I think we're all blind.  Or read what we wanted to read in your question.
Or maybe that frostbite went through my skull and affected my brain.

I've never seen a non-fed deficit covered by a fed award except in extremely
rare and highly justified circumstances.  The only one that really comes to
mind is where you have the two awards, one fed one non, awarded for the same
proposal.  The funds are expended out of the non-fed at a higher percentage
than the funded ratio would dictate.  The PI certifies that s/he made a
mistake in allocating certain expenditures, and documents that they should
have been charged to the fed portion usually by showing where the expenses
were budgeted in the Fed portion not the non-fed.  This is for a SPECIFIC
charge, not an overall deficit covering exercise.  That it just so happens
that the deficit is covered is a miracle.

And lots of luck getting a PI to state in writing that they made a mistake.

Greg

----- Original Message -----
From: "Jennifer Morgan" <xxxxxx@MUSC.EDU>
To: <xxxxxx@HRINET.ORG>
Sent: Tuesday, January 18, 2005 9:49 AM
Subject: Re: [RESADM-L] cost sharing with Pass Through federal dollars

> 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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