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IMLS grants‑to‑states session clarifies match, MOE, indirect costs and subrecipient rules
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Summary
IMLS presenters reiterated that SLAA administrative costs are capped at 4%, match is a flat 34% of program costs, MOE is a 3‑year average with limited waiver options, de minimis indirect rate is 10% (for subrecipients), equipment rules and FSRS subaward reporting were reviewed.
At the Grants to States conference, IMLS staff walked state library administrative agencies through detailed grants‑management rules for the LSTA grants‑to‑states program, covering administrative caps, match and maintenance‑of‑effort (MOE) calculations, indirect costs, equipment approval and subrecipient monitoring.
Key financial rules: Presenters emphasized the LSTA statutory 4% administrative cap for SLAA administrative costs. A presenter summarized: “SLAAs are allowed to use up to 4% of their federal funds from the grants to states program to cover administrative costs, but you're not required to do so.” They also restated the flat match rule: match (or cost share) is 34% of total program costs, and recipients must notify IMLS promptly if they cannot meet the match requirement.
MOE, recalculation and waiver process: IMLS staff explained that MOE is measured as a 3‑year average of state library expenditures; a state may submit a recalculation request to change which cost categories count toward MOE, and IMLS will reopen prior SPR years to recertify figures if a recalculation is approved. Waivers are available only for ‘‘exceptional and uncontrollable circumstances’’ that cause a demonstrable statewide fiscal decline — for example, a major natural disaster — and IMLS will compare the SLAA’s appropriation to the state’s overall fiscal indicators when evaluating requests. Presenters warned that failure to meet match is remedied by returning federal funds at the same percentage missed, while failure to meet MOE (without an approved waiver) reduces future allotments by that percentage.
Indirect costs and MTDC: Presenters clarified that subrecipients may use the de minimis indirect rate (currently 10%) if they have no negotiated rate, and SLAA pass‑throughs must honor a subrecipient’s federally negotiated rate when documented. The panel reviewed MTDC exclusions such as equipment, participant support costs, scholarships and portions of subawards exceeding $25,000.
Equipment, procurement and monitoring: IMLS reiterated equipment rules: currently items valued at $5,000 or more are treated as equipment (the threshold will move to $10,000 in the future), preapproval is required, a biennial physical inventory must be maintained, and disposition of equipment with current fair market value above the threshold requires IMLS approval. Presenters also underscored procurement expectations under 2 CFR, including domestic preference 'to the greatest extent practical' and sole‑source justifications when necessary. For subawards ≥ $30,000, SLAA must report to FSRS (FFATA reporting) within 30 days.
Practical tips and resources: Presenters encouraged states to use the SPR financial status report to cross‑check MOE, to aggregate and attach supporting spreadsheets when reporting multiple subgrants, and to maintain clear documentation to support waiver or recalculation requests. They recommended routine reconciliation, risk assessments for subrecipients, and additional monitoring (site visits or enhanced reporting) when risk is identified.
What’s next: Staff said program officers are available for state‑specific guidance and encouraged use of IMLS manuals and eGMS messaging for formal requests and approvals.
