For many years, I have heard the same opinion from some of my colleagues
in the sponsored programs administration field.  That is, that federal
grant funds cannot be committed as match to non-federal grants using
A-110 as their reference.  I have never understood this perspective.  As
I read A-110, section .23(a)(5), it appears clear to me that the focus
is on the source of the cost share used to match federal awards.
Normally, federal funds (direct or pass-through) cannot be used to match
another federal award unless prior approval of the federal awarding
agency is obtained.  I find nowhere else in A-110 that even implies that
there is a prohibition against or that prior approval of a federal
agency is required before a recipient can commit federal grant funds as
cost sharing for a non-federal award.  Of course, if a federal agency
includes this restriction as a special condition in a federal award,
that is another matter.  It seems to me that the question is whether the
non-federal awarding agency will consider the federal funds as an
eligible source of cost-sharing against its funds.  I, too, would
appreciate clarification as to what I may be missing.

Edward M. Ebert
Grants and Contracts Administrator
Office of Sponsored Programs
213 SSC-East Bartlett Hall
University of Northern Iowa
Cedar Falls, IA 50614-0394
Phone 319-273-3025
Fax 319-273-2634

Goucher, Janet Louise said the following on 4/11/2008 9:31 AM:
> All,
>
> Under A-110 Can funds from a federal grant be used as cost share on a
> NON-federal grant? I was taught  that as long as the money you were
> matching wasn't federal that it was acceptable. Your help will be
> greatly appreciated!
>
> Janet
>
>
>
> Janet Goucher
>
> Research and Sponsored Programs
>
> Illinois State University
>
>
>
>
>
>
>
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