AmeriCorps Matching Letter

by Roberto J. Rodríguez

UNITED STATES DEPARTMENT OF EDUCATION WASHINGTON, D.C. 20202

April 1, 2022

Dear Colleague:

I am writing in response to questions brought to the U.S. Department of Education (Department) regarding the permissibility of Department grantees and subgrantees using Federal funds granted by the Department—including annually appropriated funds and COVID-19 pandemic relief funds—as matching funds for AmeriCorps programs. In brief, a Department grantee or subgrantee may use program funds as matching funds for AmeriCorps programs.

AmeriCorps operates a variety of programs that bring people together to tackle the country’s most pressing challenges through national service, including in schools. In particular, AmeriCorps volunteers regularly support students in underserved districts in a manner that promotes equity and excellence, for example, by providing high-quality tutoring, mentoring, or coaching. This work of AmeriCorps members is particularly important for helping students recover from the impact of the pandemic and addressing their social, emotional, mental health, and academic needs.

Grantees and subgrantees have raised the aforementioned question because the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that, "except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: … (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period." 2 C.F.R. § 200.403 (emphasis added).

Consistent with 2 C.F.R. § 200.403(f), the AmeriCorps statute and regulations provide the authority to use Department funds for such cost sharing or matching. 42 U.S.C. § 12571(e); 2 C.F.R. § 2205.306. Accordingly, a Department grantee or subgrantee may use program funds as matching funds for AmeriCorps programs.^[1] This conclusion is based on the AmeriCorps statute and rule on the use of Federal funds for match and how these AmeriCorps governing authorities interact with Department statutes and regulations.^[2] This conclusion also stems from close consultation with and consideration of the position of other relevant Federal agencies on this topic. All other relevant Uniform Guidance and applicable Federal requirements would apply, including that the cost is reasonable and necessary for an allowable activity, is consistent with the statutory purpose of each program or approved application, otherwise meets all programmatic requirements, and AmeriCorps agrees that funding from the Department would be considered as an acceptable source of matching funds.

The Department fully supports and encourages state and local partnerships with AmeriCorps programs, including many activities in support of student learning and success that are appropriate uses of education funds. Thank you for all that you do to support students, families, and schools during this challenging time.

I look forward to the partnerships that will develop and grow with AmeriCorps programs to provide additional supports to students in underserved districts.

Sincerely,

/S/

Roberto J. Rodriguez
Assistant Secretary, Office of Planning, Evaluation and Policy Development
U.S. Department of Education

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1. This authority would be limited if a Department program expressly prohibits the use of funds for a cost share or match in another Federal program. We are not aware at this time of any such prohibition in Department programs whose funds would likely be considered for an AmeriCorps match.
2. This guidance is based on the relevant statutory and regulatory authorities applicable to AmeriCorps and is limited to the use of Department funds as matching funds for AmeriCorps programs.