Ginger:

Neat problem!  I'm really looking forward to hearing what others have to
say about it.  Meanwhile, I'll chime in with my two cents.

The numbers I see here are approximately $5,000 fair market value for
the data, $11,500 base cost to generate the data, $23,000 which is $70K
funding less equipment costs of  $47K, and $70,000 representing the
total costs of the state project, including the costs of equipment
required to analyze , that generated the data..  All valid amounts.

A-110 allows for the donation of services and property that is valued in
accordance with A-21 (or A-87 for state agencies).  If the state agency
is not using federal funds, you could claim the full $70,000.  If you
felt that was excessive, you could exclude the one-time cost of the
equipment and claim $23,000.

A-110 also says that donated supplies should not exceed the fair market
value, and shall be reasonable.  That could put us at either the $11,500
number or $5000.  Both would be reasonable in my eyes, though possibly
not in the auditor's eyes.  They would probably want the lesser number.

The problem here is that data is not tangible by itself and has no real
value.  It's the analysis that gives the data value.  A-110 tries to
define value in terms of the marketplace and commodities.  This is an
intangible.  The section on Intangible property involves ownership and
disclosure under FOIA which doesn't help us at all here.

As such, I would fall back to the definitions and keep away from section
23 discussion altogether. Cost sharing or matching is defined as that
portion not paid for by the fed directly or indirectly.  So long as the
state's sources of funding is not federal, I'd take the full $70,000.

I could argue lots of sides on this one.

Good luck!!

Greg

Ginger Baker wrote:

>The University is preparing a proposal for a private agency that gets
>some federal funds.  This agency requires a significant match.  We have
>a state agency that is willing to donate a data set (in-kind
>contribution) for the University to use on the project.  The data is
>necessary to our project and will be collected through a parallel
>project occurring at the state agency over a two year period.  The state
>project is budgeted for a two year period at a total cost of $70,000
>including a $47,000 equipment purchase.  This "scrubbed" data set is not
>available commercially and the agency will be providing us with the data
>relevant to our project as it become available over the course of our
>one year project.  The state agency has asked for our assistance in
>assigning a value to the data set.
>
>I have considered recommending that it be valued at the cost of
>purchasing a data set that could be considered comparable which we think
>is approximately $5,000, but the cost to the state agency of collecting
>the data is actual $11,500, if you exclude the equipment purchase.  We
>don't want to undervalue the donation since we have a large match
>requirement, but we also want to be reasonable and not violate A-110.
>What do you suggest as the best approach to assigning a value to the
>data since it is not commercially available and we can't exceed fair
>market value?
>
>
>--
>
>Ginger Baker
>Manager
>Statewide Office of Cost Analysis
>
>University of Alaska
>Statewide Systems Office
>910 Yukon Drive, Suite 209C
>P.O. Box 756540
>Fairbanks, AK 99775-6540
>
>Email: xxxxxx@alaska.edu
>Telephone: (907) 474-6496
>Fax:   (907) 474-5167
>
>
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