Sorry to have misunderstood. No you cannot use federal funds on one project to cover overexpenditures on a non-federal project. Overexpenditures are quite different from promised cost sharing! Chuck At 09:49 AM 1/18/2005, you wrote: >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 >========================== > > >====================================================================== > 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") >====================================================================== Chuck Chermside 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") ======================================================================
