Cost Sharing / Conflicts of Interest (Power Point File)

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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
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