Ruth,

We have a little over 90 active Department of Ed grants and it appears there
is little standardization in how Ed treats proposed cost share (whether
required by the program announcement or voluntary) in the award document.

We avoid cost sharing whenever possible and frequently charge faculty
academic year salary to the grants, with minimal if any cost share.  We also
have some with exceptionally large obligations for cost sharing.  This has
been a College/department decision.

Our faculty have been advised, based on our cognizant auditors (HHS)
position and the ED regulations, that presenting cost sharing in an
application (mandatory or voluntary) constitutes an offer to the government
which, if an award is made, must be documented in the same manner as the
charges placed against the grant (see 34 CFR 74.23).  You may also be
interested in the Dept of Ed Discretionary Grant Closeout procedure at
http://gcs.ed.gov/grntinfo/gposbul/gpos21.htm  section 2 which gives
direction to Department of Ed personnel in the procedures related to cost
sharing particularly the "OR" part which states:

 "Compare the combined total amount of cost-share/matching reported
on the SF-269 to the cost-      share/matching amount shown in the approved
budget. Block 7 of the GAN indicates the required       cost share stated as
a percentage or an amount of funds identified by the grantee in their
application under non-federal funds."

While the statement leaves some interpretation, the intent is clear enough
for us.  Just because ED does not list a percentage or dollar amount in the
Block 7 does not relieve the institution from the cost share offer on the
application form.

Gary Chaffins
Director, Office of Research Services and Administration
University of Oregon

-----Original Message-----
From: Ruth Tallman [mailto:xxxxxx@LEHIGH.EDU]
Sent: Monday, October 11, 1999 7:14 AM
To: xxxxxx@hrinet.org
Subject: Dept. of Education

Good Morning,

I have very little experience with the Dept. of Education.  We have
support from the program titled "Personnel preparation to improve services
and results for children with disabilities" from the Office of Special Educ.
and Rehabilitative Services.  In the past and in a new proposal, our PI's
are cost-sharing AY time.  I don't see anything in the guidelines regarding
required cost-sharing.

I need feedback from those with experience with the Dept. of Ed.  Any
unwritten
rules regarding cost-sharing that I wouldn't know about?

Happy Columbus Day!

Ruth

Ruth Tallman
Office of Research and Sponsored Programs
Lehigh University
e-mail: xxxxxx@lehigh.edu
phone: (610) 758-3024

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