Steve’s citation is accurate. The logic is this: When you get full F&A, you are already being reimbursed for space in the “F” part of F&A. If you then show it as cost sharing, the space is being counted twice in the same budget. In effect, you’d be double-dipping.
Gene Stein
San Diego State University Research Foundation
(619) 594-4424
xxxxxx@foundation.sdsu.edu
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of ETHEREDGE, STEVE
Sent: Friday, May 25, 2012 9:25 AM
To: xxxxxx@lists.healthresearch.org
Subject: Re: [RESADM-L] Cost sharing space
See OMB Circular A-21 Section C11 which reads in part “…Further, no final cost objective shall have allocated to it as a direct cost any cost, if other costs incurred for the same purpose, in like circumstances, have been included in any F&A cost pool to be allocated to that or any other final cost objective.”
R. Steven Etheredge, CRA
Asst. Director, Policy & Compliance
Sponsored Awards Management
University of South Carolina
901 Sumter Street, Suite 501
Columbia, SC 29208
803-777-4457 phone
803-777-4136 fax
From: Research Administration List [mailto:xxxxxx@lists.healthresearch.org] On Behalf Of Maureen McMahon (Contractor)
Sent: Friday, May 25, 2012 11:22 AM
To: xxxxxx@lists.healthresearch.org
Subject: [RESADM-L] Cost sharing space
Hello all-
I am looking for a specific citation/source that states that space that is included in an organization’s overhead rate may not be used as cost share on a proposal where full overhead is charged. If anyone can point me in the right direction, I would appreciate it.
Thanks,
Maureen
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