No. When an expense to the grant can also be allocated to non HAVA funding, allocation methodology should follow 2CRF § 200.405. Examples: Equipment that benefits both federal and non-federal elections or election office salaries where time is allocated to federal and non-federal activities. The EAC can help you make the determination to allocate funds appropriately, which should occur at the time of procurement.

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There is no one way to allocate costs and allocation methods will vary across states.  There are two scenarios in which states may need to allocate costs between the benefits to the HAVA grant and other state office activities;  (1) when purchasing equipment or claiming costs such as salaries under the grant during the grant period and, (2) when you purchase equipment you will use after the grant ends.  Allocation is done at the point of purchase.  EAC can help you make the determination during the grant to allocate the funds appropriately when you purchase the items.  As examples, if you buy equipment solely in response to the pandemic and use it during the 2020 election, you can allocate the total cost to the CARES grant because it is a reasonable and necessary cost to respond to the pandemic.  If you buy laptops for your staff and they will perform duties outside of the grant during the grant period, you need to allocate the costs appropriately.  Grantees typically allocate percentages of time spent on grant and non-grant activities.   

In general, as with equipment, states follow their own laws and procedures for using, managing, and disposing of unused supplies and should use residual supplies to support other federal grant activities before donating them to non-federally supported activities. However, this is not a requirement and states should set their own policies for disposition of unused supplies under the $5,000 aggregate threshold.

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