Help America Vote Act (HAVA) Funding – Program Income Instructions
| To: | Texas County Financial Officers |
| CC: | Texas County Judges and County Election Officials |
| From: | Dan Glotzer, HAVA Grant Manager |
| Date: | December 11, 2007 |
| Re: | Help America Vote Act (HAVA) Funding – Program Income Instructions |
Background
In October 2006, the Office of the Inspector General of the Election Assistance Commission (EAC) issued an Audit Report on Texas’ administration of the funds awarded to the state pursuant to the Help America Vote Act (HAVA). The majority of the HAVA funds were sub-awarded by the state to the Texas counties to comply with Title III of HAVA. The EAC issued a Final Audit Resolution Report in December of 2006, which included one actionable finding affecting the counties that the state must remedy. It was determined that the state must instruct the counties regarding the calculation, reporting and use of program income.
- Program income is defined as gross income received from a grant-supported activity during the grant period and includes items such as fees from the use or rental of real or personal property acquired with grant funds. In the case of the HAVA program, the grant-supported activity is the acquisition of voting systems.
Determining Program Income
The Secretary of State has opted to report gross program income because it requires less state and local resources and carries less risk. You might be aware that the EAC granted authority to the state, when calculating program income, to deduct costs incurred as a result of generating the program income (i.e., costs absorbed by the county that were attributable to providing the HAVA-funded goods and services to the local entities that were not charged to the local entities nor financed with HAVA funds). However, reporting gross program income carries less risk because it requires fewer calculations, analyses, less documentation, and there is no penalty for over-reporting whereas the Final Resolution warns if program income is underreported, that amount must be returned to the Election Improvement Fund established by the state in response to HAVA.
Program Income Use and Reporting
Use of program income includes, but is not limited to: maintenance and license fees for the voting equipment; equipment upgrades as well as new equipment; training; storage; and other costs associated with the operation and maintenance of the voting system.
Counties that received only Voting System Accessibility and General HAVA Compliance grants will have three reporting periods while counties that also received punch card or lever replacement (Voting System Replacement) grants will have eight (the three for Voting System Accessibility and General HAVA Compliance grants plus five for Voting System Replacement grant), which are all outlined below:
HAVA Title II, Section 251 (Voting System Accessibility and General HAVA Compliance Grants - All 254 Counties)
- June 17, 2004 thru September 30, 2005
- October 1, 2005 thru September 30, 2006
- October 1, 2006 thru September 30, 2007
HAVA Title I, Section 102 (Voting System Replacement - 17 Punchcard and Lever Counties)
- May 1, 2003 thru December 31, 2003
- January 1, 2004 thru December 31, 2004
- January 1, 2005 thru December 31, 2005
- January 1, 2006 thru December 31, 2006
- January 1, 2007 thru December 31, 2007
Although the Voting System Accessibility and General HAVA Compliance grants are accounted for separately in the grant system, the program income can be combined as one value for each reporting period.
If the county received Voting System Replacement funds, the grants must be accounted for separately when calculating program income.
- For example, if the county spent $100,000 on voting systems and the Voting System Replacement funds covered $30,000 of the costs and the Voting System Accessibility and General HAVA Compliance grants covered $70,000, the items leased or contracted to local entities that were purchased with the $30,000 should be reported under the Title I, Section 102 portion of the program income form. Accordingly, the items leased or contracted to the local entities that were funded with Voting System Accessibility and General HAVA Compliance funds should be reported under Title II, Section 251.
If portions of the goods or services (e.g., voting equipment) were funded by the county, that portion of the income does not need to be reported.
If the county did not contract or lease HAVA-funded resources during a particular reporting period, the Financial Officer (FO) reports zero for that period.
Gross program income equals the lease/rental fees generated from HAVA-funded voting equipment as well as other services attributable to HAVA funds.
Be sure to maintain all documentation for audit purposes.
The county’s FO, which is the county auditor or treasurer depending on the county, has the user level access to submit the program income data via the HAVA online grant system. This is the same grant system that was used to drawdown the HAVA funds at http://hava.tamu.edu/; however, the FO will likely need to work with the county clerk or election administrator to gather the necessary information.
After logging into the grant system using the same user ID and password you used to drawdown the HAVA funds, look for the “Program Income” section on the left side of the screen and click on “Report Program Income.” Once in the form, enter the applicable data in each field and click “Submit.” Once you click submit, the fields cannot be changed – only the Secretary of State’s Office can make changes after submission.
THE SOS WILL NEED ALL OF THE DATA SUBMITTED BY THE COUNTY NO LATER THAN JANUARY 30, 2008.
If you need assistance, or if you have questions, please contact Dan Glotzer at 512-463-9861 / dglotzer@sos.state.tx.us or Doug Bradford 512-463-6356 / dbradford@sos.state.tx.us — we are here to help you, to answer questions, and to make this process as easy as possible.