Volunteer Services as Local Match Funds

Q. Currently, the Department of Aging and Disabilities (DAD) is the sub-recipient of the 5310 grant held by VTrans (Vermont Dept. of Transportation.) My agency, Council on Aging for SE Vermont, Inc. (COASEV) along with several public transit providers have submitted an application for SFY05 5310 funds to DAD. My agency (COASEV) has followed the procurement procedures as directed and wants to "contract" with several small local volunteer networks to provide transit services. These networks will be reimbursed the allowed mileage and administrative costs but will donate driver hours as an in-kind match thus relieving the Council on Aging of its 20% local match requirement. VTrans is telling us that this is not allowed and that the in-kind match must be in cash and provided by COASEV or that COASEV must maintain the volunteers. Please clarify this.

A. The controlling provisions are in 49 CFR 18.24 and FTA Circular 9070.1E. Both allow volunteer services to be used as local match but the grantee (VTrans) would not be barred from placing more stringent limits on sub-grantees.