We rarely use volunteer (in-kind) effort for cost sharing. When we do, the
documentation criteria in section .__23d, A-110 are followed. We will allow
a reasonable benefits and payroll taxes allowance and apply the appropriate
University's indirect cost rate, subject to the awarding agency approval in
.__23b, A-110. The donated labor and benefits would be included in the MTDC
base.
From: John D. Pepe [mailto:xxxxxx@STROUDCENTER.ORG]
Sent: Wednesday, January 24, 2001 8:04 AM
To: xxxxxx@HRINET.ORG
Subject: Re: Cost sharing questions
Craig -
My understanding related to your scenario:
First, volunteer time supported by a valid effort reporting time/log sheet
would be acceptable as an in-kind match. Also, the value of volunteer
services provided should be determined by the prevailing wage paid for
similar duties performed, and is not necessarily limited to minimum wage.
Secondly, even though volunteer wages are not expensed in the accounting
system, F&A on this amount can still be determined and recognized as cost
share. The value of "material" volunteer services enters the F&A mix when
the rate is determined/negotiated with the federal cognizant agency since it
becomes a component of the denominator in determining the rate.
John D. Pepe
Controller
Stroud Water Research Center
970 Spencer Road
Avondale, PA 19311-9514
Voice: (610) 268-2153, ext. 253 Fax: (610) 268-0490 E-mail:
xxxxxx@stroudcenter.org
-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org]On Behalf
Of Craig Reynolds
Sent: Wednesday, January 24, 2001 8:12 AM
To: xxxxxx@HRINET.ORG
Subject: Cost sharing questions
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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