Hi All,

I've posed these questions to a number of folks in my region and have
received some, uh, "wildly divergent" answers.  So, I'm going to put the
issues to the broader RESADM community.

First, the scenario: a Project Director needs to supply a 1:1 match on a
non-research grant and wants to know if she may count her students'
volunteer time on the project as an in-kind match.  It's worth noting
that the students aren't being paid, either with agency or university
funds, although such pay would be considered an allowable and necessary
direct cost.  So, given there's nothing in the accounting system that
could substantiate the effort, can we use this as in-kind cost share,
provided we document the effort in a log and value it at minimum wage?
(Personally, I'm real uncomfortable with this, but some folks have
assured me that this practice has even survived an audit.)

Second, I'm still confused as ever about using unrecovered F&A as cost
sharing.  I know that under A-110 Section 23 it is an allowable practice
provided prior agency approval is given, but I'm confused about the
implications of such a practice vis-a-vis A-21.  As in the above
scenario, there is nothing in the accounting system that would
substantiate the cost share.  Or am I missing something here?  Moreover,
wouldn't the unrecovered F&A used as cost sharing have to be taken out
of F&A pool for future F&A negotiations?

I appreciate your collective thoughts/wisdom on this!  I've read A-110
and A-21 a number of times and still am not sure of the answers.

Thanks,

Craig

--
Craig Reynolds / Office of Research and Sponsored Programs /
Foust 251 / Central Michigan Univ. / Mt. Pleasant, MI 48859 /
T: (517) 774-3859 / F: (517) 774-3438 / E: xxxxxx@cmich.edu

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