My question has to do with meeting requirements for documentation of third party inkind cost share for sponsored programs….

A110 state in subpart C section 23:

All contributions, including cash and third party in-kind, shall be accepted as part of the recipient’s cost sharing or matching when such contributions meet all of the following ….

 (a) 2  states “are not included as contributions for any other federally-assisted project or program.”

My questions are:  Is it allowable to use non-federal cost share on an NSF project and same money ALSO on an industrial project?  Is this considered double counting? 

Who accounts for this to the sponsors (departmental administrators or central)?  Do we need to ensure that the same cost share dollars are not used for two projects?  Or HOW do you ensure this?  What is the process for documentation?

We have been trying to implement the consistency standards in A21 (501 a-d) across the board on many issues.  In other words, treating financial management of our industrial projects the same as federal, i.e requiring the employer-employee relationship for tuition remission under both federal and industrial projects…..and many others. 

SO my real question is…. How far can we stretch A110 C- 23 (a)2……Should we only allow cost share to be used on one project (Federal or Non- Federal)?  Should we insist upon disclosure in the proposal to each sponsor?

Any input is appreciated.

Thanks

Anita Quinn
Director of Research Services
Michigan Technological University
1400 Townsend Drive
Houghton, MI     49931-1295

phone - 906-487-2225
fax - 906-487-2245
xxxxxx@mtu.edu