Sent: Thursday, June 19, 2008 10:16 AM
To:
Subject: Matching requirements for the Specialty Crops Research Initiative
All:
As you may know there is a 1:1 matching requirement for awards in the SCRI. Section 7311 of the Farm Bill states:
"(3) MATCHING FUNDS REQUIRED. The Secretary shall require the recipient of a grant under this section to provide funds or in-kind support from non-Federal sources in an amount that is at least equal to the amount provided by the Federal Government."
There have been several questions about what can be counted as matching/cost sharing. However, it is near certain that the forthcoming RFA for the SCRI will not allow unrecovered indirect costs (usually used) as matching contributions. The key factor relates to the statutory cap on indirect costs, as there is apparently a policy that prevents using unrecovered indirect costs as matching when there is a indirect cost cap for a program. The EDs worked hard the past few days seeking clarification and to see if unrecovered indirect costs could be used as matching. Below in an answer from Carol Langguth below. We also sought opinions from several of top budget people in state offices and received the same answer that provided by Carol.
We hope to get specific policy language relative to this requirement and possibly affect a change in the future.
Email from Carol Langguth:
Regarding using unrecovered indirect costs for matching requirements on any program with an indirect cost cap established by legislation – you cannot use the difference between your negotiated rate and the 20 or 22% cap (45% - 22% = 23%) – however, if an organization does not charge any indirects to the Federal side of the budget, that organization can include the indirects on the matching side – or if an organization wishes to apply 10 or 12% (or any other lower percentage) on the Federal side, that organization could use the difference between the indirect cap (20 or 22%) on the matching side of the budget. There could be slight differences in the calculation as well because sometimes the application of an organization's negotiated rate is actually lower than the statutory cap on indirects – so we have to use the lesser of the two.
I hope this helps – this applies to any program with a statutory cap on indirects with a matching component.
Carol A. Langguth
Branch Chief
Awards Management Branch/OEP
USDA/CSREES
Telephone: 202-401-5204
FAX: 202-401-1804
Excerpts from OMB Circular A110 regarding cost sharing and matching. Note that using the unrecovered indirect costs require prior approval. (and based upon this information, unrecovered indirect costs will not be accepted) -- DLV
.23 Cost sharing or matching.
(a) All contributions, including cash and third party in-kind, shall be accepted as part of the recipient's cost sharing or matching when such contributions meet all of the following criteria.
(1) Are verifiable from the recipient's records.
(2) Are not included as contributions for any other federally-assisted project or program.
(3) Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
(4) Are allowable under the applicable cost principles.
(5) Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
(6) Are provided for in the approved budget when required by the Federal awarding agency.
(7) Conform to other provisions of this Circular, as applicable.
(b) Unrecovered indirect costs may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency.
<DLV note: CSREES will NOT grant approval for this matching!>
(c) Values for recipient contributions of services and property shall be established in accordance with the applicable cost principles. If a Federal awarding agency authorizes recipients to donate buildings or land for construction/facilities acquisition projects or long-term use, the value of the donated property for cost sharing or matching shall be the lesser of (1) or (2).
(1) The certified value of the remaining life of the property recorded in the recipient's accounting records at the time of donation.
(2) The current fair market value. However, when there is sufficient justification, the Federal awarding agency may approve the use of the current fair market value of the donated property, even if it exceeds the certified value at the time of donation to the project.
(d) Volunteer services furnished by professional and technical personnel, consultants, and other skilled and unskilled labor may be counted as cost sharing or matching if the service is an integral and necessary part of an approved project or program. Rates for volunteer services shall be consistent with those paid for similar work in the recipient's organization. In those instances in whic the required skills are not found in the recipient organization, rates shall be consistent with those paid for similar work in the labor market in which the recipient competes for the kind of services involved. In either case, paid fringe benefits that are reasonable, allowable, and allocable may be included in the valuation.
(e) When 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 (plus an amount of fringe benefits that are reasonable, allowable, and allocable, but exclusive of overhead costs), provided these services are in the same skill for which the employee is normally paid.
(f) Donated supplies may include such items as expendable equipment, office supplies, laboratory supplies or workshop and classroom supplies. Value assessed to donated supplies included in the cost sharing or matching share shall be reasonable and shall not exceed the fair market value of the property at the time of the donation.
(g) The method used for determining cost sharing or matching for donated equipment, buildings and land for which title passes to the recipient may differ according to the purpose of the award, if (1) or (2) apply.
(1) If the purpose of the award is to assist the recipient in the acquisition of equipment, buildings or land, the total value of the donated property may be claimed as cost sharing or matching.
(2) If the purpose of the award is to support activities that require the use of equipment, buildings or land, normally only depreciation or use charges for equipment and buildings may be made. However, the full value of equipment or other capital assets and fair rental charges for land may be allowed, provided that the Federal awarding agency has approved the charges.
(h) The value of donated property shall be determined in accordance with the usual accounting policies of the recipient, with the following qualifications.
(1) The value of donated land and buildings shall not exceed its fair market value at the time of donation to the recipient as established by an independent appraiser (e.g., certified real property appraiser or General Services Administration representative) and certified by a responsible official of the recipient.
(2) The value of donated equipment shall not exceed the fair market value of equipment of the same age and condition at the time of donation.
(3) The value of donated space shall not exceed the fair rental value of comparable space as established by an independent appraisal of comparable space and facilities in a privately-owned building in the same locality.
(4) The value of loaned equipment shall not exceed its fair rental value.
(5) The following requirements pertain to the recipient's supporting records for in-kind contributions from third parties.
(i) Volunteer services shall be documented and, to the extent feasible, supported by the same methods used by the recipient for its own employees.
(ii) The basis for determining the valuation for personal service, material, equipment, buildings and land shall be documented.
Best regards,
Mike
--
H. Michael Harrington, PhD
Executive Director, WAAESD
University Square, 1311 S College Ave.
Colorado State University
Ft Collins, CO 80523
Phone: 970-491-6280; Fax: 970-491-6250