Types of Cost Sharing • Mandatory: When the sponsor stipulates that cost sharing or matching funds are required as a condition of receiving an award. Specifically pledged in the proposal’s budget or award. • Voluntary: Not required by the sponsor, but included by the PI to enhance the proposal. Specifically pledged in the proposal’s budget or award. • Voluntary Uncommitted: Faculty effort over and above that which is committed and budgeted for in a sponsored agreement. Cost Sharing Principles The “DO” ‘s • Allowable and allocable • Necessary and reasonable • Verifiable from the University’s records • Identified in the program’s budget • In compliance with OMB Circular A-110 Cost Sharing Principles The “DON’T” ‘s • Federal to Federal • Expenditures included in the Overhead Rate • Lack of technical relationship • Double counting • Costs not allowable pursuant to OMB Circular A-21 • Costs outside the project period • Salary Dollars in Excess of Regulatory Salary Caps How Should Cost Share Amounts Be Documented? • Salaries and Benefits • Equipment, supplies, travel • Tuition • Account numbers, subcodes, spreadsheet • Annual certification • Copies of ledgers with the specific costs highlighted and supporting documentation (invoices, purchase orders, etc.) • Detailed ISIS report Third Party or Subcontractor Contributions • Effort of third party personnel • Rates need to be consistent with rates paid for similar work in the University or other third party users of such services • Documentation of the time spent • Supplies, equipment • Reasonable, fair value Discussion Questions • How do you ensure you are aware of the accounts that have cost sharing that needs to be tracked? • Is cost sharing progress monitored to ensure it is being achieved? • How do you ensure that amounts claimed as cost sharing are not double counted? Conflict Disclosure • University policy and federal policy • Timely and full confidential disclosures • Institutional review of those disclosures • Establish a mechanism to manage, reduce, or eliminate such potential conflicts Definition of Conflict • In a position to influence University business, research, or other decisions for personal gain or improper advantage to third parties • Activities or undertakings interfere with the individual’s responsibilities to the University Actual or Perceived Who can have a conflict? • Faculty • PIs, Co-PIs, etc • Researchers • Key Personnel, others responsible for oversight and.or conduct of sponsored projects • Dependents and spouses • Administrators • Direct, support, or materially influence research policy and operations Outcomes of Project • Need clarification of who should complete the COI forms • Need to ensure all forms are received • Chair’s COI form must be sent to the Dean’s Office • No COI forms have been updated outside of the annual process Outcomes of Project • Treatment of newly appointed faculty • Faculty collaborating on research project administered by another department • Resolution of items documented on Part II of the form