Those on RESADM-L may be interested the summary of
responses I received to a question I posed to NCURA Region III
folks about costsharing space.  Hope it is useful.

Mike

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Thanks to the 17 Region III folks who responded to my question
about showing space as a direct cost costshare.  If you have any
comments about this summary, or see errors, please feel free to
post them to the list.

As most of you graciously pointed out, space is taken into account
in the indirect costs (i.e. facilities and administrative costs).  So if a
grant is paying our full rate, then in effect the grant is paying it's
share of the facilities and therefore the space should not be listed
as a dollar amount of direct cost costshare.

When we can only get a reduced indirect rate (or no indirect at all)
for whatever reason, the difference between what we would have
received at a our full rate and the lower rate, can be counted as a
costshare.  By showing the indirect costs as costshare, we are in
effect showing facilities costsharing there, and again it would not
be appropriate to show space as a direct cost costshare.

(Although as one person suggested, if we did NOT choose to show
the difference of full rate and reduced rate as cost share, I suppose
we could then try to show space as a direct cost costshare.  But
having the indirect as costshare seems like a cleaner way to do it.)

If I recall correctly, some time ago the US Dept of Ed said that we
CAN'T use the difference b/w our full indirect rate and its 8%
training grant rate as costshare.  I suppose that trying to show
space as a direct cost costshare, in order to get some costshare
credit in this case, would be in effect using indirect cost as
costshare, violating the spirit of the ED regs.

It appears that there is an exception a few of you pointed out that
may allow us to show space as a direct cost costshare.  That is if
the College regularly rents out the space and charges anyone who
uses it--or at least outside groups.

Lastly, one person said that an instance occurred in which the
sponsor REQUIRED that space costshare be shown directly.  In
which case, that information was provided even though this
particular area does not usually charge for on campus users.

In short, the basic answer was pretty straightforward but as nearly
always, there are twists and turns.

Thanks again to everyone who responded and I hope you find this
summary useful.

Mike

Michael Ludwick, CRA
Associate Director of Sponsored Programs
Grants and Research Administration
College of William & Mary
P.O. Box 8795
Williamsburg, VA  23187-8795
phone: 757.221.3485  fax: 757.221.4910
email: xxxxxx@grants.wm.edu
website: http://www.wm.edu/AI/Grants/index.html
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