American Rescue Plan Act: Funding Awards and Project Period Details
The American Rescue Plan Act awards funds for various OAA activities under Title III.B, C1, C2, D, E and Title VII Ombudsman Project from April 1, 2021, to September 30, 2024. The grants have specific end dates, and fiscal flexibilities are available for ARP Title III and Title VII grants during the incident period. State Plan Administration details how funds can be managed cumulatively based on grant types.
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American Rescue Plan Act Awards funds: Title III B, C1, C2, D, E Title VII Ombudsman Project period: April 1, 2021 - September 30, 2024 Funds are to be used on any allowable OAA Activities 1
Project Period End Dates Grant Name Project Period End Date without No-Cost Extension Project Period End Date with No-Cost Extension FFY2019 Title III, Title VII & NSIP 9/30/2020 FFCRA (CM/HDC2) CARES Act (SS/HD/FC/OMC3) FFY2020 Title III, Title VII & NSIP 9/30/2021 FFY2021 Title III, Title VII & NSIP 9/30/2022 Supplemental 5 Nutrition (HDC5) Expanding Access to COVID-19 Vaccines via the Aging Network (VAC5) ARP (SS/CM/HD/PH/FC/OMC6) 9/30/2021 9/30/2022 9/30/2022 9/30/2022 Not yet available to request Not yet available to request 9/30/2021 9/30/2021 9/30/2022 9/30/2022 Not yet available to request 9/30/2024 Not yet available to request 2
Fiscal Flexibilities Presidentially Approved Major Disaster Declaration for COVID-19 under the Stafford Act MDD Fiscal Flexibilities are available to ARP Title III and Title VII grants during the incident period Flexibilities are not related to any State or Local declared emergencies If States obligate funding under the MDD flexibilities, those flexibilities are available until the obligation is liquidated or the obligation period ends States must adhere to the project period end dates Public Health Emergency for COVID-19 as Declared by the U.S. Secretary for Health and Human Services 100% transfer between C1 and C2 for ARP funding 3
State Plan Administration State Plan Administration: Cumulative 5% or $750,000 5% of the cumulative total of all the regular FFY2021 Title III grants + Supplement 5 + the Expanding Access to COVID-19 Vaccines via the Aging Network grant + the ARP grants OR $750,000 for States or $100,000 for Guam, American Samoa, Virgin Islands, Northern Mariana Islands cumulative between FFY2021 Title III grants, Supplement 5 (HDC5), the Expanding Access to COVID-19 Vaccines via the Aging Network grant, and the ARP Allowable funding may be calculated as indicated above; however, State Plan administrative funds may be expended from any part or parts of the regular FFY2021 Title III grants, Supplemental 5 (HDC5) and/or the ARP grants 4
Area Plan Administration Area Plan Administration: 10% 10% of the cumulative total of all the regular FFY2021 Title III grants plus Supplement 5 (HDC5) plus the Expanding Access to COVID-19 Vaccines via the Aging Network grant plus the ARP grants Funding may be calculated as indicated above; however, funds for Area Plan administration may be expended from any part or parts of the regular Title III grants (except for Part D), Supplemental 5 (HDC5), and/or the ARP grants 5
Equipment Prior Approval Equipment purchases made by a direct grantee (i.e., SUA) exceeding $5,000 must receive approval from ACL prior to purchase A sub-grantee (i.e., AAA) of an SUA must receive prior approval from the SUA for equipment purchases exceeding $5,000 ACL does not provide prior approval to subgrantees of the SUA SUA s should have policies and procedures on the State s prior approval process for subgrantees 6
Match Requirements B* C1 C2 D E State Plan Admin Area Plan Admin 15%** 15%** 15%** N/A 25% 25% 25% FFY 2019, 2020, 2021 T3 (OASS/CM/HD/PH/FC) FFCRA (CMC2 and HDC2) CARES Act (SS/HD/FCC3) Supplemental 5 - HDC5 N/A N/A 25% 25% N/A N/A N/A 25% 25% N/A 25% 25% 15%** 15%** 15%** N/A 25% 25% 25% ARP (SS/CM/HD/PH/FCC6) N/A N/A N/A Expanding Access to Vaccines (VAC5) * No match required for the portion of funds used to support the LTCO program **1/3 of 15% of match for services must come from State sources 7
In-Kind Contributions Non-Federal share (Match) may include cash, expenditures by the grantee, and third-party in-kind contributions. Funds and Expenditures used to Match OAA funds must not conflict with Older Americans Act requirements and Regulations. To be used as Match, in-kind contributions must be from a third-party, verifiable and the records must show how the value of the in-kind contribution was determined. That valuation must be reasonable, subject to audit, and meet the requirements at 45 CFR 75.306 8
Examples of In-Kind Contributions volunteer services (a reasonable hourly rate applied to a volunteer s time multiplied by the number of hours he/she works). For example, advisory/grievance council members, kitchen help, servers, receptionist, HDM drivers; donated time of employees from other organizations (salaries or positions must not be supported by Federal funds); unpaid interns or fellows; donated supplies and loaned equipment; donated food from food banks, etc.; donated utilities; donated or discounted space; transportation services to and from nutrition sites, medical appointments, shopping trips, etc. provided from non-Federal sources. 9
Program Income For the ARP Title III grant only, program income generated as a result of the ARP Title III grant may be used to meet match requirements Program income may only be used to meet the match requirement of the federal award in which the income is generated If a State elects to allow program income as match, SUAs should develop clear policies and procedures to account for and document program income used as match for the ARP grants States will be required to report how much program income by grant award number is used to meet match requirements 10
Transfers Grant Name B/C (30% max*) 8/16/2021 C1/C2 (100%**) 8/16/2021 FFY2021 Title III (2101XXOASS/CM/HD) FFCRA (CMC2/HDC2) CARES Act (SSC3/HDC3) Supplemental #5 (HDC5) ARP (SSC6/CMC6/HDC6) Expanding Access to COVID-19 Vaccines via the Aging Network (VAC5) 8/16/2021 8/16/2021 8/15/2022 8/15/2022 *30% maximum transfer, a waiver is required to exceed 30% transfer limit **For FFCRA and ARP, 100% transfer C1/C2 available until the end of the COVID-19 public health emergency or transfer due date, whichever is sooner; then returns to 40% maximum transfer, a waiver is required to exceed 40% transfer limit up to 50%. For FFY2021 Title III, 100% available until transfer due date, end of COVID-19 public health emergency does not impact due date. 11
Fiscal Reporting SF425 Due Dates Extended to July 31, 2021 for reporting period ending 3/31/2021 Regular Title III, Title VII, and NSIP grants FFCRA CARES Act Supplemental 5 (HDC5) NSIP Must start collecting NSIP meal counts starting 10/1/2021 2022 Grant Award Allocation will be based off of hold harmless 2019 meal count numbers 12
Distribution of Funding After any funds have been distributed to expedite COVID-19 emergency response as described in the Expediting Expenditures at the State Level in Responding to the COVID-19 Emergency, ARP funds must then be distributed based on the State s approved Intrastate Funding Formula. Title VII funding is not required to be distributed through the IFF, unless the State s IFF provides for it. 13
No-Cost Extensions Automatic No-Cost Extensions provided for 12 months on the project period for grants: 2020 Title III, Title VII, and NSIP FFCRA Title III CARES Act Title III and Title VII Grants with an undrawn balance of $10 or more will automatically be provided a 12 month project period extension in June 2021 In June 2021, a new NOA will be issued with an updated project period end date of 9/30/2022 14
