Re: cost sharing with Pass Through federal dollars Jennifer Morgan 14 Jan 2005 16:17 EST
Going back to the original question "Is it allowable to use federal grant dollars to cost share on a non-federal grant?"... Chuck and Lois... Are you really saying that you can take FEDERAL dollars and pay the cost share for a NONFEDERAL grant? How can this be reasonable, allowable and allocable to the federal project that is being charged for the cost share? If this is true, I can reconcile all my deficit accounts and maybe even my checking account! (just joking - for the auditors that might be reading this!) -Jennifer >>> xxxxxx@VERIZON.NET 01/14/05 11:04AM >>> 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") ====================================================================== ====================================================================== 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") ======================================================================