Re: Using Federal funds as cost share/match on non Federal awards Wayne Glass 17 Apr 2008 12:50 EST
I've been researching this since your original inquiry. I have yet to find a specific reference to the issue. I'm not aware of any federal-wide restriction on using federal funds as match against non-federal dollars. I have seen specific programs where it was prohibited, but I recall actually using the federal dollars from an existing grant to match against state dollars a number of times. So far (knock on wood), they have not come to haul me off for doing so. Perhaps the statute of initiations has passed... Wayne Glass Schoolcraft College -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Edward Ebert Sent: Thursday, April 17, 2008 1:06 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 > ====================================================================== 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") ====================================================================== ====================================================================== 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") ======================================================================