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.
Compliance
The allowability of this type of expense depends on the purpose of the database and the type of information stored. For example, a database that provides voters with information on campaign finance does not improve the administration of federal elections or otherwise meet the criteria for allowable activities under HAVA Section 101(b)(1), including voter education**. Since it is not an allowable cost under HAVA, expenses related to this type of database cannot be used as state match.
In some circumstances, the costs of a database may be allowed. If the database provides a central archive for historical election data and is used to support administrative activities such as post-election auditing, then the associated costs may be allowable and should be appropriately allocated based on the benefit to federal elections.
Grantees are encouraged to contact the EAC Grants Office ([email protected]) to confirm the allowability of specific database costs.
**HAVA Sec.101(b)(1)(C) states funds may be used for "educating voters concerning voting procedures, voting rights, and voting technology." While combating mis/disinformation can be considered voter education, it must focus on assisting the voter in exercising the right to vote.
The CARES Act is very specific about the use of the funds. They must be used “to prevent, prepare for, and respond to coronavirus, domestically or internationally, for the 2020 Federal election cycle.” The award instructions and EAC’s Guidance on Use of HAVA Funds for Expenses Related to COVID-19 provide many examples and answer questions about the use of CARES Act and other HAVA funds to address the pandemic. See the EAC website for the guidance at: https://www.eac.gov/electionofficials/guidance-use-hava-funds-expenses-related-covid-19.
HAVA, in Section 101(b)(2), specifically states that 101 funds cannot be used to pay costs associated with any litigation, except to the extent that such costs otherwise constitute permitted uses of a payment under this section. Therefore, they cannot be used to cover the costs of a lawsuit brought against an action the state takes such as moving a primary or changing voting processes. However, if the litigation pertained to a state's actions to mitigate the effects of the pandemic on federal elections and the litigation resulted in a judgement or order requiring the state to implement certain changes in their administration of those elections, the funds could be used to carry out those required changes
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?”
Interest earned on the federal share is reported in the Federal Interest section of the FFR on lines 10. p - r. We must track interest generated on federal funds separately, so we have dedicated the following lines:
10p. Total Federal interest earned
10q. Federal interest expenditures
10r. Remaining Federal interest to be expended (line p minus q)
Interest earned from depositing cash to meet match requirements is reported on lines 12a-12b of the FFR. We must track interest earned from state match separately, and have dedicated the following lines:
12a. State Interest Earned
12b. State Interest Expended
True program income is reported as part of the Recipient Share on Line 10(l) using the additive method identified in line 10. Program income earned from the state match is reported in lines 12c and 12d.
See also “What is net program income and how is it reported on the Federal Financial Report (FFR)?”