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HRT - 01461

Wednesday, September 20, 2023
Manufacturer
Impacted Device/System

VerityVoting 2.5 Devices: Controller, Print, Scan, Scan w/Relay, Touch, Touch Writer, Touch Writer Duo, Touch Writer Duo Standalone

Date Approved by EAC
03/23/2021
Short Description of Changes

This ECO modifies the device Operating System procedure to create the pagefile.sys file on devices in Verity Voting 2.5 after the Unified Write Filter (UWF) is applied.

Yes, once we determine the award amount that is to be returned to EAC, we will adjust your next FFR to reflect the decrease in federal award and the required match will be applied according to the updated federal award

 

Yes, your minimum required state obligations is based on your total federal expenditures. At closeout, if you have not expended the full amount of federal funding available, your state obligation would be reduced accordingly. 

See also "I received a debt collection letter, why am I getting this?"

Yes, unexpended federal interest earned on an EAC grant must be returned to the agency. Grantees may retain up to $500 of the unexpected federal interest for administrative costs where subgrants were awarded with the federal funds.

For annual and mid-year reports you should have this content ready for reporting. For the final report, you can summarize the data in the narrative and supplement later with an inventory list as part of the closeout process.  You can state that you intend to do that within your response.

When you log into Alchemer, select 'final report' and the system will populate with the additional fields you need to complete for the final report. 

Keep in mind that this final report should cover the full period of the grant and describe the accomplishments during the entire grant period for each required question.  Do not limit the response for any of the questions for this report to the last fiscal year. 

Full reporting guidance can be found on our website: https://www.eac.gov/payments-and-grants/financial-progress-reporting

Generally, states are required to follow their own laws and procedures for using, managing and disposing of equipment during the grant period. Absent state procedures you can find the minimum requirements in 200.313 for managing equipment (including replacement equipment), whether acquired in whole or in part under a federal award, until disposition takes place.

Property records must be maintained through the life of the property that include:

  • a description of the property,
  • a serial number or other identification number,
  • the source of funding for the property (including the FAIN),
  • who holds title,
  • the acquisition date,
  • cost of the property,
  • percentage of Federal participation in the project costs for the Federal award under which the property was acquired,
  • the location,
  • use and condition of the property,
  • Status of the property including any ultimate disposition data including the date of disposal or sale price of the property.

If states subgrant funds, they must ensure their subgrantees follow the requirements at 2 CFR 200.313 for equipment which provide the parameters for equipment inventories.  This is a long-standing requirement under federal grants. At closeout, grantees inform EAC how any remaining equipment will be used once the grant closes.

No, however states are responsible for ensuring proper accounting and disposal of subgrantee equipment purchases. States are not required to submit inventories from their subgrantees to EAC, but states must oversee equipment purchases by their subgrantees and coordinate their disposition with EAC when the grant ends. States will submit inventories to EAC for equipment the state agency bought for its own use, but only for equipment that still has a current per unit fair market value over $5,000. For subgrantees, states follow the regulations at 2 CFR 200.305 which describe the requirements for managing and disposing of equipment. At closeout, states should request an inventory of equipment with a current fair market value over $5,000 from each subgrantee and determine how those subgrantees will continue to use and maintain the equipment. If the subgrantees are not going to continue to use the equipment for HAVA purposes, contact EAC to determine disposition of the equipment. If subgrantees will continue to use the equipment for election purposes, states will certify that subgrantees have met all financial and programmatic requirements under the grant and that equipment will continue to be used for HAVA purposes. 

See also "What is the process for equipment inventory?"

Fair market value is what a reasonable third party would be willing to pay. The resale value is the same as fair market value. We would expect the resale value to be less than what the jurisdiction originally paid for the supplies unless there is an extreme shortage and high demand, but you should not assume that the value would be reduced without doing some documented market research. 

You can access online reseller resources to determine fair market value and document your methodology.  You could also provide guidance to your counties to access online resources, e.g.  Amazon, eBay or other reseller marketplaces, to see what the unused supplies they have are selling for on the open market.

At closeout, states only need to provide an inventory list for any equipment that has a current fair market value over $5,000. If states subgrant funds, they are responsible for providing oversight for the inventory and usage of equipment at the subaward level prior to certifying their closeout.

The regulation at 2 CFR 200.33 defines equipment as tangible personal property (including information technology systems) having a useful life of more than one year and a per-unit acquisition cost of $5,000 or a lesser amount if the state has a lower threshold. 

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