Under HAVA (254(b)(1)(d)) and the Uniform Guidance §200.305(b)(7)(ii) / §200.332(a)(2,3), HAVA grantee requirements are passed through to subgrantees. Where subgrants are disbursed as advanced payments, the subgrantee is required to place their funds in an interest-bearing account and report any interest earned and expended to the grantee. The HAVA grantee must report subgrant interest earned and expended on their FFR as part of the cumulative amounts reported on lines 10p (Total Federal interest earned) and 10q (Federal interest expenditures) on the EAC custom FFR. Subaward interest activities should be detailed in the subgrant narrative section of the progress report. 

 

Additional regulatory considerations such as 2 CFR 200.305(b)(8) may be applied to subgrantees. More specifically, the non-federal entity (subawardees) must maintain advance payments in interest-bearing accounts unless certain circumstances are applicable. Circumstances per 200.305(b)(8) include: the entity receives less than $250,000 in federal awards per year, an interest-bearing account is not expected to earn interest in excess of $500 per year on federal cash balances, or other enumerated conditions. Interest earned up to $500 per year may be retained for administrative expenses. 

 

If one of the above-mentioned circumstances apply to the subgrantees who receive an advance payment of HAVA grant funds, then that subgrantee is not required to deposit that payment in an interest-bearing account. Be advised that if they do not meet the criteria of 2 CFR 200.305(b)(8), all awarded HAVA funds must be kept an interest-bearing account and monitored then reported as such. 

The SF-425 Federal Financial Report (FFR) should reflect all activities against the Federal award depending if you are reporting on a cash or accrual basis. Whether the grantee advances the payment, or provides it as a cost reimbursement-based award, reporting the subgrant expenses as they are incurred/approved provides an accurate reflection of the rate of spending on the award and abides by (2CRF § 200.502(a)).

Line 10.b (Cash Disbursements) and Line 10.e (Federal share of expenditures) should reflect the sum of all expenses including: direct costs for goods and services and approved reported subaward expenses.

Line 10.f (Federal Share of Unliquidated Obligations) should reflect the amount of outstanding dollars incurred by the grantee. For cash base reporting, 10.f reflects dollars incurred but not yet paid. For accrual base reporting, 10.f reflects dollars incurred but not yet recorded.

Please discuss any potential changes in reporting these expenditures on the FFR with the Grants Office in advance at [email protected].

The U.S. Election Assistance Commission (EAC), in collaboration with NIST, is initiating a process to publicly solicit, evaluate, and approve protocols used in end-to-end (E2E) cryptographically verifiable voting systems for conformance to the recently revised Voluntary Voting System Guidelines, Version 2.0. This workshop will be used to discuss the plan and further develop the protocol requirements and evaluation criteria. The date and time is Thursday, October 06, 1:00-5:00 pm and Friday, October 07, 2022 1:00–5:00 pm.