WIOA Title I-A & I-B Policy & Procedure Manual Ch. 4) Fiscal Management
4.15 Leveraged Resources
Effective date: December 13, 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 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
Are verifiable from the non-federal entity's records;
Are not included as contributions for any other federal award;
Are necessary and reasonable for accomplishment of project or program objectives;
Are allowable under Subpart E—Cost Principles of this part;
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; and
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
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.
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
The following cannot be used as Match however may be counted towards Leverage.
Non-federal share of funds used for grant purposes
Paid with federal funds (unless authorized by the program statute)
Used as match in another federal program
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/or 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.
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