Matching Share
A. Purpose and Scope. This chapter sets forth the criteria and procedures for the allowability and evaluation of cash and in-kind contributions made by subgrantees in satisfying matching share requirements.
B. Definitions.
- Cash contributions. Cash contributions represent the subgrantee's cash outlay. Unless authorized by Federal legislation, outlays charged to other Federal grants or to Federal contracts or funds received from other Federal grants shall not be used as part of the subgrantee's cash contribution except as specified in the subgrant agreement.
- In-kind contribution. In-kind contributions represent the value of noncash contributions provided by the subgrantee. Only when authorized by Federal legislation may property purchased with Federal funds be considered as the subgrantee's in-kind contribution. In-kind contributions may consist of charges for real property, nonexpendable personal property, and the value of goods, and services directly benefiting and specifically identifiable to approved objectives of the grant-supported program.
- Grant costs. Grant costs are the sum of the allowable costs by subgrantee and the values of the cash or allowable in-kind contributions made by the subgrantee in lieu of cash to accomplish the objectives of the subgrant agreement during the grant period.
- Grant period. The grant period is the span of time stipulated in the subgrant agreement, usually twelve (12) months, during which all nonfederal share is contributed and during which all work to be accomplished under the terms of the agreement must be completed.
- Matching share. In general, matching share (or "cost sharing") represents that portion of total project or program costs not borne by the Federal Government.
C. Contributions. All contributions, whether cash or in-kind, will be accepted as an eligible matching share when such contributions meet all of the following criteria:
- Are verifiable from the subgrantee's records;
- Are not included as matching contributions for any other federally assisted program or any Federal contract (i.e., are not double counted);
- Are necessary and reasonable for proper and efficient accomplishment of approved grant objectives;
- Are incurred and contributed within the grant period;
- Are types of costs which are allowable under the "Costs" section of this manual;
- Are not paid by the Federal Government directly or indirectly under another assistance agreement unless authorized by Federal law to be used for cost sharing or matching;
- Are provided for in the approved subgrant agreement; and
- Conform to other provisions of this Manual.
D. Allowability. General principles for establishing the allowability of matching share are as follows:
- Although NPS and the SHPO prefer and encourage subgrantees to make required contributions in cash, either cash or in-kind contributions of goods, property, services, or combinations of these, can qualify for and meet matching share requirements when the criteria above are met and the contribution is made during the grant period. Cash contributions by subgrantees applied as matching share are to be treated exactly like Federal grant funds.
- In-kind contributions must be fairly valued and must be of such nature that, if the Federal share had been used to pay for the contribution, the subgrantee would have incurred an allowable cost. In-kind contributions are eligible only to the extent that they represent actual necessary costs for which Federal funds could be applied for project or program objectives. Any grant funds applied in excess of actual cost would constitute an unallowable project to the subgrantee.
- Following a grant approval, nonfederal share contributions of cash will be recorded as they occur. All in-kind contributions must be recorded in the ledger accounts as grant costs when the in-kind services performed or goods received must be maintained on a current basis. (Note: After-the-fact certification for personnel costs contributed by University subgrantees is allowable if documentation is prepared in accordance with OMB Circular A-21, Section J.6.)
E. Timing of Contribution. Matching share (as with costs borne by the Federal share) will not be allowable if contributed prior to the effective date of the subgrant award whether or not the cost would have been allowable if incurred after such date, unless the SHPO has given written approval in advance in accordance with Federal instruction.
F. Relationship of Costs of Grant Period.
- General. To be eligible for matching assistance, costs must have been incurred within the approval grant period, with the specific exceptions described above and elsewhere in this chapter. SHPO does not reimburse obligations regardless of when they are assumed; it reimburses eligible costs incurred during the NPS approved grant period. Costs incurred, or contributions of services made, or assets acquired prior to or subsequent to the grant period authorized by the SHPO, unless specified in the subgrant agreement, are not allowable.
G. Valuation of In-Kind Contributions.
- Valuation of volunteer services. Volunteer services may be furnished by professional and technical personnel, consultants, and other skilled and unskilled labor. Volunteered services may be counted as matching share if they are an integral and necessary part of an approved project.
- Rates for volunteer services.
- Each hour of volunteer service may be counted as nonfederal share if the service is an integral and necessary part of the approved work. Volunteer services charged to the grant must be such as will make a meaningful and desirable contribution. Volunteers must possess the required qualifications in the skill or profession involved, and must actually perform that specific work.
- Rates claimed for volunteer services must be consistent with those regular rates paid for similar work in other activities of the State Government. In those instances in which the skills required for the HPF-assisted work are not found in the State Government, rates used must be consistent with those paid for similar work in the labor market in which the subgrantee competes for the kind of services involved.
- If a volunteer performs services outside his profession or trade, this volunteer's time must be valued at the Federal minimum wage rate unless a higher rate can be documented as applicable and is approved by the SHPO. All such rates are subject to NPS field and audit review.
- The use of volunteer services must be documented by the same methods used by the subgrantee for its own employees.
H. Required supporting documentation for volunteer services. All volunteer services claimed as nonfederal share must be substantiated by time cards or records that are signed by both the volunteer and his supervisor, as required for all other employees of the subgrantee. Such records must show the actual hours worked and the specific duties performed. The records should also indicate the basis for determining the rate of the volunteer's contributions, and such documentation must be available for audit (see suggested record keeping form).
I. Valuation of donated expendable personal property. Expendable personal property includes such items as expendable equipment, office supplies, laboratory supplies, or workshop supplies. Values assessed to donated or contributed expendable personal property included as matching share must be reasonable and must not exceed the fair market value at the time of donation. The basis for determining the valuation must be documented and available for an audit.
J. Valuation of Donated nonexpendable personal property.
- The valuation of donated nonexpendable personal property shall not exceed the fair market value of equipment and property of the same age and condition at the time of donation.
- Donation of title. If the donor transfers title to the property, the amount allowable as matching share shall be determined as if the subgrantee had purchased the property and paid the fair market value of the property at the time of the transfer. (See suggested form).
- Donation for use. If only use of property is donated as a loan, the amount allowable as matching share shall be determined as if the subgrantee had rented the property and paid the fair rental value at the time of the donation. (See suggested record keeping form for equipment use)
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