Election Officials

Frequently Asked Questions (FAQs) for Grants

HAVA Section 251, 101, 102 Funds Questions

Capital Improvements

Questions & Answers

Capital Improvements

Can a locality use HAVA funds to make modifications to a storage space in order to provide appropriate storage for voting equipment?

Generally, making modifications to a warehouse to store voting equipment is an allowable cost. However, this expense is not directly related to meeting any of the Title III requirements. Only Section 101 funds or Section 251(b) funds may be used for this expense. However allocability and cost reasonableness must still be considered. For example, if the warehouse modification will not be used exclusively for the purpose of improving the administration of Federal elections, only that percentage of costs associated with the administration of Federal elections can be charged to the HAVA grant. Similarly, it may be more reasonable to select a different warehouse rather then retrofit the current structure. 

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May HAVA Section 101 or 251 funds be used to purchase a building to be used for warehouse voting system equipment?

Generally, purchasing a warehouse to store voting equipment is an allowable cost. This expense is not directly related to meeting any of the Title III requirements. Thus, only Section 101 or Section 251(b) funds may be used. Factors such as allocability and cost reasonableness must still be considered in determining the appropriateness of the expense. For example, if the warehouse will not be used exclusively for the purpose of improving the administration of Federal elections, only that percentage of costs associated with the administration of Federal elections can be charged to the HAVA grant. Similarly, it may be more reasonable to rent a warehouse rather then purchase one. 

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Can HAVA Section 102 funds be used to buy, rent or improve a warehouse to store voting systems?

No. Section 102 of HAVA grants payments to States for the purpose of replacing punch card and lever voting systems not for the storage or warehousing of such equipment. 

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May HAVA funds be used to rent space to store voting equipment purchased to meet HAVA requirements?

Generally, renting a warehouse to store voting equipment is considered to be an allowable cost. This expense is not directly related to meeting any of the Title III requirements. Thus, only Section 101 or Section 251(b) funds may be used. Factors such as allocability and cost reasonableness must still be considered in order to determine the appropriateness of this type of expense. If the warehouse will not be used exclusively for the purpose of improving the administration of Federal elections (e.g., rental space would be used to house equipment other than voting systems that would be used in Federal elections), only that percentage of costs associated with the administration of Federal elections can be charged to the HAVA grant. Rental costs of buildings and equipment are covered by OMB Circular A-87.

Rental costs under leases which are required to be treated as capital leases under Generally Accepted 13 Accounting Principles (GAAP) are allowable only up to the amount that would be allowed had the State or local government purchased the property on the date the lease agreement was executed. The provisions of Financial Accounting Standards Board Statement 13, Accounting for Leases, determine whether a lease is a capital lease. The determination is based on factors such as if the lease transfers ownership of the property to the lessee by the end of the lease term; contains a bargain purchase option; the lease term is equal to 75 percent or more of the estimated economic life of the leased property unless the lease term falls within the last 25 percent of the total estimated economic life of the leased property; or the present value at the beginning of the lease term of the minimum lease payments excluding executory costs such as insurance, maintenance, and taxes to be paid by the lessor, including any profit, equals or exceeds 90 percent of the excess of the fair value of the leased property to the lessor at the inception of the lease.

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HAVA Section 251, 101, 102 Funds Questions

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