COST SHARING Objective: To understand the requirements related to cost sharing to ensure compliance with federal regulations and FSU Policy. 1 CReATE ver. 04/13 © 2013 Florida State University. All rights reserved Today’s Agenda What is Cost Sharing? FSU Policy FSU Procedures Cost Sharing Expenditures Agency Specific requirements Cost Sharing Accounting in OMNI FACET Common Issues 2 What is cost sharing? Project costs not borne by the sponsor Also known as “Matching” 3 FSU Cost Sharing Policy http://www.research.fsu.edu/contractsgrants/costsha ring.html Committed Mandatory – required by agency Voluntary Not required by agency Reflected in proposal * Must account for and report Cost share amount not met, award reduced proportionately Uncommitted (Project Enhancement) Not quantified Do not have to account for and report * - quantified in the award document, proposal budget, or proposal narrative 4 Cost Sharing Procedures http://www.research.fsu.edu/contractsgrants/docu ments/csprocedures.pdf Sources Unrecovered F&A Personnel costs (FACET) Other direct costs (travel, tuition, consultants, equipment, etc.) Other sponsored agreements when appropriate/allowable Award-related (program) income when University is authorized to expend such income 3rd party contributions 5 Cost Sharing Procedures Cost Share Commitment form http://www.research.fsu.edu/contractsgrants/docum ents/cs_commit_form.pdf Need when Advance requested Proposal Prepared and submit to SRS as part of package Award SRS confirms cost sharing sources at the same time negotiating/executing the sponsor award The sponsored project budget will not be activated until all cost sharing information has been received SRAS sets up sponsored and cost share child budgets at same time 6 OMB Circular A-110, Subpart C, Cost Sharing Expenditures Allowable according to OMB Circular A-21 Directly related to the project objectives Not included on any other federally-assisted awards Not paid by the Federal government unless authorized by statute Verifiable from recipient’s records Need to spend at the same rate as spending on the sponsored project 7 Allowable Cost Sharing Expenditures The following are types of expenses that are allowed as Cost Sharing: Salaries of faculty and technical staff working on project funded from source other than project Includes related fringe benefits Other direct costs, e.g. travel, laboratory supplies, equipment, etc. benefiting project F&A on cost sharing MTDC Unrecovered F&A on project e.g. funded rate = 8% vs. institution rate = 47% 8 Unallowable Cost Sharing Expenditures The following are types of expenses that are NOT allowed as Cost Sharing: Expenses that University has defined as F&A, such as administrative salaries/supplies, equipment depreciation, and O&M expenses CAS exemption must be approved to charge F&A costs directly as cost sharing expenditures Salary dollars in excess of regulatory salary caps, such as the NIH salary cap Unallowable costs as defined in Section J of OMB Circular A-21 9 3rd Party Contributions 3rd Party Cost Share Commitment Form Completed to document what/amount of contribution proposed Types Donate services Donate equipment, supplies, travel, facilities Employee's regular rate of pay plus fringe benefits (cannot apply F&A) Must document valuation basis Fair market value Volunteer Value at FSU rate of pay (similar work) Labor market rate of pay if no similar work at FSU 3rd Party Contribution Certification Form Required for reporting preparation 10 What are the cost sharing policies of some major funding agencies? IT IS IMPORTANT TO ALWAYS REFER TO THE SPECIFIC AGENCY GUIDELINES AS AN AGENCY MAY HAVE REQUIREMENTS THAT DIFFER 11 FROM THE CIRCULAR. National Science Foundation (NSF) Statutory requirement that each grantee share in the cost of research projects resulting from unsolicited proposals is no longer effective as of June 1, 2007 Effective January 2011, unless cost sharing requirements are included in the program solicitation, it is not allowed 12 National Science Foundation (NSF) When NSF Cost Sharing is Required NSF mandatory cost sharing will only be required when explicitly authorized by the NSF Director Contributions derived from other Federal funds or counted as cost sharing toward projects of another Federal agency may not be counted towards meeting the specific cost sharing requirements of the NSF grant Failure to provide the level of cost sharing reflected in the approved grant budget may result in termination of the NSF grant, disallowance of grant costs, and/or refund of grant funds to NSF 13 National Science Foundation (NSF) When NSF Cost Sharing is NOT Required If cost sharing included in proposal, then proposer risks the proposal being returned without review or declined Waiver of any indirect costs to which FSU is entitled would be considered voluntary committed cost sharing and is therefore prohibited by NSF (i.e. FSU charges the federally approved IDC rate on NSF awards) 14 Public Health Service A number of PHS grant programs require non- Federal participation in the costs of grantsupported activities; the extent of that participation is specified by PHS or is negotiable PHS no longer has a general legislative requirement that recipients of research grants must cost share on their projects. However, specific program legislation may require grantees to share in the cost of the project or the PHS awarding office may administratively apply a matching requirement 15 US Department of Education Cost sharing required on certain grants Each state receiving a grant under the State Grant Program or Teacher Recruitment Grant Program must cost share at least 50% of the amount of the grant award annually. Each partnership receiving a grant under the Partnership Grant Program or Teacher Recruitment Grant Program must provide from non-federal sources an amount that is at least 25 percent of the TQE grant for the first year, 35 percent for the second year, and 50 percent for all subsequent years. NOTE: The matching contributions may be in cash and/or in-kind. In any fiscal year, grantees whose approved applications and budgets identified an amount of match that exceeds the statutory minimum for any project period must meet that higher amount. 16 Cost Sharing Accounting “Child” Budgets Parent Budget checking at child level – must have sufficient balance at child level to “pass” budget checking Direct Child 700001 Indirect Child 700001 Cost Share Child 17 Cost Sharing Budget Setup Matrix Source of Funds (Fund Code) Funding Combination Fund Transfer E&G (1xx/2xx) DeptID+1xx+SP Project No Auxiliary (3xx)** DeptID+3xx+SP Project OR DeptID+555+SP Project Case by Case C&G (520-540) DeptID+5xx+C/S Project No SRAD/PI Support (550) DeptID+555+SP Project Yes (Journal Entry) FSU Foundation DeptID+555+SP Project Yes/FSUF Ck FSU Rsch Foundation DeptID+555+SP Project Yes/FSURF Ck 18 ** - only certain types of auxiliaries are allowable as cost share Effort Commitment Only Proposal contains key personnel effort commitments not supported by sponsor funding No dollar amount proposed as cost sharing Cost share budget not required Exception when related to instruction Commitment must be met Documented in FACET application 19 Cost Sharing Reporting Mandatory/Voluntary Committed SRAS staff responsible for preparing and submitting (when required) to agency Source of report are cost sharing budget expenditures in OMNI Other project used as cost sharing Department provides ledger of expenditures to be used for cost sharing 3rd party cost sharing documented on certification form 20 Cost Sharing and FACET Faculty Assignments Commitments & Effort Certification Tracking (FACET) Enter total effort on project on certification page A-21 page view – automatically allocates effort Direct Charged Salaries Committed Cost Sharing Over the Cap (OTC) Uncommitted Cost Sharing 21 Cost Sharing and FACET Agency Salary Cap (e.g. NIH) Salary Cap must be funded from a nonsponsored source of funds to reflect institution support OTC portion is not allowed to be included to meet cost sharing requirement Fund 556 created to account for the OTC portion of the salary funding 22 Common Issues Setting up cost share budget at Advance stage Department not “spending” cost share budget Spend at same rate as that of sponsored project Cost sharing expenditures must be reflected in OMNI budget established Multi-year projects Cost sharing budget should be increased and funds transferred (when appropriate) Over spending on cost sharing budget May cause budget checking issues at direct child if causes parent to be over budget 23 QUESTIONS