But that wasn't the question, the question is can you take an overexpenditure on a nonfederal grant and cover it with FEDERAL dollars.

"Can you use federal dollars to cover a cost share obligation for a non-federal grant?" was the question.  So far, everyone that has answered has said you can use unrestricted non-federal dollars to cover the cost share on a federal grant... which is what I've always assumed to be true.

But how can someone say that a restricted federal grant, where every dollar is supposed to be allocable to the project for which the federal dollars were funded, be used to cover a cost share commitment on a non-federal project?  That is contrary to everything I've ever read or heard about fiscal compliance.

If I have gotten this wrong, can someone tell me where it is written in the circulars that money can be used from federal grants to pay for the cost share commitment owed on a non-federal grant?

-Jennifer

Jennifer Morgan, MHA

Associate Chair for Research Administration
Department of Psychiatry and Behavioral Science

Southern Section President
Society of Research Administrators International

Medical University of South Carolina
67 President Street, Suite 504
Charleston, South Carolina  29425

voice:  843-792-0191
fax:  843-792-0048
email:  xxxxxx@musc.edu

>>> xxxxxx@COX.NET 01/16/05 02:41PM >>>
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
==========================

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