The question may also be whether the feds know that their money is being used as match. In the situation I referred to in my previous post, we were already running a federally-funded program. We approached the state for a grant, citing the existence of the federal dollars as leverage for the state funds we were requesting. We showed the fed dollars as matching funds. But we did not ask the feds if we could, since there was not a specific prohibition in the federal contract. Perhaps we were being naïve, but this was at an institution with a well-established track record of federal funding. I always felt the issue of not matching fed to fed was pretty intuitive. Similar prohibitions exist at the state level. There is some discussion I've found about concerns of using state money as match for federal, when in fact the state money is pass-through federal dollars. Not that this helps in resolving the original question! Wayne -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Folk, Lee Sent: Thursday, April 17, 2008 1:37 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] Using Federal funds as cost share/match on non Federal awards 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 > ====================================================================== 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") ====================================================================== ====================================================================== 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") ======================================================================
