.21 RSA MOE Presentation 

MOE Penalty Change Announcement

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