Good Morning Heather:
Thank you for your follow up email. I just received confirmation from the Indirect Cost Group here within the U.S. Department of Education that the below June 30,
2020 response that I shared with you is correct: Thank you for your follow up question. No you may not include the 8% indirect costs on the match side of the funding as part of your contribution and should be
excluded from consideration for matching or cost sharing purposes.
Thank you for checking. Have a nice day!
Hello Shedita,
Since the deadline for these proposal applications is nearing and I have a number of other people from other applicant institutions also wanting to know the final answer on this I am following up.
Thank you.
Heather
From: Nelson, Heather (xxxxxx@uidaho.edu)
Sent: Tuesday, June 30, 2020 11:36 AM
To: Alston, Shedita <xxxxxx@ed.gov>
Subject: RE: One more question about allowable match for the TPSID program
Hi Shedita,
I guess I’m not understanding. We are not calculating/capturing the indirect costs twice. The indirect costs on the match side are
not being reimbursed.
Total MTDC base for direct costs (federal + match) = $370,371
Total indirect costs for the project (federal + match) = 29,629
$29,629/$370,371 = 8%
If the agency was paying for the entire cost of the project then we would be using the $29,629 as the indirect cost. If you take that entire project and split it 75/25 then the indirect costs would flow to the
institutions match side.
I haven’t been able to find the 2 CFR 200 guidance on this, if it is even spelled out directly, but I have never seen a restriction like this from the Department of Education or any other federal agency.
Thanks for your patience.
Heather
Hello Heather:
Thank you for your follow up question. No you may not include the 8% indirect costs on the match side of the funding as part of your contribution and should be
excluded from consideration for matching or cost sharing purposes. The purpose of the 8% indirect cost rate is to limit indirect cost reimbursement. If you separately charged those same type costs as direct or used them for matching,
you would be circumventing the limitation.
Hope this helps Heather. Have a nice day.
Hi Shedita,
Thank you for following up and I’m sorry that my question was not clear. May I presume that we are allowed to include 8% indirect costs on the
match side of the funding as part of our contribution? This is standard 2 CFR 200 allowability, but the statement that match “…is comprised only of total
direct funds” is causing us concern. Here is another, hopefully more clear example:
Federal funds Match funds
Direct MTDC: $277,778 $92,593
Indirect: 22,222 7,407
Total: $300,000 $100,000
Match = 25% of project
Thanks again.
Heather
Good Afternoon Heather:
Thank you for your email. Here is the response to your question:
This response came from the Office of General Counsel here at the U.S. Department of Education:
“Given this legislative history, and the general interpretation of similar language in grant programs, we believe that the better legal reading is that the match amount has to be based on the costs of the program
not the grant amount.”
Each applicant is required to match the Federal funding they are applying to receive under the TPSID program, in which case one would just take the matching requirement amount that your project is proposing (the
TPSID program’s minimum matching requirement amount is 25%) of the costs of the project (not of the costs of the federal award) to determine the match.
This encompasses both the Federal and non-Federal cost of the grant, which means that match has to be calculated on the basis of both the Federal and non-Federal amount, in other words the total project cost.
Knowing this, it is recommended that applicants carefully consider whether or not they will propose to a matching requirement amount that exceeds the minimum 25% requirement under the TPSID program.
I hope this helps. Have a nice day.
Hi Shedita,
I know that you have been out, but I’m just following up on this question.
Thank you very much.
Heather
Hello Shedita,
Thank you for the confirmation on the required match. There was a statement on the Power Point (slide 24) as follows:
Please note: the matching requirement (which is comprised only of total direct funds) can not be met with federal funds.
I am concerned that the highlighted statement implies that our institution would not be able to use the 8% indirect rate on the match expenses that are incurred. I don’t believe that is the case, because it would
go against the applicable federal guidance in 2 CFR 200, but would like you to confirm. Here is an example:
Institution provided match: 50,000 in internal salaries and fringe per year
We should be able to include 8% on the $50,000 ($4000) in the total provided match in our budget, correct?
Thanks again.
Heather
Heather Nelson, Associate Director
Office of Sponsored Programs
University of Idaho
(208) 885-6680