WIOA Title I-A & I-B Policy & Procedure Manual
Ch. 4) Fiscal Management



4.15 Leveraged Resources

Effective date: _________, 2020

Background

Leveraged resources are all resources used to support WIOA Title I-B grant activities and grant outcomes, whether or not those resources meet the standards required of allowable match. Leveraged resources can be either:

  • Allowable Match;
    or
  • Non-Match.

Allowable Match

Match is defined as additional non-federal funds expended to support grant objectives when required either by statute or in the Funding Opportunity Announcement (FOA) as a condition of the award.1

For all federal awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the non-federal entity's cost sharing or matching when such contributions meet all of the following criteria:2

  1. Are verifiable from the non-federal entity's records;
  2. Are not included as contributions for any other federal award;
  3. Are necessary and reasonable for accomplishment of project or program objectives;
  4. Are allowable under Subpart E—Cost Principles of this part;
  5. Are not paid by the federal government under another federal award, except where the federal statute authorizing a program specifically provides that federal funds made available for such program can be applied to matching or cost sharing requirements of other federal programs;
  6. Are provided for in the approved budget when required by the federal awarding agency; and
  7. Conform to other provisions of this part, as applicable.

Match must be spent on allowable activities.3 Non-federal entities can only account for funds used for cost sharing or match when they are expended.4

Types of Match

  1. Cash
    Cash match reflects additional funds or services (allowable costs) provided and paid for by the grantee and/or any subrecipient from non-federal funds that support the grant objectives and outcomes. Cash match includes unreimbursed allowable indirect costs. Cash match is valued as the actual costs incurred as reflected in the grantee's/subrecipient's accounting system.
  2. In-Kind
    In-kind contributions are the non-cash contributions that benefit a federally assisted project or program and are contributed by non-federal third parties, without charge, to a non-federal entity under a federal award.5

Value of In-Kind Contributions

In-kind contributions must be valued consistent with 2 CFR § 200.306. Refer to U.S. Department of Labor Leveraged Resources Guidance for further clarification.

Types of Non-Match

The following cannot be used as Match however may be counted towards Leverage.

  1. Federal funds from other programs
  2. Non-federal share of funds used for grant purposes
  3. Paid with federal funds (unless authorized by the program statute)
  4. Used as match in another federal program
  5. Expenditure of Program Income

At this time, none of the federal statutes for programs currently administered by Department of Labor- Employment and Training Administration specifically allows the use of its funds as match for another federal program.6

Leveraged Resource Methodology

Local WDBs must have written policy and procedures defining how leverage is calculated.

Local WDBs must maintain records that support the cash match costs and be available for audit and review. For third party contributions, support for the value must be verifiable from sub-grantee records or be maintained by the grantee, including the methods used to determine the value.

Types of Leveraged Resources

Examples of LR activities include, but are not limited to:

  • Training
  • Tuition grants
  • Other job readiness activities and services
  • Grants or matching funds for certification fees
  • Grants for tools or other required, job-specific supplies
  • Donated supplies, personnel services, equipment, or space

Types of Funding Sources for Leveraged Resources

Examples of LR funding sources include, but are not limited to:

  • Federal Pell Grants
  • Public programs authorized by WIOA
  • Trade Adjustment Assistance (TAA) program
  • Department of Labor National Emergency Grants
  • Wisconsin State funding

Leveraged Resource Reporting

Local WDBs must report all leveraged resources on the monthly financial status report in Contract Management and Expenditure Tracking (COMET) for the life of the grant.