Yes. HAVA Sec. 101(b)(1)(F) allows funding to be used for improving, acquiring, or modifying methods for casting votes (e.g. paper ballots). Under this section, costs associated with purchasing or printing ballot paper with new or additional security features, including ongoing or future acquisition, are allowable and fully allocable to HAVA.
Security
Insurance (including cyber insurance) is an allowable expense per HAVA 101(b)(1)(B) and 2 CFR §200.447. Costs must be allocated based on the benefit to the improvement of the administration of elections for Federal Office, per 2 CFR § 200.405 and HAVA 101(b)(1)(B). An allocation methodology representative to the benefit of federal elections should be included when allowing and allocating cyber insurance costs. An expenditure for cyber insurance should follow the limitations set by §200.447 as well as general allocation principles for HAVA grants.
For additional guidance on insurance please see the FAQ titled “May a state use HAVA funds to lease or purchase buildings or equipment?”
The Fiscal Year 2019 National Defense Authorization Act included a prohibition on federal agencies and federal grant recipients from procuring certain Chinese telecommunications and video surveillance equipment. The Section 889 restrictions went into effect on August 13, 2020, for federal grant recipients under a new section to 2 CFR contained in 2 CFR §200.216.
The prohibited telecommunications equipment is telecommunications equipment produced by Huawei Technologies Company or ZTE Corporation (or any subsidiary or affiliate of such entities). Additionally, video surveillance and telecommunications equipment produced by Hytera Communications Corporation, Hangzhou Hikvision Digital Technology Company, or Dahua Technology Company (or any subsidiary or affiliate of such entities) that is used for the purpose of public safety, security of 16 government facilities, physical security surveillance of critical infrastructure, and other national security purposes is covered equipment under Section 889.
Yes, this is an allowable expenditure and EAC encourages states and localities to explore this type of expenditure as an immediate way to augment cyber capabilities already in place.