This is a most interesting question.
1) This inquiry was broached with federal auditors during one of the national IDC conferences. Overall for federal sponsored agreements, the auditors responded that cost share, match and In-kind contributions must meet the exact same Allowability Criteria as direct charged costs under the grant terms and conditions as well as federal regulations..
For example, if a federal grant does not permit the direct charging
of clerical/administrative salaries, then institutions could not use these
as cost share..
2) The NIH GPS has the best statement of such by mandating that "Costs
used to satisfy matching or cost sharing requirements are subject to the
same policies governing allowability as other costs under the approved
budget."
http://grants1.nih.gov/grants/policy/nihgps_2001/part_i_1.htm#MatchingorCostSharing
3) Also, A-110 (section 23) alludes to this same principle, via the
clauses for "Allowable under the applicable cost principles" and "Are provided
for in the approved budget when required by the Federal awarding agency".
http://www.whitehouse.gov/omb/circulars/a110/a110.html#23
4) However, In truth, I do not know if USDEd has this specific wording
in its grants policy.
5) Finally this same criteria was promulgated during the recent 9/2002
NCURA Video-conference.
I hope that my response is of some value.
Regards,
Steve
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On 10/01/2002, Dawn Underwood wrote:
I have been assisting with the budget preparation for a McNair
submission to the US Dept of Ed. Our board of trustees has approved
an undergraduate tuition waiver for participants of this program.The guidelines state that payment of academic year tuition may not be
charged against the grant.The question is, if this cost is unallowable on the sponsor request,
is it also unallowable as a cost share from the university? This is a
sizable chunk of money, and the PI is interested in showing it as cost
share in the proposal.Your responses are greatly appreciated!
Dawn Underwood
Academic Research & Sponsored Programs
Ball State University======================================================================
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