Any subaward passing through federal funds should be clearly identified as
such by the prime.  If it is not, you can assume it is a procurement by the
prime, not subject to flowdown of federal regulations.

Chuck

At 05:28 PM 1/13/2005, you wrote:
>Laurie,
>
>It's always been my understanding that you can't match one federal
>project with another federal grant.  The only caution is that the
>non-federal project isn't a pass-through of federal dollars that isn't
>easily recognizable.
>
>Lois Smith,
>Associate Controller, Sponsored Programs
>The University of Akron
>330-972-6563
>xxxxxx@uakron.edu
>
>
>-----Original Message-----
>From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On
>Behalf Of Laurie Chamness
>Sent: Thursday, January 13, 2005 4:52 PM
>To: xxxxxx@HRINET.ORG
>Subject: [RESADM-L] cost sharing with federal dollars
>
>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
>
>
>======================================================================
>  Instructions on how to use the RESADM-L Mailing List, including
>  subscription information and a web-searchable archive, are available
>  via our web site at http://www.hrinet.org (click on "Listserv Lists")
>======================================================================
>
>
>======================================================================
>  Instructions on how to use the RESADM-L Mailing List, including
>  subscription information and a web-searchable archive, are available
>  via our web site at http://www.hrinet.org (click on "Listserv Lists")
>======================================================================

Herbert "Chuck" Chermside, CRA
Director Emeritus, VCU Sponsored Programs
Executive Director, Research Administrators Certification Council
1915 Robindale Rd.
Richmond, VA 23235-3931
804-320-5502
xxxxxx@verizon.net

======================================================================
 Instructions on how to use the RESADM-L Mailing List, including
 subscription information and a web-searchable archive, are available
 via our web site at http://www.hrinet.org (click on "Listserv Lists")
======================================================================