Thursday, January 15, 2015

Library Services and Technology Act (LSTA) January Updates

LSTA Funding Amounts for Wisconsin

LSTA amounts to WI 2012-2014
LSTA amounts to WI 2012-2014
The table at left shows the federal funding amounts that the IMLS has awarded Wisconsin in the past three years. The Division for Libraries and Technology has not yet received the IMLS’ 2015 federal award to Wisconsin. This has interrupted potential project activities submitted in 2015 LSTA grant applications. Purchases cannot be made until the state receives the LSTA award. 

MOE = Maintenance of Effort
Maintenance of Effort (MOE) image
Maintenance of Effort image
In order for state agencies to receive federal funds from the Institute of Museum and Library Services (IMLS), there is a legal provision called maintenance of effort (MOE) that a requires a state, as a condition of eligibility for federal funding, to maintain its financial contribution to a program at not less than the amount of the average of the past three years. An MOE formula ensures that federal assistance results in an increased level of library-related activity and that a state does not simply replace state dollars with federal dollars over time; maintenance of effort demonstrates a state’s commitment to library programs. Image is courtesy of Trey Fox from

The Wisconsin Division for Libraries and Technology (DLT) did not meet maintenance of effort in federal budget years 2011-2012 due primarily to a 10% cut in public library system funding at the state level. The Division submitted material requesting a waiver of the MOE stating that “The Director (of IMLS) may waive the [MOE requirement] if the Director determines that such a waiver would be equitable due to exceptional or uncontrollable circumstances such as a natural disaster or a precipitous and unforeseen decline in financial resources of the State.” IMLS, however, denied the initial request in June, 2014. 

An appeal of the denial was submitted to IMLS in November and was declined a second time.  IMLS did not agree that there was proof of “uncontrollable circumstances.” IMLS stated that they were “…required by law to reduce the State’s FY2015 allotment distributed to the SLAA by 4.97 percent.” (The SLAA is the State Library Administrative Agency and 4.97% is a reduction of approximately $135,000).

Risk Assessment
As of December 26, 2014 the Office of Management and Budget (OMB) issued “new guidance for the distribution of Federal grant resources to improve performance and outcomes while ensuring the financial integrity of taxpayer dollars.”  What does that mean? It means that changes have been made to the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards under 2 CFR Part 200 covering Grants and Agreements in the Code of Federal Regulations (CFR).   The Division for Libraries and Technology will have to develop internal controls for considering the merit and risk of awarding future grants and monitor compliance. 

Written by Terrie Howe, Public Library Development Team