Edward, No, I haven't found it spelled out anywhere, but I would
reference A-110, Subpart C, .23(5)"Are not paid by the Federal
Government under another award, except where authorized by Federal
statute to be used for cost sharing or matching." If the Feds won't
allow a federal award to be used as cost sharing for another federal
award without a statute in place, then they aren't going to allow
federal funds to be used as cost sharing on non-federal awards. That's
my "conservative" viewpoint & I'm sticking to it. :) Lee
Ms Lee Folk, CRA, MS-UHCL Class of '93 and '00
Assistant Director, Office of Sponsored Programs
University of Houston-Clear Lake
2700 Bay Area Blvd, MS 44 Ph 281-283-2138
Houston TX 77058-1098 Fax 281-226-7122
e-mail: xxxxxx@uhcl.edu
"Hope is a choice." Wendy Schlessel Harpham
-----Original Message-----
From: Research Administration List [mailto:xxxxxx@hrinet.org] On
Behalf Of Edward Ebert
Sent: Thursday, April 17, 2008 12:06 PM
To: xxxxxx@hrinet.org
Subject: Re: [RESADM-L] Using Federal funds as cost share/match on non
Federal awards
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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