Discussion of Federal Head Start Performance Standards relative to non-Federal share
- 1. Non-Federal Share: Head Start Presented by Reginald Walker,
MBA Chicago, IL April 27, 2005 This document is confidential and is
intended solely for the use and information of the client to whom
it is addressed.
2. REFERENCED PERFORMANCE STANDARDS
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- 1304.40(d)(3) Programs must provide parents with opportunities
to participate as employees or volunteers
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- 1304.41(a)(3) Agencies must perform outreach to encourage
volunteers from the community to participate in the program
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- 1304.50(d)(2)(iv) Assist in recruiting volunteer services from
parents, community residents, and community organizations
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- 1304.52(b)(3) Current and former parents must receive
preference for employment vacancies for which they are
qualified
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- Sec. 1301.20 Matching requirements
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- Sec. 1301.21 Criteria for increase in federal financial
assistance
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- Sec. 1303.8 Waiver of requirements;
3. REFERENCED PERFORMANCE STANDARDS
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- Sec. 74.23 Cost sharing or matching
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- Sec. 92.24 Matching or cost sharing
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- OMB A-122, "Cost Principles for Non-Profit Organizations
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- OMB A-87, "Cost Principles for State, Local, and Indian Tribal
Governments
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- OMB A-21 Cost Principles for Educational Institutions
- 10. INFORMATION MEMOS/PROGRAM INSTRUCTIONS:
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- IM-HS-01-13: Budgeting for Partnerships between Child Care and
Head Start
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- IM-01-1105: Matching Requirements for American Indian/Alaska
Native & Migrant and Seasonal Agencies
4. DEFINITIONS 5. DEFINITIONS
- Total Costs = Costs incurred by a grantee, including in-kind
contributions.
- Matching Share = Costs that is the responsibility of the
recipient
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- Match may be cash or non cash (good and services)
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- Cash Contributions From anyNon Federal Source
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- Match must be expended during the project period
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- Cash match is countedwhen it is spent , not when its donated or
generated.
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- may be real property, equipment, goods and services
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- counted for the period when the services are provided
6. REQUIREMENTS TO QUALIFY FOR MATCH 7. GENERAL MATCH
REQUIREMENTS
- Head Start grants shall not exceed 80 percent of the total
costs of the program; and
- The non-Federal share will not exceed 20 percent of the total
costs of the program .
8. GENERAL MATCH REQUIREMENTS
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- Allowable: Meets the requirements of the applicable cost
principles;
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- Reasonable: Does not exceed what would be normally incurred for
a services or activity;
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- Necessary: Needed to carryout a service or activity; and
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- Allocable: Allocable to a cost objective, such as a grant,
contract, project, service, or other activity.
- The grant application must include budgets for the Federal and
non-Federal funds.
- The Financial Assistance Award (FAA) constitutes approval of
both the Federal and non-Federal budgets.
9. GENERAL MATCH REQUIREMENTS
- The 269 must indicate total Federal matching expenditures in
agreement with the approved budget.
- Matching expenditures reported on the 269 require the same
documentation as Federal expenditure
- Programs with indefinite project periods are required to
provide matching or cost-sharing on a budget period basis
- The 15% administrative cost includes federal and non-federal
share.
10. SPECIFIC REQUIREMENTS
- Verifiable from recipients records
- Not included in another Federally-assisted project
- Not paid for by any Federal dollars
- Meets other circular provisions
- Volunteer services must be integral and necessary;
- Labor rates must be compatible with rates in the organization
and/or labor market (including fringe benefits)
11. WAIVER OF MATCH REQUIREMENTS 12. WAIVER
- A waiver may be granted for full or portion of matching
requirements if any of the following exist:
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- The community lacks required resources
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- The impact of the cost the agency may incurred in initial
years
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- The impact of an unanticipated increase in the cost of the
agency
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- The agency is located in a community adversely affected by a
major disaster
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- The impact on the community would be negative if the agency
ceased to exist
13. VOLUNTEER SERVICES 14. VOLUNTEER SERVICES
- Volunteer services can be counted as non federal share ifallof
the following exist:
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- Service are a necessary part of the program
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- Labor rates are consistent with those paid by the program or
the local labor market for a similar function
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- Skills arent found in the organization
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- The work is controlled by the organization
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- The service performed must be measurable and material
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- The work must be documented
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- Signature, date of service and rate of pay of both the
volunteer and staff
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- Explanation of the service performed
- Volunteer services can be professional and technical personnel,
consultants, other labor
- Fringe benefits may be counted as non federal Share
15. VOLUNTEER SERVICES
- Examples of allowable volunteer services :
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- Time donated by community members, board, policy council, and
parents in management activities
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- The difference between a reduced rate or fee charged for goods
or services as opposed to the standard rate or fee
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- Time spent by parents working with their children in a Home
Base program (if the activities and time are written in the Home
Visitor plan)
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- The use of the parent's homes for programmatic purposes may be
valued
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- Center Based home visits and parent teacher conferences can be
allowed; (ifrequired by the performance standards)
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- Time parents spend working with their children on activities
outside the classroom is unallowable; however
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- Structured exercises in which the parent and child participate
can be allowable (if required by the program standards and if not
done at home)
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- Transportation costs is allowable, if not regularly provided to
the center
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- Transportation for medical services if required by the
performance standards
16. VALUATING DONATED PROPERTY 17. VALUATING DONATED
PROPERTY
- Property shall be value according to the recipient accounting
policies, consider the following:
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- Land and/or buildings shall not exceed the fair market value
established by an independent appraiser; and certified by the
recipient
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- Equipment shall not exceed the fair market value of equipment
of the same age and condition.
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- Loaned space shall not exceed the fair rental value of
comparable space
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- Loaned equipment shall not exceed its fair rental value
- If a third-party donates the use of equipment, or space but
retains the title, the contribution shall be valued as
followed:
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- For Grantees Subject to Part 92, The contribution shall be
valued at the fair rental rate of the equipment or space
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- For Grantees Subject to Part 74, The equipment or space shall
not exceed its fair rental value
18. LOANED EQUIPMENT OR SPACE
- If a third-party donates the use of equipment, or space but
retains the title, the contribution shall be valued as
followed:
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- For Grantees Subject to Part 92, The contribution shall be
valued at the fair rental rate of the equipment or space
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- For Grantees Subject to Part 74, The equipment or space shall
not exceed its fair rental value.
19. DONATED SUPPLIES 20. DONATED SUPPLIES
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- Laboratory supplies or workshop
- Supplies shall be reasonable; and not exceed the fair market
value
- Examples of allowable and Unallowable donated supplies
include:
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- Clothing donated to facilitate a program activity (e.g.
costumes for holiday plays) is allowable
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- Clothing to personally benefit the child or the family is
unallowable
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- Food used for programmatic purposes are allowable
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- Gifts from parents are not allowable
21. COMPUTATION OF MATCH 22. COMPUTATION OF MATCH
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- Assume that the Federal funds = $150,000
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- Total project costs are $187,500 ($150,000 + $37,500)
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- Non Federal Share = $187,500 X 20% = $37,500
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- Gross up the 20% match requirement to get the effective rate:
20%/80% = 25%
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- Multiply the effective rate by the amount of the Federal share
= $150,000 X 25% = $37,500
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- Non Federal Share = $37,500
23. COMPUTATION OF A DISALLOWANCE 24. COMPUTATION OF A
DISALLOWANCE
- Assume $187,500approved project cost($150,000 Federal funds +
$37,500 In-Kind)
- If $150,000 in Federal fundsare expendedand only $30,000 in
Non-Federal share is approved then theactual project costbecomes
$180,000 ($150,000 + $30,000)
- Federal share of the actual project cost is $144,000 ($180,000
X 80%)
- Difference between the federal share of the actual project cost
and the expended project cost must be reimbursed the federal
government as calculated below
Expended Federal Funds Based on Approved Budget$150,000 (Less)
Federal Portion of Actual Project Cost144,000 Refundable Federal
Grant$6,000 25. 10 COMMON ERRORS REGARDING NON-FEDERAL SHARE
- 1. Inadequate or no documentation;
- 2. Overvaluing the donation of goods or services;
- 3. Including items that would not be allowable costs;
- 4. Matching Head Start Program with other Federal Funds
- 5. Matching multiple grants with the same In Kind
- 6. Valuing donations that were purchased with federal
funds
- Counting items that are furnished for personal use; (food and
clothing)
- 8. Transportation by parents for personal convenience or
transportation of employee's children by the employee;
- 9. Not obtaining an independent valuation of donated land or
space
- 10. Including time spent by parents on activities in the
home.
26. 5 POINTS TO REMEMBER ABOUT ALLOWABLE NON-FEDERAL
- 1. Must be something that could be charged to Head Start;
- 2. Not used as a match for other grants;
- 3. Be adequately documented;
- 4. Value should be based on what it would have cost if
purchased; and
- 5. Base volunteer services on the nature of the service
provided.