Is it allowable to use the same expenditures as cost share on two grants
when one of the grants is federal and the other is state money?

We have an NEH federal flo-thru grant that requires a $90,000 match in
cash and in-kind expenditures. We want to use approximately $70,000 of
that match as match on a second grant, for which the source of funds is
state money, not federal flo-thru. Is this legal?

The Federal Grants Management Handbook, under paragraph 463, "Costs
Allowable for Matching and Cost Sharing" states:
 "Unless authorized by legislation, regulations or the award
agreement, costs used to satisfy a grantee's matching requirement may
not be derived from federal grants or subgrants from other programs or
costs used as match or cost sharing on other grants."

We interpret this to mean that we may not use the same cost share
expenditures on two FEDERAL grants.  Since one of our grants is state
money, we think we are allowed to use the same cost share on both the
federal grant and the state grant.

How do you interpret this?

-

Laurie P. Chamness                    Phone:  (843) 953-4973
Assistant Director                        Fax:  (843) 953-6577
Research & Grants Admin          E-mail:  xxxxxx@cofc.edu
College of Charleston
66 George Street
Charleston, SC  29424

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