I think your friendly state agency "expert" has much to learn.  You might
start with showing him the definitions of  "cash contributions", "cost
sharing and matching" in A-110, and then go on to __.23.

This "donation" would not, in my judgement, meet the definition of cost
sharing, because it is not a "portion of program or project costs".

Chuck

At 12:31 PM 6/13/00 -0500, you wrote:
>Our university has been a subcontractor for federal flow-through dollars
>from a certain state agency for several years.  Until now there has been no
>cost-share requirement for these funds.  The state agency has now decided
>(discovered?) that they can leverage more federal dollars if they require us
>and their other subcontractors to provide cash cost-share.
>
>However......As I understand from from the agency representative, he does
>not really want "cost-sharing funds" to be provided by us as subcontractors
>on a grant, at least not "cost-sharing" in the sense of direct expenditures
>from institutional funds in support of the project that operates on our
>campus.  What he really wants is "front money" --  He wants us to make a
>"donation" to  his agency, which he can put into an account at his agency
>and they can use our dollars, combined with similar donations from other
>subcontractors, to leverage federal dollars.  Eventually, these dollars
>would flow back to us in contracts from his agency.  There is the assumption
>that when the dollars come back to us, they will be accompanied by some of
>the federal dollars that his agency obtained by using our dollars as
>matching funds.
>
>I have never encountered an arrangement like this, and it strikes me as
>risky at best.  I'd appreciate reactions and/or insights from colleagues who
>may have experience with anything similar. Thanks.......
>
>Linda S. Freed
>Office of Grants and Sponsored Programs
>Austin Peay State University
>P. O. Box 4517
>Clarksville, TN  37044
>voice:  931-221-7881; fax: 931-221-7304
>e-mail:  xxxxxx@apsu.edu
>
>
>======================================================================
>  Instructions on how to use the RESADM-L Mailing List, including
>  subscription information and a web-searchable archive, are available
>  via our web site at http://www.hrinet.org (click on "Listserv Lists")
>======================================================================

Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Express Delivery Only:
 Sanger Hall, Rm. 1-073
 11th & Marshall Streets
 Richmond, VA  23219
Voice:  804-828-6772
Fax     804-828-2521
OFFICE e-mail   xxxxxx@VCU.EDU
Personal e-mail xxxxxx@vcu.edu
http://views.vcu.edu/ospa/

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================