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What is the match?. Purpose. To explain the non-Federal cost-share requirement – the “match ” – of the Hazard Mitigation Assistance (HMA) programs. To identify strategies a Subgrantee can use to meet the “match.” To describe the documentation for the non-Federal cost-share.
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Purpose • To explain the non-Federal cost-share requirement – the “match” – of the Hazard Mitigation Assistance (HMA) programs. • To identifystrategiesa Subgrantee can use to meet the “match.” • To describe the documentationfor the non-Federal cost-share.
Authorities • Hazard Mitigation Assistance Unified Guidance July 12, 2013 • 44 Code of Federal Regulations(CFR) 13.24
Acronyms DOB Duplication of Benefits HMA Hazard Mitigation Assistance FMA Flood Mitigation Assistance PDM Pre-Disaster Mitigation HMGP Hazard Mitigation Grant Program ICC Increased Cost of Compliance
Why this is important • Each Federal grant program requires a non-Federal match. • Failure to meet the match can jeopardizeFederal funding eligibility.
Definitions • Cost-Share – • Non-Federal Funds – Portion of the costs of a Federally assisted project not borne by the Federal government. Financial resources provided by sources other than the Federal government.
Ways to meet the cost-share • Cash. • In-kind. • Certain Federal funds allowed as non-Federal match. • ICC.
Cash match – the EASIEST way • Subgranteematches the cost-share using its own funds. • Examples of documentation: • Cancelled checks with invoices. • Proof of electronic funds transfers with invoices.
In-kind contributions • In-kind contributions are non-cash donations provided by non-Federal third parties. • These can be in the form of real property, equipment, supplies, labor, services and other expendable property.
In-kind (Continued . . . ) In-kind documentation includes: • Record of donor. • Dates of donation. • Rates + time tracking for staff + equipment. • Deposit slips for cash donations.
In-kind (Continued . . . ) • Documentationmustbe kept on file by the Grantee +Subgrantee. • Records must be maintained for three (3) years from the date of FEMA closeout of your last project associated with the specific disaster.
Examples of in-kind • A local attorney’s time to review the real property acquisition contract documents and conduct the settlements for the Subgrantee. • The normal cost of the attorney’s professional timedonatedto the project (based on her normal per hour or per settlement rate) is allowable as local in-kind cost-share.
Examples of in-kind (Continued . . . ) • A homeowner accepts 75 percent of the value of his home in cashand donates the rest of the appraised value to the project. • The remaining 25 percent donated value is allowable as a third party in-kind contribution.
Examples of in-kind (Continued . . . ) • The local hardware store donatesconstruction materials for a hurricane shuttering project. • The retail value of those materials is an allowable third party in-kind contribution.
Changes in guidance • There isno longer a limiton in-kind contributions for the non-Federal cost-share.
Certain Federal funds allowed as non-Federal match • Generally, non-Federal cost-share requirements may notbe met with funds from other Federal Agencies. • There are exceptions.
Examples of “Federal funds” • Federal funds that can be usedas the non-Federal cost-share: • U.S. Department of Housing and Urban Development (HUD)Community Development Block Grant (CDGB) funds.
Rule of thumbFederal funds as match • Federal funds used to meet a non-Federal cost-share requirement mustmeet – and be used for – eligible approved activities of both the Federal source program and the HMA grant program.
Increased Cost of Compliance (ICC) • Are costs associated with bringing the structure into compliance with the local flood plain ordinance.
ICC (Continued . . . ) • National Flood Insurance Program (NFIP) ICC claim payment from a flood event may be used to contributeto the non-Federal cost-share requirement. • Claim must be submitted within the NFIP timeframe. (Set by NFIP – 2 yearsfrom the date of claim)
ICC (Continued . . . ) • ICC coverage can be a part of a commercial/residentialNFIP policy.
ICC (Continued . . . ) • If the ICC payment exceedsthe required non-Federal share, Federal funding will be reducedto the difference between the cost of the activity and the ICC payment.
ICC (Continued . . . ) • ICC match can onlybe used for the following projects: • Elevation • Relocation • Demolition • Floodproofing
ICC (Continued . . . ) • Example: • If you received $10,000 for ICC then that $10,000 will be used as part of the non-Federal match, if used for the intended purpose. • If not used for the intended purpose, it will be counted as Duplication of Benefits (DOB).
ICC (Continued . . . ) • Policy holder must sign the insurance claim over to the Subgrantee. • Only the part of the ICC benefit that pertains to the project can be assigned. • The ICC benefit canNOTbe assigned to another individual.
Cost-share documentation requirements • The local match must be documented as reasonable+ allocable+ necessary. • And must complywith all Federal requirements + regulations. • The type of cost-share MUST be identified at the time of application.
Most important 3 takeaways • Several options to meeting the cost-share requirement: • Cash. • In-kind. • Certain Federal funds allowed as non-Federal match. • ICC. • Always documentyour cost-share. • No longer a limiton in-kind contributions.
Contact Jeffrey Giering jeffrey.giering@la.gov Tenesha Wilson tenesha.wilson@la.gov
For more information + to download materials from today’s seminar: gohsep.la.gov/outreach.aspx