Carolyn, I 'll answer part two of your question. I believe you can use the value of the partners' space as cost-share since they're not collecting indirect from the feds. However, I will defer to those more knowlegeable to give you advice on how the value of that space should be established. Barbara Carolyn Elliott-Farino wrote: > Help! We've been through this many a time and I can't believe it's > Friday and I'm buried in A-21 again trying to square cost sharing. Our > issue today is not cost sharing per se; rather, we are struggling with > the use of university space for a project and whether or not that can > be cost share. In this example we received the grant a year ago. We > had to cost share 50% of the cost of the project (really 1:1 > matching), indirects were limited to 8%, and unrecovered indirects > were not allowed as cost share. (Yes, you guessed — Dept of > Education). We proposed space (using depreciation costs) for much of > our cost share, e.g. office for assistant, computer lab, classrooms > etc. We only proposed space that would be 100% dedicated to the > project, but this is space on our campus and we are getting indirects > (although limited). Don't the indirects cover the use of this space? I > spoke with our internal auditor this morning and he seemed to think > that we might not be able to cost share space when we get indirects. > I checked the Resadm archives and found some treasures, which all seem > to indicate that it's not permissible to charge university space as > cost-sharing. Do you all agree with that interpretation? Also, we have > a couple of partners who aren't getting any indirects, just some money > for one position. Can they include space as cost-sharing since IDCs > aren't an issue? And doesn't it have to be depreciation, not rental > rates? > From the archives: > >"Cost sharing contributions have to be allowable >>under applicable cost principles, and the test I always use is if a cost >>sharing expense could be charged to a project, then it can also count as a >>cost sharing contribution." We don't direct charge space, so how can we charge it as cost sharing? > >Here's a terrific summary from 1998: > >"Thanks to the 17 Region III folks who responded to my question >about showing space as a direct cost costshare. If you have any >comments about this summary, or see errors, please feel free to >post them to the list. > >As most of you graciously pointed out, space is taken into account >in the indirect costs (i.e. facilities and administrative costs). So if a >grant is paying our full rate, then in effect the grant is paying it's >share of the facilities and therefore the space should not be listed >as a dollar amount of direct cost costshare. > >When we can only get a reduced indirect rate (or no indirect at all) >for whatever reason, the difference between what we would have >received at a our full rate and the lower rate, can be counted as a >costshare. By showing the indirect costs as costshare, we are in >effect showing facilities costsharing there, and again it would not >be appropriate to show space as a direct cost costshare. > >(Although as one person suggested, if we did NOT choose to show >the difference of full rate and reduced rate as cost share, I suppose >we could then try to show space as a direct cost costshare. But >having the indirect as costshare seems like a cleaner way to do it.) > >If I recall correctly, some time ago the US Dept of Ed said that we >CAN'T use the difference b/w our full indirect rate and its 8% >training grant rate as costshare. I suppose that trying to show >space as a direct cost costshare, in order to get some costshare >credit in this case, would be in effect using indirect cost as >costshare, violating the spirit of the ED regs. > >It appears that there is an exception a few of you pointed out that >may allow us to show space as a direct cost costshare. That is if >the College regularly rents out the space and charges anyone who >uses it--or at least outside groups. > >Lastly, one person said that an instance occurred in which the >sponsor REQUIRED that space costshare be shown directly. In >which case, that information was provided even though this >particular area does not usually charge for on campus users. > >In short, the basic answer was pretty straightforward but as nearly >always, there are twists and turns. > >Thanks again to everyone who responded and I hope you find this >summary useful." > >Wow! I found this useful. It unfortunately seems to confirm my suspicions that perhaps we cost shared incorrectly > >(oh drat — that will be a nightmare to fix). > > >Angie: > >What she said. This is very tenuous ground. The Fed would love for you to >cost share a building because it takes it out of your numerator when you >calculate your rate, and you don't get it back. If you do a use charge >(generally used after the building is fully depreciated), that comes out, >too. If you do use the building, do depreciation only because it's easier >to work with, and you don't run into these complications. > >All said and done, it's much easier to stick to salaries, wages, materials & >services, travel and equipment. Even I can determine that! > >Greg Schmidt > > >>Angie, >> >>This is a tricky one because renovations and lab space are normally not >>allowable as cost-sharing. I would read the guidelines carefully and then >make >>sure that any funds used as cost-share are directly attributable to the >>proposal. For instance, if it is a research proposal, the renovations >should >>be space that will be dedicated to research. If half the building will be >>classrooms and half will be research lab space, you would have to be able >to >>pinpoint the costs for the research side only. >> >>Good luck! >> >>Ruth Tallman >> > >>ANGIE LOPEZ wrote: >> >>> A PI at my institution is applying for a grant that requires 30% cost >share >>> and he is interested in using building/lab space to fulfill this >>> requirement. I realize that space is usually taken into account in an >>> institution's F&A costs. However, my institution recently purchased the >>> building and it was not part of our F&A negotiations. (FYI-our indirect >>> cost rate is based on salaries and wages) >>> >>> Can we (or should we) show the building (or a portion of it) as cost >share >>> in our proposal? Any feedback you can provide would be most helpful. >>> >>> Thanks! >>> >>> Angie Lopez > > ====================================================================== > 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") > ====================================================================== > -- Barbara H. Gray Director of Sponsored Research Desert Research Institute 2215 Raggio Parkway Reno, Nevada 89512-1095 Telephone: 775-673-7381 Fax: 775-673-7459 E-mail: xxxxxx@dri.edu www.dri.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") ======================================================================
