Audit Resolution is the follow-up process with grant recipients to ensure grantees take appropriate and timely action to address OIG (Office of Inspector General) audit findings of HAVA funds. After the OIG issues a final report, the EAC Grants staff will work with the audited agency to implement recommendations from the audit report and confirm the grantee has taken appropriate correction action. The result will be a management decision by the EAC that describes what the grantee has done or will do to address the findings. The resolution process will be complete when the EAC confirms all actions are resolved.
Program income is income you earn as a direct result of activities supported under the grant. For example, if you developed cyber security training materials with grant funds and charge your voting districts for them, the funds you receive in payment are program income. Net program income is the amount of income remaining after deducting the costs of providing the materials to voting districts, such as shipping costs. Program income must be reported in the Program Income section of the FFR on lines 10 L - O.
See also “Where do we report interest earned on the federal share?”
The state must follow its own laws and procedures regarding the distribution of grant funds when issuing a sub-grant but must also assure that the sub-grantee is aware of the limitations imposed by the federal grant. A state must follow its own law as to whether a cost sharing agreement is required, or some other form of grant agreement is needed. However, there should be some documentation that supports the transfer of these funds to the local governments, whether it be a certification by the governments that they will comply with the limitations or that the governments receive funds on a cost reimbursement basis after providing a request for the funds and proof that they were spent in accordance with the state and federal restrictions. OMB Circular A-102, Common Rule, 41 C.F.R. § 105-71.137, Sub-grants, covers the requirements for states that issue sub-grants of federal funds.
In addition to FAQs, the EAC publishes guidance on grant requirements such as reporting and closeout on our website: https://www.eac.gov/payments-and-grants/financial-progress-reporting
For additional guidance and general questions about EAC grants and HAVA, please email [email protected] or [email protected].
Yes, semi-annual, and annual reporting are required. Both a Federal Financial Report (FFR) and a narrative Progress Report are due for semi-annual and annual reporting cycles.
See “Reporting” for more information about the EAC’s reporting requirements.
The EAC considers requests for extensions on a case-by-case basis. Requests must be made in writing via email prior to the deadline of the required submission and should include an explanation for why the extension is needed.
A corrective action plan (CAP) is a step-by-step plan of action that is developed to achieve targeted outcomes for resolution of an identified problem or noncompliance. The EAC requires a CAP for grantees that are out of compliance with grant requirements (e.g. missed reporting deadlines).
The Consolidated Appropriations Act of 2020 authorizes the federal funds, titled “Election Security Grants” in the Act “to make payments to states for activities to improve the administration of elections for federal office, including to enhance election technology and make election security improvements.
The accompanying Congressional joint explanatory statement states, “Consistent with the requirements of HAVA, states may use this funding to: replace voting equipment that only records a voter's intent electronically with equipment that utilizes a voter-verified paper record; implement a post-election audit system that provides a high-level of confidence in the accuracy of the final vote tally; upgrade election-related computer systems to address cyber vulnerabilities identified through [Department of Homeland Security] or similar scans or assessments of existing election systems; facilitate cybersecurity training for the state chief election official's office and local election officials; implement established cybersecurity best practices for election systems; and fund other activities that will improve the security of elections for federal office.”
See “Post-Award Usage of Funds” for specific examples of allowable activities under HAVA.
Capital improvements to land, buildings, or equipment which materially increase their value require prior written approval from the EAC per 2 CFR 200.439. Without pre-approval, capital improvement costs are not allowable.
State allocations for mandatory grants under HAVA are calculated based on a formula established in the law that includes three steps:
- A minimum percentage is allocated to all states and the District of Columbia (½ of 1% of the appropriation) and the five territories (1/10 of 1%).
- The remainder is allocated based on the voting age population of each state in relation to the total voting age population of all states as reported in the most recent decennial census.
- If all states and territories do not receive the guaranteed minimum payment in HAVA ($1,000,000 for territories and $5,000,000 for the 50 states and the District of Columbia), funds are re-allocated from states above that minimum to states below the minimum to ensure all states and territories receive at least the guaranteed minimum.
The guaranteed minimum payment established in the law can be changed in appropriations language.