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Understanding Non-Federal Match for the RCP Program

Most DOT discretionary and formula grant programs involve sharing project costs between a non-Federal entity or recipient and the Federal government. Non-Federal “matching” or “cost sharing” (both terms may be used interchangeably) means that a portion of the project’s total cost is not paid for by the Federal award and / or Federal funds and the recipient of those Federal funds provides a non-Federal match. Matching funds are typically stated as a percentage of the project’s total cost. Please consult the DOT Navigator to learn the basics of “Understanding Federal Match Requirements.” Match requirements vary program to program. 

The Reconnecting Communities Pilot (RCP) discretionary grant program requirements do not allow the program to cover 100% of project costs. The applicant is required to provide non-Federal match to supplement the Federal grant, if awarded. The applicant should describe the anticipated funding plan in the application budget narrative. Please note - ALL expenses counted as non-Federal match must be otherwise eligible for RCP funding. 

The pathway to full funding varies for Planning and Capital Construction. 

Major Funding Sources 

There are three major funding sources for the RCP: the RCP grant, Non-Federal Match or “match” provided by the recipient, and other Federal Funds (for Capital Construction only). 

This graphic reflects the maximum Federal Assistance scenario to show the relationship between major funding sources. Actual RCP Award amounts may be lower than the maximum, which could necessitate a larger non-Federal match. 

Maximum Federal Assistance Chart

 

RCP Planning Grants  RCP Capital Construction Grants 
RCP grant may not exceed 80% of the total project cost.   RCP grant may not exceed 50% of the total project cost. 
Applicants must contribute a minimum 20% non-Federal match. There are limited exceptions. See below.  Applicants may satisfy up to 80% of project costs with other Federal funds (in addition to the RCP grant) 
--- Applicants must contribute a minimum 20% non-Federal match. There are limited exceptions. See below. 

 

General parameters regarding non-Federal match as it relates to the RCP program: 

  • The first question is whether an expense (including intended non-Federal match) is eligible under the grant. An “eligible expense” is an expense incurred by the RCP grant recipient that directly facilitates the execution of a grant agreement and its activities and must be “reasonable,” “necessary,” and “allocable” (2 CFR Part 200.403[a], 404, and 405). Eligible expenses comprise the total project cost for the grant including that funding through RCP and non-Federal match. Matching Eligible expenses must be documented appropriately to be counted towards a match. 
  • Match may include both funds from the applicant or other non-Federal entity, or third-party in-kind contributions from other non-Federal sources. Examples include State funds originating from programs funded by State revenue, funds originating from State or local revenue-funded programs, or private funds. 
  • The value of personnel, goods, services, space, and utilities provided by the grant recipient and partners that directly facilitates the grant may be categorized as direct or indirect costs (2 CFR Part 200.412, 413, and 415). Those costs, like all eligible costs, can count toward non-Federal match or be reimbursed with RCP funds, if they are billed to the RCP grant. 
    • Indirect costs may be billed at the federally negotiated indirect cost rate or a 10% de minimis rate, if the former has not been negotiated. 
  • Third-party in-kind contributions are typically in the form of the value of personnel, goods, services, space, property, and utilities contributed by a non-Federal third party, such as a private business or nonprofit, specifically for the program. In-kind contributions may also include materials, pro bono work provided to the project by third parties, and donations from private sponsors.  
  • Non-Federal match funds may be counted only once and may not be counted as match for multiple Federal awards. 
  • A non-Federal match that is an eligible expense for one grant may not be eligible in all instances across all grants. 

The Tables below provide illustrative match examples for RCP Planning and Capital Construction Grants. Please note, the applicability of examples depends on the applicant organization’s accounting practices. The last section of this document provides examples of costs that are typically not eligible expenses, including for match. 

RCP Grant Eligible Funding Sources for Non-Federal Match 

Funds 

  • Provided by the local entity (e.g., City, County, Tribe, MPO) that received the award. 
  • Funds provided by a State organization, as long as the original source was not Federal funding (with limited exceptions). 
  • Funds from private sector, non-profit, philanthropic, or other partner organizations. 

RCP Grant Eligible Expenses and Non-Federal Match Examples 

Eligible RCP expenses may support eligible public engagement activities, eligible planning studies and activities, and eligible construction activities. See Page 7 of the NOFO.   

Eligible expenses for the RCP Grant, non-Federal matching funds, and in-kind contributions will fall under the following categories and examples. 

Category  Eligible Costs and Match Examples
Personnel 
  • Staff member hired to execute the grant full-time.  
  • Staff hours spent in the direct execution of the grant agreement.  
  • Staff time managing contractors and partners who are executing the Planning or Capital Construction projects.   
  • Staff hours associated with the financial and administrative management of the grant that are not being directly billed to the grant but are supporting the project with portions of their time and not included as part of an indirect rate. 
  • The total staff and volunteer time spent as part of the committee or task force that is directly engaged in the oversight of the Planning and Capital Construction project development, implementation, and monitoring. The rate billed as match for volunteer time may be associated with those volunteers’ typical hourly wage or a local approved volunteer rate. 
Goods 
  • Purchased or donated goods such as office supplies, IT equipment, flyers, and banners that support the implementation of the project.  
  • Purchase of materials to execute the project. 
Services
  • Purchased or donated services of third-party organizations for the implementation of the RCP project (if donated, valued at the employee’s regular rate of pay and may include fringe and indirect costs). Examples of services may include contracts for services that directly support the implementation of the RCP project.  
  • The time that members of the public spend participating in any engagement or collaboration activity such as a public meeting that is reasonable, necessary, and allocable for the project. 
Space
  • If counting the direct cost of space, such as office rental (charged relative to the scale of the award). For example, if the RCP grant award amounts to 5% of an organization’s budget for the year, then 5% of space costs may be counted toward non-Federal match if it is not part of an indirect rate. 
  • Fair market cost of space that is specifically associated with developing the RCP project, but is not charged to the grant, such as the cost to rent a meeting room to meet with stakeholders. 
Utilities
  • If counting the direct cost of utilities, such as phone and internet service, if it is charged relative to the scale of the award. For example, if the RCP award amounts to 15% of an organization’s budget for the year, then 15% of utility costs may be used as match. 

Examples of costs likely to be ineligible Expenses for RCP Grants and non-Federal match 

The following are examples of costs that are typically not eligible for the RCP grant nor for non-Federal match: 

  • The time that members of the public spend to learn more about activities associated with the execution of the grant. 
  • Expenses not directly necessary for the facilitation of the grant agreement, including providing food, beverages. 
  • Promotional materials (e.g., t-shirts, mugs, hats) to give out at public outreach events or to staff and/or volunteers working on the grant. 
  • Workforce activities not directly associated with the transportation project to remove, retrofit, or mitigate.
  • Public art not directly associated with the transportation project. 
  • Lobbying, including costs to influence policy decisions or elections. (See 2 CFR 200.450 for further information on lobbying.) 
  • General costs of government outside the scope of implementing the grant (e.g., salaries and expenses for City Council, Mayor, Tribal executive). (See 2 CFR 200.444 for further information on general costs of government.) 
  • Entertainment (e.g., band, DJ, performers) to entice participation in events. 
  • Time and costs associated with developing grant application and other pre-award costs. 
  • Fundraising costs for organization (e.g., financial campaigns, endowment drives, solicitation of gifts) associated with grant recipient or partnership organizations to obtain contributions for general operations. 
  • Fines, penalties, and fees resulting from violations or failure to comply with Federal, State, or local laws and regulations. 
  • Funds may not be used to support or oppose union organizing. 

Examples of Federal funding programs that may be counted toward the 20% non-Federal match requirement 

There are limited instances when Federal funds may be used to satisfy the RCP’s non-Federal match requirement. 

For Planning Grants, funding programs that may be used to satisfy non-Federal match include, but may not be limited to:  

  • DOT’s Tribal Transportation Program Funds, if the project will provide access to Tribal land.  
  • DOT’s Federal Lands Transportation Funds, if the project will provide access to Federal land. 
  • DOT’s Recreational Trails Program Funds, if the project is eligible under that program. 
  • HUD’s Community Development Block Grants (CDBG), if the CDBG-funded portion of the project is undertaken as part of CDBG-eligible activities.  

For Planning Grants and Capital Construction Grants, funding programs that may be used to satisfy non-Federal match include, but may not be limited to:  

  • Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program. SLFRF funds available under sections 602(c)(1)(C) and 603(c)(1)(C) of the Social Security Act (42 U.S.C §§ 802–803) may be used for the provision of government services up to the amount of the recipient government’s reduction in revenue due to the COVID–19 public health emergency. However, if the recipient’s SLFRF payment exceeded their reduction in revenue due to the emergency, the excess amounts cannot be used as non-Federal share. 
  • Transportation Development Credits / Toll Credits.  

Examples of Federal funding programs that may be counted toward “Other Federal Funds” for Capital Construction Grants 

Capital construction grant applicants may seek to supplement an RCP award with Federal funds (formula or discretionary) for a maximum of 80% Federal assistance for total project costs.  

Examples of Federal programs (formula and discretionary) include:  

  • DOT’s Metropolitan Planning and Statewide Planning & Research funds (FHWA and FTA) 
  • DOT’s Surface Transportation Block Grants, including Transportation Alternatives  
  • DOT’s Congestion Mitigation and Air Quality Improvement program 
  • DOT’s Rebuilding American Infrastructure with Sustainability and Equity (RAISE) grants 
  • DOT’s Multimodal Project Discretionary grants 
  • DOT’s Safe Streets and Roads for All grants 
  • HUD’s Community Development Block grants 
  • HHS’s Community Services Block grants 

For more information 

  • See page 6 of the RCP NOFO for Cost Sharing and Matching 
  • See page 7 of the RCP NOFO for Eligible Facilities, Activities, and Costs 
  • See page 13 of the RCP NOFO for Budget 
  • 2 CFR 200 - PART 200 - UNIFORM ADMINISTRATIVE REQUIREMENTS, COST PRINCIPLES, AND AUDIT REQUIREMENTS FOR FEDERAL AWARDS 
  • DOT Navigator, Understanding Federal Match Requirements