Is it allowable to use federal grant dollars to cost share on a
non-federal grant?  Our Associate Director of Grants and Contracts
Accounting said that using federal dollars as cost share is prohibited
by the federal government, and she cited:

A21, C4c.  "Any costs allocable to activities sponsored by industry,
foreign governments, or other sponsors may not be shifted to
federally-sponsored agreements."
and
A-110, .23(a) "All contributions, including cash and third party
in-kind, shall be accepted as part of the recipient's cost sharing or
matching when such contributions meet all of the following criteria."
Criterion number 5 says:  " Are not paid by the Federal Government under
another award, except where authorized by Federal statute to be used for
cost sharing or matching."

--
Laurie Chamness
Assistant Director
Office of Research and Sponsored Programs
Medical University of South Carolina
PO Box 250808
Charleston, SC  29425

Ph (843) 792-3832
Fax (843) 792-6447
E-Mail:  xxxxxx@musc.edu

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