Maintenance of Effort

Maintenance of Effort (MOE) outlines a grantee’s administrative requirement to maintain a specified level of non-Federal expenditures (effort) to avoid a reduction levied against a future Federal grant.

VR agencies must report all allowable non-Federal expenditures incurred under the VR program, regardless of the source of funding, even if the amount reported exceeds the amount of non-Federal share required to match the total Federal funds awarded. This information is necessary for RSA to assess whether the State has met its MOE requirement.

For purposes of the VR program, a State must report all non-Federal expenditures in the FFY in which those expenditures are incurred for purposes of satisfying the MOE requirement because MOE is determined on an FFY basis, not on the basis of a period of performance for an entire grant award.

Non-Federal obligations and expenditures incurred during the carryover year do not count toward the prior FFY of appropriation’s match requirement but will count toward the current FFY’s MOE requirement.

Non-Federal expenditures for the purpose of establishing a facility for a community rehabilitation program (CRP) will not be counted toward the State’s MOE (34 CFR § 361.62(b)); however, these non-Federal expenditures, if obligated or liquidated within the period of performance, count toward satisfying the State’s match requirement. Additionally, Non-Federal expenditures for the purpose of constructing a facility for a CRP will not be counted toward the State’s MOE (Section 101(a)(17)(C) of the Rehabilitation Act and 34 CFR § 361.62(b)).

MOE waivers, allowable under 34 CFR § 361.62, are requested for an amount of non-Federal funds to be waived, it is not a waiver of the entire requirement. In order to sufficiently determine the amount of funds requested in a waiver, grantees must wait until the end of the period of performance of an award, due to the fact that obligations satisfy the non-Federal share requirement. Only after all expenditures have been completed can the grantee adequately determine the amount of funds necessary to request via the waiver.

MOE waivers may be requested when a State VR agency has a decrease in non-Federal funding due to exceptional or uncontrollable circumstances, such as a natural disaster or serious economic downturn.