No, for grant purposes the requirement for timekeeping applies to the grant overall, not to specific program categories within the budget. The state may have more specific timekeeping practices that allocate staff time for its own purposes.
Grantees must establish timekeeping practices for employees paid in part or in whole with federal funds or whose time is being allocated as match on the grant. The regulations at 2 C.F.R. 200 section 430 (i), Standards for Documentation of Personnel Expenses, provide general guidance on timekeeping. They indicate that charges to grants for salaries and wages must be based on records that reflect the work performed, be supported by a system that provides reasonable assurance that the charges are accurate and properly allocated to the grant, reflect the total activity of the staff person, not just the activity related to the grant, and be incorporated into the official records of the grantee.
Sections 107–110 of the C.F.R. describe Office of Management and Budget (OMB) and agency responsibilities related to reviewing and implementing the regulations in 2 C.F.R. 200. They apply to EAC and its grantees.
No. You can only use state expenditures incurred during the period of the grant as match. Only the portion that falls within the grant period can be used as match.
EAC has adopted 2 C.F.R. by policy and grantees acknowledge the regulations by reviewing and accepting the terms of the award as specified in the Notice of Grant Award.
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.