This is an e-mail from USDA CSREES regarding cost sharing from Colien Hefferan, the CSREES Administrator.
From: "Hefferan, Colien" <CHEFFERAN@csrees.usda.gov>
Reply-To: "Hefferan, Colien" <CHEFFERAN@csrees.usda.gov>
Date: Thu, 26 Jun 2008 13:30:26 -0400
To: W Agricultural Experiment Station <w-aesdirs@colostate.edu>
Subject: [us-aesdirs] Update on Matching Requirements for CSREES Programs
For your information, I have attached the Agency’s background information on grant programs that require a nonfederal match. This may be useful as you anticipate the formal request for applications (RFA) for the Specialty Crops Research Initiative (SCRI). We expect to publish this in the next week or so, pending apportionment of funds to the Agency to implement the program. The information below comes from the standard guidance provided in RFAs for similar programs.
In addition, I am aware of concern regarding our guidance that the difference between a university’s negotiated indirect rate and the legislatively set cap of 22% for such rates can not be used as part of the matching requirements of the SCRI awards. The rationale for this is as follows: If a grant recipient, even though prohibited from directly charging indirect costs to Federal funds, could count such funds as part of a matching requirement, the net effect would be no different than if such costs had not been prohibited. In this case, to allow such would be to negate the legislative requirement limiting indirect cost recovery.
CSREES wants as much participation in this program as is feasible and has no desire to impose any limits to that participation. As with all of the programs we manage, we follow Federal guidance for the administration of grants and agreements and the specific requirements of the law under which the programs are authorized. I hope this information will help as you plan to address the science and extension needs related to specialty crops through the SCRI.
Colien Hefferan, Administrator
Cooperative State Research, Education, and Extension Service
U.S. Department of Agriculture
RFA Template for Programs with Indirect Costs and Matching Requirements (including cash contributions and in-kind support from non-Federal sources)
B. Cost Sharing or Matching
The recipient of a grant under the [Insert Program Name}must provide funds or in-kind support from non-Federal sources in an amount that is at least equal to the amount provided by the [Insert Name of program]. There is no provision for waiver of this requirement.
5. SF 424 R&R Budget Fed & Nonfed
Information related to the questions on this form is dealt with in detail in Part V, 6. of the CSREES Grants.gov Application Guide. This form (accompanied by the required Budget Justification attachment (see Field K on the Form)) contains the itemized listing and description of your project’s budget. Applicants must complete one SF 424 (R&R) Budget Fed & Non-Fed Form for each 12-month period, plus a cumulative budget form for the entire project.
(a) Matching. Applications should include written verification of commitments of matching support (including both cash and fair market value of in-kind contributions) from third parties (non-federal sources). Written verification means:
For any third party cash contributions, a separate pledge agreement for each donation, signed by the authorized representative of the donor organization and the applicant organization, which must include: (1) the name, address, and telephone number of the donor; (2) the name of the applicant organization; (3) the title of the project for which the donation is made; (4) the dollar amount of the cash donation; and (5) a statement that the donor will pay the cash contribution during the grant period.
The sources and the amount of all matching support from outside the applicant organization should be summarized on a separate page and placed in the application as a part of the Budget Justification attachment (see Field K on the Form SF 424 (R&R) Budget Fed & Non-Fed). All pledge agreements must be included as a PDF attachment.
The value of applicant contributions to the project shall be established in accordance with the applicable cost principles. Applicants should refer to OMB Circulars A-21, Cost Principles for Educational Institutions; A-87, Cost Principles for State, Local, and Tribal Governments; A-122, Cost Principles for Non-Profit Organizations; 2 CFR Part 215, Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (OMB Circular A–110); and the cost principles in the Federal Acquisition Regulation at 48 CFR 31.2 for further guidance and other requirements relating to matching and allowable costs.
D. Funding Restrictions
CSREES has determined that grant funds awarded under this authority may not be used for the renovation or refurbishment of research or extension space; the purchase or installation of fixed equipment in such space; or the planning, repair, rehabilitation, acquisition, or construction of buildings or facilities. [Included in most CSREES RFAs.]
Section 7132 of the Food, Conservation and Energy Act of 2008, amended the National Agriculture Research, Extension, and Teaching Policy Act of 1977 (7 U.S.C. 3310(a)), limiting indirect costs to 22 percent of the total Federal funds provided under each award. Therefore, when preparing budgets, applicants should limit their requests for recovery of indirect costs to the lesser of their institution’s official negotiated indirect cost rate or the equivalent of 22 percent of total Federal funds awarded.
The maximum allowed indirect cost of 22 percent may be claimed under the Federal portion of the award, or the maximum allowed indirect cost of 22 percent may be claimed as matching contributions (if no indirect costs are requested). However, the maximum allowed indirect cost of 22 percent may not be claimed on both the Federal portion of the award and as matching contributions (Note: An awardee may, as an example, request 11 percent of indirect costs on both the Federal portion of the award and as matching contributions. Or, an awardee may request any other, similar percentage combination that, when combined, does not exceed the 22 percent maximum indirect cost allowed.) Nevertheless, the total combined percent of requested and contributed matching indirect costs cannot exceed 22 percent.
Douglas L. Vincent, Ph.D., P.A.S.
Special Program Director for Contracts and Grants
College of Tropical Agriculture and Human Resources
University of Hawaii at Manoa
Gilmore 202
3050 Maile Way
Honolulu, HI 96822
808-956-8152
vincent@hawaii.edu
vincentd@ctahr.hawaii.edu
douglas.l.vincent@gmail.com