Questions and Answers Regarding Retroactive Use of Toll Credits
Question (Q1): A State initiated a project three years ago and has since been reimbursed at 80% since that time. The State now wants to apply toll credits to the 20% non-Federal match that has already been paid. Can the State use toll credits to apply Federal-aid funding to cover the 20% match that has already been paid from project start to date?
Answer (A1): Toll Credits may be applied on progress payments made on or after the point of approval to use toll credits on the project. A State may not bill retroactively for progress payments already made on the project (i.e., the 20% match already paid).