Jennifer: There's no reason why you can't take an overage on a Fed grant and charge it to a non-fed grant, provided there are no restrictions on the non-fed grant. Back in the day, we used to frequently send a proposal to a fed and non-fed funding source. Usually the non-fed came in with a small amount of funding, while the fed took the lion's share. We also used the non-fed share as cost sharing. You do need to take care that the non-fed share doesn't have fed funds in it. Dr. Chuck is right that the non-fed portion should clearly state that there ARE fed funds included in the award - like a CFDA number or a fed award number, or the presence of OMB or FAR citations. Absent those, have at it! Greg Currently in a thaw mode. Calgary was -50 on Wed - Fri morning (wind chill), -35 without wind. Brings a whole new meaning to the word "cold". ----- Original Message ----- From: "Jennifer Morgan" <xxxxxx@MUSC.EDU> To: <xxxxxx@HRINET.ORG> Sent: Friday, January 14, 2005 4:17 PM Subject: Re: [RESADM-L] cost sharing with Pass Through federal dollars > 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") > ====================================================================== > ====================================================================== 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") ======================================================================
