Lesley, I agree with Bill Campbell. Based on OMB-A21 and CASB's Cost
Standards, the source of funding is irrelevant, the important thing is that
the effort was performed for the benefit of the federally funded projects.
Your time sheets are the hard data to prove that the effort was performed.
However, don't forget to include all the cost sharing amounts in your MTDC
Base in your indirect cost rate proposal; your Federal Cognizant negotiator
wants to see this because it directly affects all components of your rate:
the higher the cost sharing amount in the MTDC base, the lower the proposed
(calculated) indirect cost rate will be. Louis.

>Lesley, we regularly count employee contributions of the sort you
>describe as cost-share.  In fact, we count anything any entity--persons,
>our own institution, other institutions, businesses, etc.--contributes to the
>project as cost-share.  No problems so far.
>
>Bill Campbell
>Univ. of Wisconsin-River Falls
>

>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
>
>
------------------------------
Louis Guin, PhD, Assistant VP
Univ. of Southern California
Office of Financial Analysis
UGB Suite 107, MC-8002
Los Angeles, CA 90089-8002
(P) 213 743-2454
(F) 213 748-0871
(E) xxxxxx@usc.edu