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Third Party In-Kind Contributions As Match For FHWA Planning Funds

07/25/2006 01:50:38 PM, Revised 12/26/2014
Lorrie Lau
HQs Planning Memos and Guidance, Federal Highway Administration,
Lorrie.Lau@dot.gov

The value of third party in-kind contributions may be accepted as the match for Federal funds, in accordance with the provisions of 2 CFR 200.306(b), and may be on either a total planning work program basis or for specific line items. The use of third party in-kind contributions needs to be identified in the original work program and grant/subgrant agreement, or amendments thereto, and approved by the Federal grantor agency. The use of in-kind contributions may not be made retroactive prior to approval of the work program or an amendment thereto.

The recipient/subrecipient should be made aware that they are responsible for ensuring that the following additional criteria are met:

• The third party performing the work must agree to allow the value of the work to be used as the match.
• The cost of the third party work must not be borne by other Federal funds or be used as a match for other federally funded grants/subgrants.
• The work performed by the third party must be an eligible transportation planning related activity that benefits the federally funded work and must be identified in the work program.
• The third party costs (i.e., salaries, fringe benefits, etc.) must be allowable under 2 CFR 200, Subpart E- Cost Principles.
• The third party work must be performed during the period to which the matching requirement applies.
• The third party in kind contributions must be verifiable from the records of the recipient or subrecipient and these records must show how the value placed on third party in kind contributions was derived.
• Invoices submitted by a subrecipient to a recipient should show total expenditures by subrecipient and the third party contributions. The recipient then would reimburse the subrecipient for the Federal (and State, if any) share, not to exceed the subrecipient's expenditures. If the total amount of third party contributions at the end of the program period is not sufficient to match the total expenditure of Federal funds by the subrecipient, the subrecipient will need to make up any shortfall with its own funds.