Advisory council approves in-kind match window and moves to two annual OHP grant cycles

Members of the Off-Highway Program (OHP) advisory council on Aug. 6 approved a rule change allowing applicants to count in-kind contributions made up to 12 months before the execution of an OHP grant contract and agreed to set the grant program on a twice-yearly cycle with a shorter application window.

The council’s action followed several hours of discussion about how to prevent abuse of in-kind match credits and how to give staff flexibility to administer the program. “Volunteer hourly contributions may be counted as matching funds if they occur within 12 months prior to the execution of a contract provided the work is directly correlated and approximate to the project scope described in the application,” said Sheriff Curtis as he moved the motion; Scott seconded. The motion, amended during the meeting to emphasize staff discretion, passed on a roll-call vote.

Council members said the change was prompted by applicants who asked to count work done prior to awards and by desire to make the program more accessible for projects that involve planning or early construction.

Why it matters: in-kind match rules affect which projects can meet minimum match requirements and can shift who is competitive for limited OHP dollars. Allowing documented, pre-contract work to count can help groups that must do planning, environmental compliance or initial construction before a grant award, but creates a need for careful verification.

Most of the meeting debate centered on two safeguards: strict connection to the specific project and documentation standards. “It’s gotta be specific to the project they’re applying for,” Sheriff Curtis said, pushing back on broader language that could let unrelated volunteer work be counted. Program staff and legal counsel recommended leaving some of the administrative specifics to a program policy rather than writing detailed federal terms into administrative rule, so the division can adapt if federal requirements change.

Division staff said standard documentation for pre-award in-kind work will include a written day-by-day log and photographs and that the division will offer a preapproval conversation for applicants unsure whether work qualifies. “We can always put in there that the work needs to be preapproved by us,” the program manager said during discussion, adding a discretionary check to reduce the risk of misapplied match.

On timing, the council agreed to change grant-cycle language from “spring and summer” to “two cycles per year” and set the application period to 45 days (staff said the packet’s sample calendar shows openings roughly in January and a second cycle later in the year). The council reasoned that shorter, predictable cycles and a firm program guide will reduce last-minute application rushes that strained staff during the recent round.

The division will publish detailed program guidance for fiscal year 2026 that specifies documentation requirements, how staff will evaluate pre-award in-kind claims, and procedures for multi-year or phased grants. Legal counsel stressed that leaving operational specifics to a policy will make it easier to adapt the program if federal rules—cited in discussion by several members—change.

What the council directed: staff will draft program guidance and an internal review checklist for pre-award in-kind documentation, include a process for callers to request preapproval guidance, and return to the advisory council with that policy language at a future meeting. The adopted rule language creates the 12-month allowance and retains the division’s discretion to accept or reject pre-award hours when applications are scored.

The votes: the in-kind rule change motion (allowing in-kind contributions up to 12 months prior, with division discretion and documentation) carried on a roll-call vote. Separately, a motion to make the grant schedule “twice a year” also passed by roll call; staff said the change will be implemented with a 45-day application window and published dates announced well ahead of each cycle.

Council members emphasized that pre-award work is not a guarantee of funding: applicants who document in-kind work still must meet scoring criteria. “Applicants need to understand that just because you’ve done in-kind, that doesn’t necessarily mean you can get grant funded,” a council member said during discussion.

The council also authorized staff to use a policy (not the narrower rulemaking process) to elaborate the documentation and preapproval process, citing the need for rapid updates if federal guidance shifts. Staff and legal counsel said they will bring a draft to the council for review before publishing the 2026 program guide.

Ending note: The adopted changes aim to balance flexibility for project developers with oversight safeguards; exact documentation requirements and preapproval procedures will be published in forthcoming division guidance.