Could someone shed some light on this for me?  We have some grants with EPA
and USAID that don't require a specific amount of cost share but we would
like to show as much cost share as we can.

Our organization offers comp time to its exempt employees as follows:  For
every three extra hours worked, the employee earns one comp hour.  For
example, in order to have one day off and charge it to comp time, we have to
have worked 24 hours extra.  Can we report the other 16 hours (for each comp
day earned) as cost share (along with the applicable fringe)?  Our personnel
policy specifically states that the organization "compensates" employees for
only 1/3 of the effort actually recorded on the timesheets, so I think we
should be able to report the other 2/3 as an in-kind contribution.
It's true that this in-kind contribution is from the employee and NOT the
organization, but it's still an in-kind contribution--it's still time and
effort devoted to the project--much the same as a consultant "donates"
his/her time when they work for us and we only pay their travel expenses.

A-110 doesn't specifically say whether or not in-kind contribution from the
recipient's employees (when their effort is not compensated by the
recipient) is allowable or unallowable as cost share.  A-110 DOES state,
however, that if "an employer other than the recipient furnishes the
services of an employee, these services shall be valued at the employee's
regular rate of pay. . .".

Does anyone out there count non-compensated employee effort as
cost-share/in-kind
contribution on any Federal projects?

I appreciate your comments,

Thanks,

Lesley