Nonprofit Accounting Basics



John Meriscko

National Association of County and City Health Officials

Eligibility specifies the criteria for determining the individuals, groups of individuals, or subrecipients that can participate in the program and the amounts of assistance for which they qualify.

This is the eligibility of those participating in the program funded by the grant or contract rather than the eligibility of the primary recipient. If a grant is awarded to provide lunches for individuals meeting certain criteria, the grant recipient must be able to demonstrate that the individuals receiving the lunches met the criteria established in the grant.

The eligibility may be determined solely by the grant or contract recipient or by using another entity to perform part or all of the eligibility determination. For example, a state arranges with local government social services agencies to perform the “intake function” (e.g., the meeting with the social services client to determine income and categorical eligibility) while the state maintains the computer systems supporting the eligibility determination process and actually pays the benefits to the participants. The state is fully responsible for federal compliance for the eligibility determination as the benefits are paid by the state. The state shows the benefits paid as federal awards expended on the state’s Schedule of Expenditures of Federal Awards.

The specific requirements for eligibility are unique to each federal program and are found in the laws, regulations, and provisions of contract or grant agreements pertaining to the program. Depending on the number of participants in the program, manual systems to very large sophisticated computer systems may be used.