Kellie,
I don’t know for sure, but hopefully my posting will
encourage someone who does know to respond. My initial reaction is that
an SBA loan would be considered a federal award for this purpose. The goal of
the regulation on cost sharing is to preclude one from using federal funds from
one source as cost share on a project funded by different federal dollars, and
it would seem that the SBA loan is federal money, at least until it is paid
back.
Others more knowledgeable are kindly invited to jump in.
Carolyn
From: Research
Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Kellie
Dyslin
Sent: Monday, May 18, 2009 1:13 PM
To: xxxxxx@hrinet.org
Subject: [RESADM-L] Small Bus Administration loan as cost share?
Dear all:
Forwarding the
question below on behalf of Jason Tardy in my office here at NIU. Thanks in
advance for any advice.
Colleagues,
I am working on a
Department of Energy proposal which requires 20% cost-share. My university will
be partnering with a small business. Said small business would like to use
an SBA loan as part of the cost-share.
Have any of you ever dealt with this situation? I have researched the
regulations and found the following under CFR 600.313 (DOE Financial Assistance
Rules):
"Acceptable
contributions. All contributions, including cash
contributions and third party in-kind contributions, must be accepted as
part of the recipient's cost sharing or matching if such contributions
meet all of the following criteria:
...
(5) They are not
paid by the Federal Government under another award
unless authorized by Federal statute to be used for cost sharing or
matching."
...
So the question is
whether an SBA loan is considered an "award" or whether there is a
statute authorizing its use for cost-sharing.
-----------------------------------
Jason Tardy
Research Development
Specialist
Office of Sponsored
Projects
Engineering Bldg.
140
Northern Illinois
University
DeKalb, IL 60115
Phone: (815)
753-6911
Fax: (815) 753-1310
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