As I read the CFR, The US Department of Education typically only limits
indirect cost costsharing on training grants (examples summer institutes,
training programs for selected participants, the introduction of new or
expanded courses) or projects that implement previously developed materials
and methods and require no significant adaptation of techniques or
instructional services to fit different circumstances.  Projects that
involve research, development and dissemination of new educational materials
and methods are not considered training grants.

The specific clause that limits the use of indirect costs to satisfy
matching or costsharing requirements applies to training grants and is set
forth in 34 CFR 75.562.c3

-----Original Message-----
From: Youngers, Jane [mailto:xxxxxx@UTHSCSA.EDU]
Sent: Wednesday, February 23, 2000 2:22 PM
To: xxxxxx@HRINET.ORG
Subject: Re: Cost Sharing Indirect Costs

As a reply to the whole group:  A-110 allows agencies to decide whether or
not indirect cost waivers or differences between the allowed rate and the
negotiated rate can be used as a match.    For example, the Department of
Energy allows the difference to be used as cost sharing as does NSF.
Department of Education specifically prohibited the use of the difference
between negotiated rates and 8% as cost sharing or matching.  You need to
consult the specific agency guidelines or implementations of A-110 (in ED's
case you would find it at 34 CFR 74, 77.

Cheers,
Jane
Jane A. Youngers
Director, Grants Management
Mail Code 7828
University of Texas Health Science Center at San Antonio
7703 Floyd Curl Drive
San Antonio TX  78229-3900
phone 210.567.2333
fax 210.567.2344
email xxxxxx@uthscsa.edu

-----Original Message-----
From: Victoria Steel [mailto:xxxxxx@CMSU2.CMSU.EDU]
Sent: Wednesday, February 23, 2000 11:39 AM
To: xxxxxx@HRINET.ORG
Subject: Re: Cost Sharing Indirect Costs

I would like to add something to this request. Currently our institution is
preparing a proposal for the Department of Education's Preparing Tomorrow's
Teachers To Use Technology (PT3) Program. The program requires a 1:1 match
from the applicant. The guidelines state that the indirect costs cap is 8%
and that the difference between the 8% and our negotiated rate can not be
used as a match. This is the first time we have encountered this position
from a funder, can anyone provide insight?

Victoria Steel

>I noticed in last week's discussion about FIPSE F&A rates that a number of
>colleges and universities indicated that they had used the DoEd suggested
>rate of 8% of TDC and showed as part of their cost share the difference
>between this figure and the amount they would have recovered for F&A had
>they used their federally-negotiated rate.
>
>In several NCURA-sponsored workshops I've attended over the past six
>months, however, I have heard several times that doing this will ultimately
>bring down an institution's F&A rate.
>
>I'm curious as to whether other institutions have any policies regarding
>this issue and how frequently this practice is used when cost sharing is
>required and F&A cost restriction are required or strongly encouraged.
>
>And could someone who understands better than I do the issues surrounding
>the negotiation of indirect rates explain (again) to me why it might be a
>bad idea to do this?
>
>Thanks.
>Laura C. Hartley, Ph.D.
>Grants Officer/Staff Writer
>Office of the Provost
>Lesley College
>29 Everett Street
>Cambridge, MA 02138-2790
>Phone: 617-349-8795
>Fax: 617-349-8974
>email: xxxxxx@mail.lesley.edu

- - - - - - - - - - - -
Victoria Steel
The Graduate School
Humphreys 410
Central Missouri State University
Warrensburg, MO 64093

phone: 660.543.8099
fax: 660.543.8333

email: xxxxxx@cmsu1.cmsu.edu
www.cmsu.edu/graduate
- - - - - - - - - - - -

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