Additional guidance on calculating the value of match for COC projects

From: Harmon-Darrow, Aimee 

Sent: Thursday, June 12, 2014 10:22 AM
To: Bal CPD
Subject: Additional guidance on calculating the value of match for COC projects

The question of how to calculate the value of in-kind match was discussed during the monthly Financial Analyst call and further guidance was provided by the SNAPS office below.

Valuation:

Her responses to the questions standard language from the CoC Program AAQ.

HUD is publishing additional FAQs related to match in the next 2-4 weeks. The CoC Program Match Toolkit will be published late summer.

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Q: How does a recipient/subrecipient value volunteer hours for match in the CoC Program?. 

A: Under the Continuum of Care (CoC) program Interim Rule, there is not a fixed or standard hourly rate for volunteer hours.

In the case of supportive services provided by volunteers or interns, the recipient or subrecipient must have a written letter from the volunteer or intern documenting their commitment to provide assistance to the project. All volunteer or intern labor must be valued at a standard rate. Rates can be defined based on standard local professional wages associated for the task that the volunteer is providing, or volunteer wages can be defined at a generic rate such as $10 per hour.

According to the CoC Program interim rule (578.73(c)(3)), services provided by individuals must be valued at rates consistent with those ordinarily paid for similar work in the recipient's or subrecipient's organization. If the recipient or subrecipient does not have employees performing similar work, the rates must be consistent with those ordinarily paid by other employers for similar work in the same labor market. Before the execution of the grant, a memorandum of understanding (MOU) must be in place that documents the third party's commitment, the specific services to be provided, the profession of the persons providing the services, and the hourly cost of the services to be provided. The value of in-kind match must be documented in accordance with the requirements of Section 578.73 and OMB Circular A-87 or A-122, as applicable. In-kind match must conform also to 24 CFR Parts 84 and 85.

Per Section 578.73(a) of the CoC Program interim rule, the recipient or subrecipient must match all grant funds, except for leasing funds, with no less than 25 percent of cash or in-kind contributions from other sources. Recipients and subrecipients may count as match any cash or in-kind contribution that is expended on costs that would otherwise have been eligible to be paid for with CoC Program funds under Subpart D of the CoC Program interim rule, including supportive services. Donated services are considered "in-kind" match. While resources are being used as match under the CoC Program are required to be expended on eligible activities under Subpart D, resources that are considered leverage (and not also considered match) are not required to be used for eligible activities under Subpart D of the CoC Program interim rule and may instead be used to support any activity within the project provided by the recipient.

When the match is provided through an in-kind contribution, the recipient is required to secure written documentation of the match commitment prior to grant execution. For a contribution of in-kind services to count as match, the recipient must enter into a formal MOU with the agency providing the in-kind service and must establish a system to document the actual value of services provided during the term of the grant. A recipient may use a letter from the partner agency to document the commitment to provide the in-kind service in advance of executing a formal MOU, for instance, if the recipient wants to wait to execute an MOU until after receiving a notification of award from HUD. The MOU can be between a recipient or a subrecipient and another agency, but the terms must be described in the MOU.

Q: Valuing property/space wants to use as match in the CoC Program?

A: Value of buildings are to be made by source agency…may use tax assessor records or other documentation documenting value of building; space in a building may be prorated.

Recommended Elements of In-Kind Goods and Equipment Commitment

Written documentation of donation of in-kind goods should be provided on the source agency’s letterhead, signed and dated by an authorized representative, and should include the following:

<![if !supportLists]>·       <![endif]>Value of donated goods to be provided to the recipient for the project

<![if !supportLists]>·       <![endif]>Specific date the goods will be made available

<![if !supportLists]>·       <![endif]>The actual grant and fiscal year to which the match will be contributed

<![if !supportLists]>·       <![endif]>Time period during which the donation will be available

<![if !supportLists]>·       <![endif]>Activities that can be provided by the person or in, or with, the property or goods

<![if !supportLists]>·       <![endif]>The value of commitments of land, buildings, and equipment are one-time only and cannot be claimed by more than one project or by the same project in another year.