Can an application for funding originally submitted for another Infrastructure Investment and Jobs Act programs be repackaged and submitted for the State and Local Cybersecurity Grant Program?

The Notice of Funding Opportunity for State and Local Cybersecurity Grant Program (“SLCGP”) does not specifically address repackaged applications.[1] However, an eligible entity may be able to repackage and submit to the SLCGP an application previously submitted for another Infrastructure Investment Jobs Act (IIJA) program, provided the application is complete, includes all information required for eligibility under the program being applied to, and did not result in funding under another grant program.

Determinations of FY22 SLCGP funding allocations will be formula-based as described in the notice of funding opportunity (“NOFO”). SLCGP also requires a non-federal cost share. The SLCGP NOFO states that even if the actual cost of an SLCGP grant application or project exceeds the grant amount under SLCGP, the grant amount will not change. The NOFO, however, does not specifically state anything about use of other federal grants to fund any potential cost overrun.

If a previously submitted application for another IIJA program resulted in funding allocation, in addition to SLCGP requirements, applicants should review the requirements of the other grant program and confirm that there are no restrictions against submitting that application for SLCGP and does not result in funding for the same projects (a duplication of benefits). 

Per the Uniform Administrative Requirements in 2 C.F.R. 200, entities should ensure that SLCGP funds do not duplicate other federal funding sources.[2] FEMA describes Duplication of Benefits (“DOB”) for entities using multiple federal funding sources in FAQs as follows:

A DOB occurs when an entity receives (i.e., draws down/takes possession of) multiple sources of federal funding assistance, or outside funding (e.g., insurance), for a specific eligible cost or activity where funding has already been used for the entirety of that particular cost or activity, or in excess of the amount needed for that specific eligible cost or activity.[3]

Last Updated: November 7, 2022