1 Cost Sharing UCM APR #17 Policy Statement Description. Cost sharing or matching represents the use of institutional funds to supplement project costs not borne by the sponsoring agency. Cost sharing constitutes additional financial obligations for the university, thus, UCM policy is to make cost sharing commitments only when required by the funder and then to cost share only to the extent necessary to meet those requirements. All cost sharing must be reviewed and approved prior to proposal submission by directors/chairs/deans/vice presidents (as appropriate) through the inclusion of the cost share on the Office of Sponsored Programs Internal Routing Sheet as well as completion of the Office of Sponsored Programs Commitment for Matching and Cost Sharing form. Determining the acceptability of cost share and what sources can be used as cost share is the responsibility of the Office of Sponsored Programs. Cost Sharing Expenditures. All types of cost sharing expenditures are reportable and must be documented and identifiable. All cash cost share will be transferred from its current university account into the sponsored program account in order to facilitate the reporting and tracking of all project expenditures in one fund. All cash cost share, including personnel salary and benefits, must be transferred as committed to the project. PI/PDs are responsible for completing or acquiring all necessary documentation in order to appropriately budget cost share items for a proposal including in-kind cost share if awarded. PIs are also responsible for obtaining any necessary documentation of in-kind cost share from third parties. Overview Based on the Office of Management and Budget (OMB) Circular A-110, "Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations" (2 CFR 215), The Office of Sponsored Programs requires that all cost sharing on sponsored projects meet the following criteria: Be verifiable from university records Not be included as contributions for any other federally assisted project or program Be necessary and reasonable for proper and efficient accomplishment of the project or program objectives Be allowable under the applicable cost principles Not be paid by the Federal Government or other sponsoring agency under another award, except where authorized Be provided for in the approved budget when required by the sponsoring agency Conform to other provisions of A-110, as applicable In order to meet the requirements of UCM policy and other federal, state, local and sponsor requirements, UCM will create cost share accounts to provide accounting for cost share funds on sponsored projects. All cost sharing expenses must be treated in a consistent manner in proposal preparation and in the financial accounting and reporting to the sponsor. Definitions Cost Sharing (or Matching): The portion of project or program costs not borne by the sponsoring agency. Mandatory Cost Sharing: Cost sharing required by the sponsor as a condition of the award. Voluntary Committed Cost Sharing: Cost sharing that is not required by the sponsor but is voluntarily offered by the institution, documented and quantified in the proposal and accepted by the sponsor. Minimal Effort: Primary Individuals should include at least a minimum level of effort on a sponsored project. At a minimum, a Primary Individual should include at least one percent (1%) of his/her time and effort on a sponsored project for the period of performance. 2 Voluntary Uncommitted Cost Sharing: A cost associated with the sponsored project and not funded by the funding agency, which was not committed in the proposal or in any other communication with the funding agency. Salary Cap: A limit or “cap” on the annual rate of salary reimbursement for a given amount of effort. The difference between the reimbursed salary and the unreimbursed salary above a sponsor imposed salary cap will be considered a mandatory cost share of effort. In-Kind Contributions: Non-cash contributions provided by the university or third parties. Individual: An Individual is any UCM employee who has Committed Effort (whether paid by the Sponsor or Cost Shared) on a Sponsored Program. Where appropriate in this policy, the following subcategories will be utilized: A Primary Individual has some responsibility for the overall conduct and management of the research or activity as described in the proposal/application or as identified in the Notice of Award of a Sponsored Program. A Primary Individual is typically identified in the Sponsored Program Award as the principal investigator, project director, co-investigator, or co-project director and typically, but not always, carries an academic (i.e., faculty) appointment. The PI: In the Effort-Related Policies, when a duty or responsibility falls squarely on only one Primary Individual, that individual may be referred to as The PI. Effort: the amount of time spent on any activity for which an Individual is compensated by UCM. Effort is expressed as a percentage of the Individual’s Total Institutional Activities, which Total Institutional Activities typically include work on Sponsored Programs, teaching and instruction, service, or other duties for UCM. The minimum effort every Primary Individual is required to expend on each of the Primary Individual’s Sponsored Program(s), is generally at least 1%, either directly charged or cost-shared. The minimum effort and a PI’s actual effort should be commensurate with his/her responsibilities. Exceptions to the minimum level of effort may be permitted for equipment and instrumentation grants, doctoral dissertation grants, augmentation grants and special institutional and training awards. Roles and Responsibilities Principal Investigator (PI) Ensures that any Cost Sharing found in his/her Sponsored Program proposal or application complies with this policy; Clearly identifies Cost Sharing in proposals and includes in the narrative or other descriptive parts of the proposals only Mandatory Cost Sharing or Cost Sharing that is approved and intended to become a binding commitment on UCM; Works with his/her supervisor to obtain necessary approvals for Mandatory Cost Sharing and Voluntary Committed Cost Sharing; Ensures Mandatory Cost Sharing and Voluntary Committed Cost Sharing on an Award is provided by either UCM or a third party and is documented Works with the Office of Sponsored Programs to ensure that Cost Sharing is appropriately adjusted. College/Department/Center/Institute Ensures all personnel are familiar with the Cost Sharing policy; and Commits funding, as appropriate, to meet Cost Sharing requirements. Office of Sponsored Project and Research Integrity Advise Principal Investigators of cost sharing requirements; and Review proposals to assure cost sharing commitments are fully documented, all necessary approvals have been obtained, and proposal commitments match the Cost Sharing/Matching Funds Request Form. Provides information necessary to PI and departmental staff for the administration of Cost Sharing In coordination with the PI, verifies that Cost Sharing funds are available and verifies the account number(s) from which the funds will be transferred to a cost sharing account Identifies, monitors and tracks Cost Sharing to assure all requirements are being satisfied 3 In conjunction with Grants and Contracts Financial Services, obtains documentation and certifications as needed for reporting Financial Services Set up cost sharing accounts and transfer funds; Notify PI of companion account numbers; and Report and certify cost sharing to funding agencies as required by award terms and conditions. Procedures Proposal Routing 1. 2. 3. 4. 5. The PI, working with the Office of Sponsored Prgorams staff, must identify any Cost Sharing. The PI must identify the source of funds necessary to support Mandatory Cost Sharing and Voluntary Committed Cost Sharing. Commitments of Cost Sharing from a third party must be delineated and documented in a Letter of Support issued by an authorized official who can legally bind the third party organization (e.g. Company President or Non-Profit Organization Director.) A Cost Sharing Form must be completed for all Mandatory and Voluntary Committed Cost Sharing identifying all cost share commitments and source of funding. In addition to approving Effort Commitments found in a PI’s proposal, the PI’s supervisors (dean, department chair, Center/Institute director, and/or appropriate vice president) must review and approve the Cost Sharing Form for all Mandatory Cost Sharing and Voluntary Committed Cost Sharing found in a proposal. Such approval includes a review and approval of all funding sources identified to support such Cost Sharing. Voluntary Committed Cost Sharing will not be allowed except in very rare situations where (a) the department chair or Supervisor recommends it and supplies written documentation showing that such Voluntary Cost Sharing is needed for the proposal to be competitive, (b) the dean or the supervisor of The PI’s Supervisor recommends such Voluntary Cost Sharing to the provost and (c) the provost, or his/her designee, approves such Cost Sharing. The supporting documentation, recommendations, and provost approval relating to authorized Voluntary Cost Sharing shall be retained in the applicable Sponsored Program file retained by Office of Sponsored Programs. Post Award Monitoring 1. 2. 3. 4. 5. 6. At the time of award, the PI must ensure that the Cost Sharing amounts are still supported by the identified funding sources and that the Cost Sharing amounts are appropriate, especially when the awarded budget is less than the proposed budget. Office of Sponsored Programs will request Financial Services set up the sponsored project account and the cost share account. Financial Services will set up the necessary cost share account(s) and transfer funds from the identified source account(s) to the cost share account(s). Upon account set up, Office of Sponsored Programs will provide a copy of the award documents to the PI and request that all appointments and other relevant expenses be charged to the new cost share account(s) provided by Financial Services. Awards requiring cost share/match will not be processed until complete cost share information has been received. All PI/ PDs, with appropriate oversight from Office of Sponsored Programs, will ensure Mandatory Cost Sharing and Voluntary Committed Cost Sharing is provided, tracked, monitored, and recorded in documents that are retained for audit purposes. Reporting/Closeout 1. 2. Office of Sponsored Programs will obtain certification of cost share/match from the PI, in accordance with the sponsoring agency’s award terms and conditions. Closeout of the companion account(s) will be processed at the same time as closeout of the sponsored project account. Forms 4 Cost Sharing Form (xlsx) Guidance on “Institutional Commitment/Support” in Grant Proposals Sometimes it is necessary to provide institutional commitment/support language in sponsored project proposals, either within the narrative of the application or as a letter attached to the proposal application. This guidance is provided to faculty and staff as they develop such proposals, in the hope that this will speed and simplify proposal development. This guidance also provides introductory thoughts, sample language, and a sample letter as examples for future use. The first and most important item to note is that institutional commitment/support is not cost sharing or matching. Cost sharing and matching are specific terms of art that are primarily differentiated by the use of specific dollar amounts in the grant application (such as, “UCM will commit $50,000 in cash towards the delivery of the project.”). Language reflecting institutional commitment and support does not provide specific dollars amounts; it provides general statements of university support towards the project. The differentiation between institutional commitment/support, on the one hand, and cost sharing, on the other, has important implications for our indirect cost (F&A) structure. Increased cost sharing has the effect of reducing our F&A rate that is subsequently negotiated with the U.S. Government. Down the road, this could reduce F&A distributions. It is in our interest, then, to keep our F&A rate as high as possible, and one way to accomplish that is by minimizing the usage of cost sharing except where it is mandatory or justified in compelling circumstances. Examples of institutional commitment/support language include: “The University will provide offices, labs, and administrative space as necessary for the accomplishment of project deliverables.” “UCM has several labs that will be utilized for the proposed research.” “Administrative staff within the _____________ Department will be available to provide support to the researchers conducting research in this project.” “Several graduate students within the department will be providing basic research support to the researchers during the life of the project.” The main point here is to outline department/college/university support that will be available to the project, without providing specific dollar amounts that could be construed as auditable cost sharing by the sponsor. 2014 JP modified from University of Texas San Antonio Retrieved from: http://vpr.utsa.edu/osp/guidelines.php