In response to the question about use of unrecovered overhead as matching, I
note that the USDA implementation of A-110 is unchanged from A-110 as follows:

"3019.23 Cost Sharing or Matching.  (7)(b) Unrecovered indirect costs may be
included as part of cost sharing or matching only with the prior approval of
the Federal awarding agency."

By adopting the language verbatim, USDA has reserved a choice for itself on
a program by program basis.  Unfortunately, it appears that they must have
changed their mind between the program announcement and the award decisions.
I really don't think an institution has much choice here, particularly in
light of their adoption of A-110.  So, it comes down to whether you really
want to accept the award or stand on principle.  And that's an institutional
decision.  (And the #4 approach.)  I think from a CAS point of view, one
shouldn't attempt to itemize ordinary IDC as DC for matching
purposes--violates the consistency provisions.

Just my thoughts for whatever they are worth.

>I have an issue that begs for both a policy question response and a
>practical approach.  I would especially like to hear from Land-Grant
>Institutions, but any thoughts would be welcome!  So here goes:
>
>           *****Policy Question******
>   Has anyone had a difficult time with a federal agency (in our case, USDA)
>refusing to accept unrecovered F&A as an allowable match when the F&A
>programatically allowed is less than the negotiated rate?
>  Originally published guidelines (in effect at the time the proposal was
>submitted) for the program in question (USDA Challange Grant) had mentioned
>several specifics of what may or may not be used for the matching
>committment including the difference between the institution's negotiated
>rate and USDA published rate.  However, under the new USDA-AREER  funding,
>the agency (USDA) has reneged on the initial guidelines as published and is
>insisting on using what appears to be selected parts of law as it has deemed
>desirable.
>   This is making for some difficult times in reworking budgets, etc. under
>the "new" rules. (Especially with the matching components!)  Has anyone else
>had this problem and how did you deal with it?
>
>   ******Practical Approach Question*****
>
>In the USDA's response to our inquiry, we were informed that the Agriculture
>Secretary's legal counsel interprets the limitation to apply both to
>indirect and to the use of indirect for matching.
>
>While our institutional counsel works with the USDA, we are faced with what
>we believe are our only options:
>
>1. Hold up (or perhaps, withdraw) proposals that have hard deadlines;
>
>2. Go ahead and charge the difference between the 19% and our negotiated
>44.5% federal rate as unrecovered indirect and let the legal counsels of
>both USDA and our institution work it out;
>
>3. Submit proposals with itemized operating expenses (usually dealt with as
>indirect costs) as matching, (presuming we will have enough that qualify
>under CAS)
>
>or
>
>4.   Agree to this new reduced rate and proceed.
>
>If you have other thoughts, suggestions or information of how your
>institution or others are coping with this very significant reduction in
>indirect match and USDA/CSREES' mid-process creation of a special fee,
>please advise.
>
>Rusty Okoniewski, Interim Director,
>IFAS Sponsored Programs
>University of Florida
>McCarty Hall-D (Bldg. 498)
>P.O. Box 110110
>Gainesville, FL 32611-0110 USA
>E-mail: xxxxxx@gnv.ifas.ufl.edu
>Voice: (352) 392-2356
>Fax: (352) 392-8479
>Suncom: 622-2356
>
Jane A. Youngers
Director
Office of Grants Management
University of Texas Health Science Center at San Antonio
7703 Floyd Curl Drive
San Antonio TX  78284
voice:  210-567-2333
fax: 210-567-2344
email:  xxxxxx@uthscsa.edu