1)  You were correct to disapprove the application for the reasons you gave.

2)  Anyone who does it that way is courting major disallowances on audit,
and maybe even charges of fraud.

BUT there was only a small error in his plan.

The PI has only 100% effort to give, even if you have to calculate: 100% of
a 9-month contract and 100% of a summer contract.  Note that some
institutions may have a limitation of how many months may be in the summer
period for faculty members.  (This is not the same as limiting only certain
opportunities in the summer and letting others fill the 3 months of
summer.)  If your institution allows 3 months summer work, then that PI
could work three months, and charge 1 month to the grant and make a
personal (third party) contribution of 2 months worked without
salary.  That would be 100% of 12 months.

In many institutions, employee benefits for the whole year are paid for
over the 9 month academic year, so the value of that cost sharing would be
the 2 months salary foregone, but no benefits.  The institution can argue
from a strong position that it is contributing imputed F&A on that salary,
also.

Additionally, USDA limits F&A recovery on its grants.  7 CFR 3019.23 (b)
states "Unrecovered indirect costs may be included as part of cost sharing
or matching only with the prior approval of the Federal awarding
agency."  So additional matching could come from unrecovered F&A only if
approved by the agency.  Worth a try, but get it settled before submitting
the proposal.

Chuck

At 03:38 PM 3/19/2004, you wrote:
>I would much appreciate some comments on the following situation:
>
>In a recent grant application (which required matching funds from Evergreen)
>to a university administering US Department of Agriculture funds, a faculty
>member requested 1.5 months of summer salary and proposed to contribute 2
>months of salary toward a required match.  Our faculty are on 9 month
>contracts, so this faculty member would have been compensated for 10.5
>months, and, in addition, contributed a match of 2 months' salary.
>
>The faculty member justified this by saying that 1) his/her regular work
>included work to be done under the grant (the grant involved curriculum
>development and implementation) and 2) "other colleges and universities
>regularly do this."
>
>We disapproved the grant application because the total time involved for the
>faculty member would have been 12.5 months annually, and because "everyone
>else does it" would not withstand audit.  My understanding is that faculty
>may only be compensated (at least under NSF rules) for two summer months -
>11 months in total.
>
>So I have two questions:
>
>1)  Were we correct in disapproving the application for the reasons
>explained above?
>
>and - 2)  Does everybody do it???
>
>John McCann, M.P.A., Ph.D.
>Academic Grants Manager
>Office of the Academic Vice President and Provost
>The Evergreen State College
>2700 Evergreen Parkway NW
>Olympia, WA 98505
>
>E-mail: xxxxxx@evergreen.edu
>Phone: 360-867-6045
>Fax: 360-867-6745
>
>
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Herbert B. Chermside, CRA
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Voice:  804-827-6036
Fax     804-828-2051
e-mail xxxxxx@vcu.edu

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