PROGRAM INCOME / IN-KIND ASSISTANCE / IN-KIND

CONTRIBUTION

PROGRAM INCOME REFERENCESPROGRAM INCOME REFERENCES

• NGR 5-1/ANGI 63-101 Chapter 7.

• 32 CFR, SECTION 33.25.

• DoDGAR 3210.6-R, SECTION 33.25.

• Rental of State owned and Federally supported armories.

• Reimbursements made to the USPFO by another Federal agency for the use of a NGB supported facility.

• Billeting Fund.

FUNDS THAT AREFUNDS THAT ARE NOTNOT PROGRAM PROGRAM INCOMEINCOME

RENTAL OF STATE OWNED, RENTAL OF STATE OWNED, FEDERALLY SUPPORTED FEDERALLY SUPPORTED

ARMORIESARMORIES

TITLE 10 U.S.C. 1823(C) Permits the States to rent out Armories if the State

uses the income to maintain the Armories.

REIMBURSEMENT BY REIMBURSEMENT BY ANOTHER FEDERAL AGENCYANOTHER FEDERAL AGENCY

• Funds submitted to the USPFO.

• USPFO processes a reimbursement for actual costs incurred.

• Cooperative Agreement modified to increase Federal contribution.

BILLETING FUND

NGR 210-50

BILLETING FUNDBILLETING FUND

• ARNG Billeting Operations

• Required for Transient Billeting

• Not considered Program Income

• State Non-Appropriated Fund

• Not Fiscal Year Dependent

• Fees Cannot Exceed 50% of Local PerDiem Rate

• Billeting Fees approved by USPFO

BILLETING FUNDBILLETING FUND (Continued)(Continued)

• Covers cost of daily operations: Maid Service

Front Desk Personnel

Consumable Supplies Amenities

• May be used for minor repairs

• USPFO must audit fund annually

• Should have a capital expenditure plan

BILLETING SURCHARGE FEESBILLETING SURCHARGE FEES

• Surcharge is an additional fee charged forunofficial users

• TAG has latitude to determine unofficialusers

• Surcharge fee is used to offset utility cost

• Surcharge fees are submitted to USPFOand credited O&M account

• Surcharge fees are fiscal year dependent

PROGRAM INCOMEGRANTEES (NGB) ARE

ENCOURAGED TO EARN PROGRAM INCOME

Program income is defined in NGR 5-1/ANGI 63-101, Chapter 7 as the gross income, received by a recipient from fees for services performed and from the use, rental, or sale of real or personal

property, the operation and maintenance of which is supported under an NGB CA.

PROGRAM INCOMEPROGRAM INCOMEDEFINEDDEFINED

PROGRAM INCOME CONCERNSPROGRAM INCOME CONCERNS

*Equipment acquired with NGB CA funds shall NOT be used to provide services for a

fee to compete unfairly with private companies that provide equivalent services.

*Likewise we should not rent facilities that

would compete unfairly against the private sector.

USER’S FEE

• NATIONAL GUARD USERS: Recover Cost for Additional Services

• FEDERAL AGENCIES: Recover Identifiable Incremental Costs

• NON-FEDERAL USERS: Recover an Amount Equal to its Overhead Cost

ACCOUNTING FOR PROGRAM INCOMEACCOUNTING FOR PROGRAM INCOME

• Program income is accounted for and used as an addition to the State’s contribution to a CA.

• If program income is received on a cost-shared CA, the amount of program income added to the funds committed to the CA is a percentage of gross program income equal to the percentage of the Federal contribution stated in the CA.

ACCOUNTING FOR PROGRAMACCOUNTING FOR PROGRAM INCOME (Continued)INCOME (Continued)

• The State must expend program income funds following the rules applicable to the type

of funds from which the program income was generated.

• Program income is used to offset future requests for reimbursement.

ACCOUNTING FOR PROGRAM ACCOUNTING FOR PROGRAM INCOME (Continued)INCOME (Continued)

• Cooperative Agreement modified to increase estimated cost.

• Program income is reported in DAADS as part of the State contribution.

FUNDING “CASH” Quarterly Authority Annual Budget Authority Allotment Annual Funding Program Maximum Funding Limitation Estimated Cost

Federal Share (100%) $_______________________ $_____100,000__________________Federal Share (75%) $_______________________ $_______________________Federal Share (50%) $_______________________ $_______________________

Federal Total $_______________________ $______________________

State Share (50%) $________________________ $______50,000_________________State Share (25%) $________________________ $_______________________

Program Income $_______________________

State Total $________________________ $_______________________

Grand Total $________________________ $_______________________

In-Kind Assistance.

1,000.00

FUNDING – PROGRAM INCOME

PROGRAM INCOMEPROGRAM INCOMEEXAMPLESEXAMPLES

The State Resource Manager received $1,000 in program income from the State Human Resources Division for using the Training Site auditorium. (100% Federal)

 State Resource Manager:

 1. Receives the check from the Training Site Administrator.

 2. Reports the $1,000 program income to the Grants Officer.

 3. On the next request for reimbursement, reduces the amount requested by the amount of program income.

EXAMPLE #1EXAMPLE #1

The Grants Officer:

 1. Completes a modification to the cooperative agreement.

 2. Reports program income in DAADS as an increase to the State contribution.

 If the original contribution by the State was $0, add the $1,000 program income contribution for a total State contribution of $1,000.

EXAMPLE #1 (Continued)EXAMPLE #1 (Continued)

The State Resource Manager received $5,000 in program income from the state highway patrol for using an agreement supported pistol range. (75% Federal/25% State)

 State Resource Manager:

 1. Reports the $3,750 program income to the Grants Officer. (5,000 X 75% Federal share)

 2.   On the next request for reimbursement, reduces the amount requested by the amount of program income.

3. The State Resource Manager at their discretion will use the $1,250 that is not reported as program income. 

EXAMPLE #2EXAMPLE #2

The Grants Officer:

1. Completes a modification to the cooperative agreement.

2. Reports program income in DAADS as an increase to the State contribution.

If the original contribution by the State was $100,000 add the $3,750 program income contribution for a total State contribution of $103,750.

EXAMPLE #2EXAMPLE #2 (Continued) (Continued)

MANAGEMENT CONTROLSMANAGEMENT CONTROLS

• Determine which programs in your state may create Program Income.

• Validate whether program income is being generated• Is program income submitted to State Comptroller?• Has the State Comptroller correctly applied program

income (proper share & proper appendix) by reducing requests for reimbursements?

• Validate that CA has been modified to increase the State Share by the applied Program Income and reported in DAADs.

IN-KIND ASSISTANCE IN-KIND ASSISTANCE REFERENCEREFERENCE

NGR 5-1/ANGI 63-101 Chapter 6

GOVERNMENT FURNISHED EQUIPMENTGOVERNMENT FURNISHED EQUIPMENT

• Government furnished equipment is NOT In-Kind assistance.

• Reference NGR 5-1/ANGI63-101 Chapter 6-2c

The transfer of property or services (valued at the time of contribution at fair market

value), in lieu of funds by NGB, to satisfy (in whole or in part) its obligation of assistance

support to the State.

IN-KIND ASSISTANCE IN-KIND ASSISTANCE AUTHORIZEDAUTHORIZED

• Supplies.• Services (exception is Federal contracts for the

performance of fire fighting or security guard functions).

• Maintenance or repair.

• Contracting through the USPFO.

• Contracting through other Federal channels.

TYPES OF IN-KIND ASSISTANCETYPES OF IN-KIND ASSISTANCE

• In-Kind Assistance is on a case-by-case basis and considered the exception, not the rule.

• The value of the In-Kind Assistance must be accounted for in the Cooperative Agreement.

• The total monetary value of the In Kind Assistance is the amount used to determine a State’s share when a Cooperative Agreement is

cost shared.

IN-KIND ASSISTANCE IN-KIND ASSISTANCE

• USPFO Approves/Disapproves

• Modify Cooperative Agreement (if approved)

• Federal Procurement

PROCESSING IN-KIND ASSISTANCEPROCESSING IN-KIND ASSISTANCE

“CASH” Quarterly Authority Annual Budget Authority Allotment Annual Funding Program Maximum Funding Limitation Estimated Cost

Federal Share (100%) $______100,000___________ $_______________________Federal Share (75%) $_______________________ $_______________________Federal Share (50%) $_______________________ $_______________________

Federal Total $_______________________ $______________________

State Share (50%) $________________________ $_______________________State Share (25%) $________________________ $_______________________

Program Income $_______________________

State Total $________________________ $_______________________

Grand Total $________________________ $_______________________

In-Kind Assistance $____________________

“within the federal share indicated above, in-kind assistance thru federal procurement procedures of $1,000 is being withheld and designated specifically.”

FUNDING – IN KIND ASSISTANCEFUNDING – IN KIND ASSISTANCE

1,000.00

PROCESSING IN-KIND PROCESSING IN-KIND ASSISTANCE (Continued)ASSISTANCE (Continued)

• Accountability of cost shared CA.

• The USPFO notifies the State of the State’s cost share

State credits the amount against the costs claimed for reimbursement under that agreement on the next voucher submitted.

MANAGEMENT CONTROLSMANAGEMENT CONTROLS (Continued)

• Is In-Kind Assistance approved by the USPFO as an exception?

• Has the CA been modified converting cash contribution to IKA with no change in total value? Validate that any State Share is applied on future reimbursement.

CASE STUDY

CASE STUDY MODULE # 7  

The 133rd ARW (NG) Base Civil Engineer has notified NGB ANG/CE that a requirement exists to purchase contract training for maintenance state employees (FOMA) on a new fire suppression system installed at the wing. The message further stated that the training would be purchased using an Air Force contract in the approximate amount of $4,000.00. The Wing is to use existing funds contained within the FOMA (75-25), with the understanding that they will be reimbursed at mid-year.  What steps are required to make this happen? Are there any concerns that should be addressed relative to this action?

IN KIND IN KIND CONTRIBUTION BY CONTRIBUTION BY

STATESTATE

• Cost share occurs when the FederalGovernment is not funding 100% of theactivity

• Cost share is also known as> Matching share> Match> Matching funds

COST SHARE DEFINITION

• Cost share is set by NGB or legislation

> Appendices

> NGR 5-1/ANGI 63-101

COST SHARES

• GAO Principles of Federal Appropriations Law-Vol II

• Department of Defense Grants & Agreements Regulation (DoDGARS) 3210-6R

• NGB Cooperative Agreement and Support Agreement Handbook (CASA)

OTHER COST SHARE REFERENCES:

RECIPIENT’S COST SHARE CAN BE:

• HARD MATCH

• SOFT MATCH

• Hard Match is strictly cash contribution.

• The only hard match required in CA is MILCON for Armories per 10 USC 18236. The land has to be State owned and its value cannot be part of the match.

HARD MATCHHARD MATCH

All other CA’s, unless specified by legislation, are soft match and the State

can contribute other than cash in the form of supplies or services (allowable costs

only).

SOFT MATCH

• Value assessed per DoDGARS 33.24

• Assessed value of contribution must be valued at a “Fair & Reasonable” amount that can be be verified by State’s records.

VALUE OF STATE IN-KIND CONTRIBUTION:VALUE OF STATE IN-KIND CONTRIBUTION:

For donated services:(1) Volunteer Services-valued at rates consistent

with those ordinarily paid for similar work in State’s organization or similar to labor market if State doesn’t have this type of employee.

(2) Other Organization’s Employees-valued the employee’s regular rate of pay (for same type of work) exclusive of Fringe Benefits and Overhead Costs.

EVALUATING STATE IN-KIND EVALUATING STATE IN-KIND CONTRIBUTION PER DODGARS 33.24:CONTRIBUTION PER DODGARS 33.24:

For donated supplies & loaned equipment or space where title does not pass to grantee or subgrantee:

(1) Value of supplies will be market value at time of donation(2) Value of equipment or building space will be at fair rental

rate of that equipment or space.

For donated equipment, buildings, and land:If a 3d party passes title to grantee or subgrantee,

the treatment of the donated property depends on the purpose of the grant. (See DoDGARS 33.24)

For donated real property for construction/acquisition-see DoDGARS 33.24.

EVALUATING THIRD PARTY IN-KIND CONTRIBUTION PER DODGARS 33.24:

MODULE TEACHING POINTS

• HARD/SOFT MATCH

• Is Soft Match valued per

DODGARS 3210.6R?

QUESTIONSQUESTIONS