Thanks, David. That seems definitive enough for me. -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org]On Behalf Of David Schmidt Sent: Thursday, April 17, 2008 5:02 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] Using Federal funds as cost share/match on non Federal awards Hi Edward, The following response was put on another listserve, it was from a consultant and it was from his prior Institution. I personally look at this as a statement of work change and have the PI get the concurrence from the sponsoring Federal agency in writing. 1) A-110 (section 23) mandates that: "a) All contributions, including cash and third party in-kind, shall be accepted as part of the recipient's cost sharing or matching when such contributions meet all of the following criteria. (2) Are not included as contributions for any other federally-assisted project or program. (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. (6) Are provided for in the approved budget when required by the Federal awarding agency." http://www.whitehouse.gov/omb/circulars/a110/a110.html#23 This is particularly true for cases involving cost share/match from federal grants/sources to other purposes, since such a diversion of resources means that federal projects are not receiving the level of services pledged by the university in proposal/award documentation. 2) In fact, our policies/procedures included the wording above; and, we generally would not allow cost share/match from one grant to another grant without the written permission of the external sponsors/original funding sources; also, if memory serves me correctly, our cases mainly concentrated on cost share/match from some agricultural federal appropriation funding to federal agriculture sponsored grants (however, we required written permission even on these). 3) Also, it should be noted that another reason for care in this matter is that these are included within the workscope of A-133 Audits, 2007 Compliance Supplement, Section G: http://www.whitehouse.gov/omb/circulars/a133_compliance/07/pt3.doc 4) Finally, in those rare allowable cases, we included any such labor cost share/match on Effort Statements for certification by faculty/staff and brought these amounts into our F&A Rate Proposal for the proper base (e.g., research, instruction, public service) and controlled non-labor cost share/match in the like manner, per the DCA Best Practices Manual (see page 17): http://rates.psc.gov/fms/dca/c&u.html Dave David O. Schmidt, CPA, CRA Manager Grants & Contracts Administration University of North Dakota 264 Centennial Drive Twamley Hall - Room 100 Stop 7306 Grand Forks, ND 58202-7306 Telephone - 701-777-2505 Fax - 701-777-2504 e-mail - xxxxxx@mail.und.nodak.edu >>> Edward Ebert <xxxxxx@UNI.EDU> 4/17/2008 12:06 PM >>> 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") ======================================================================
