We had only one person reply to our request for clarification on what
seems to be a generally accepted position among our colleagues that
federal funds cannot be used as cost share toward a NON-FEDERAL award.
I think those of us who doubt it still do not have a handle on the
supporting regulatory or other basis (e.g., audit findings?) for this
stance.  I would be most appreciative if those who believe this is true
and can articulate the supporting basis would take a few minutes to
reply to the ListServe.  As Jennifer mentioned, this question came up
before and probably will again unless someone can help us understand.
Thanks!

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

Jennifer Donais said the following on 4/11/2008 11:49 AM:
> 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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