Section 209 of HAVA states that EAC does not have the authority to issue any rule, promulgate any regulation, or take any other action which imposes any requirement on any state except to the extent permitted under a specific section of the National Voter Registration Act.  The regulations at 2 C.F.R. 200 are government-wide regulations for federal grants. They are not regulations issued or promulgated by EAC. EAC and its grantees are subject to these and other government-wide regulations.

If you want to claim indirect costs under the grant, you must submit an indirect cost rate proposal to EAC. EAC will then work with the indirect cost unit at the Department of Health and Human Services to review and negotiate an agreement with the state.

Yes, the funds can be maintained in the same account as long as you can distinguish between revenue and expenditures for each grant separately.

No, they are two separate grants and must be accounted for and reported to EAC separately.

Match to the federal funds by the state or by counties can be counted as match.  Any match the state requires from local jurisdictions can be counted toward the overall required state match, not just toward the funds dedicated to that jurisdiction.

In-kind match is always a contribution by a third-party.  Expenditures that the state incurs through its own budget are cash match.  Expenditures the state incurs, regardless of whether they were formerly paid for with federal funds, can be counted as state match as long as they are expended for activities within the approved budget for the grant (allocable to the grant).  E.g. The grant budget and narrative indicate the 2020 funds will be spent for activities in support of post-election auditing and cyber security upgrades to the voter registration system.  Costs the state covers for those activities can be used as match on the grant.