NOFA #007 Frequently Asked Questions

The U.S. Treasury has published a number of resources that can be found at https://home.treasury.gov/policy-issues/coronavirus/assistance-for-state-local-and-tribal-governments/state-and-local-fiscal-recovery-funds.
For Compliance and Reporting Guidance, go to https://home.treasury.gov/system/files/136/SLFRF-Compliance-Statement.pdf.
Please note that NOFA 007 operates under the Interim Final Rule found at https://www.govinfo.gov/content/pkg/FR-2021-05-17/pdf/2021-10283.pdf.

Applicable Federal contract provisions can be found in your NOFA 007 Grant Agreement, Attachment B. Federal provisions regarding cost principles and audit requirements can be found at https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1.

Grants are all assessed independently and are subject to terms applicable to the specific grant. Future grants will take into account the buildout of your current broadband project. Your entity cannot receive more than 100% of the total costs incurred for buildout.

DoIT will approve one advanced payment per project. The maximum request for the advanced payment is 50%, but a grantee is permitted to request less.

All federally-funded grants are subject to 2 CFR Part 200. In addition, all funds must be obligated between March 3, 2021 and December 31, 2024. Purchases made prior to March 3, 2021 are not allowable expenditures and will not be reimbursed. See Interim Final Rule: Frequently Asked Questions section 6.2 and 6.12.

Work that is self-performed does not require competitive bid. Personnel/Labor costs support is discussed in 2 CFR § 200.430. Fringe benefits (2 CFR § 200.431) and equipment rates per hour can be charged back to the project but the methodology for the costs must be documented, as well as a source for the amounts charged. 

Recipients may leverage existing contracts for SLFRF activities if the existing contracts conform to the procurement standards in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards in 2 CFR § 200.317-200.327. If you have competitively bid your vendor in the last 6 years and can show they currently have cost reasonableness, and you have proper supporting documentation, including any change orders for price differences, then it would appear you have reasonable documentation to justify a noncompetitive procurement. If you have not competitively bid, please consult 2 CFR § 200.320 to determine whether you have sufficient justification for sole sourcing your procurement. The DoIT will not approve noncompetitive procurements.

The DoIT will not approve noncompetitive procurements. If you do not participate in a competitive bid process, or do not adhere to the requirements in 2 CFR § 200.320, you may be subject to grant claw back or other remedies as noted in 2 CFR § 200.339.

Although existing contracts may be leveraged under NOFA 007, these contracts must be in compliance with 2 CFR Part 200. While this statute allows for non-competitive or sole source procurements, the subrecipient is liable for making the determination as to whether the procurement complies with the requirements outlined in 2 CFR § 200.320. The DoIT will not approve noncompetitive procurements. If the subrecipient determines that the purchase complies with the requirements of 2 CFR Part 200, complete and thorough documentation should be made and kept by the subrecipient justifying its reasons for not seeking a competitive bid. When documenting a non-competitive procurement, a cost reasonableness analysis for the costs incurred should be included. Reasonableness of costs is outlined in 2 CFR § 200.404.

See response to question 9.

See response to question 9. See also 2 CFR § 200.320 for Methods of Procurement.

Procurement requirements and methods are discussed in 2 CFR § 200.320. If, after a number of sources have been solicited, and competition is determined to be inadequate,  a non-competitive procurement under 2 CFR § 200.320(c)(5) may be of consideration to the Grantee. Documentation to support this justification of inadequate competition should be maintained.

Parent/subsidiary intercompany procurement and materials invoicing is not specifically addressed in the CSLFRF guidance. For the subsidiary, a noncompetitive procurement may be justified at the Grantee's discretion, and if so, should include supporting documentation that the parent company competitively procured the materials. For the inventory movement, documentation is necessary to demonstrate that the original company competitively procured for the materials purchased, and then subsequent movement through to the subrecipient. The U.S. Treasury may not agree with this interpretation. Based on other federal guidance, exchanges between entities of this nature must be at cost.

Part 32 is not an explicit acceptable accounting method listed in the Grants Management Guide or the NOFA 007 Grant Agreement. Please refer to section 4.4 (Proof of Allowable Expenditures) of the Grant Agreement, and the Grants Management Guide where the Office explicates acceptable proofs of purchase and proofs of payment the Office will accept at the time of claims reimbursement.

Yes, you can charge a connection fee if those costs are not in your awarded budget. DoIT will not reimburse a subgrantee for costs passed to customers for reimbursement. Costs associated with completion of the project must be consistent with the 2 CFR Part 200.404 (reasonable costs).

2 CFR requires that the procurement of goods and services should be competitive and to reduce the risk for waste, fraud, and abuse. For details on how to complete your procurement actions, please review the 2 CFR Part 200 and the 2 CFR 200 Guide. 

A copy of your bank statement (please redact anything not related to the payment record itself), a copy of a canceled check (front and back), or a copy of the ACH payment report. ACH receipts are acceptable as long as the record details what invoices are included in the payment. 

A project is considered complete when all broadband units are served. A broadband unit is considered served if a provider can connect the home, school, or business within a commercially reasonable time for a commercially reasonable price.  

All aggregate dollar amount thresholds are project-wide. 

All grantees are eligible for (1) advance payment of up to 50% of the grant award amount. According to Section 15.321 of the NOFA 7 Grant Agreement, advance payments must be requested one year after the execution of the grant agreement or in accordance with cash requirements for implementing the project. 

Before compiling internal payroll records, please contact the DoIT grants support team through the Correspondence module in your organization's grant file in Iowa Grants. A  grant support specialist will determine what internal records will be necessary.