We too came up against this question, and desipte much effort in looking
at A-110 & surveying our colleagues via the ListServe, we were never
able to point with confidence to any regulation or guideline which
precluded (or conversely, allowed) it.

I'd be interested to hear if anyone else has ever come across anything
directly addressing the question.

Edward Ebert wrote:

> 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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>
>
>
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Office of Grant & Contract Administration
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