Cost Sharing James Trotter Quality Standards Manager Sponsored Projects Administration What is Cost Sharing? Cost sharing is sometimes referred to as “matching” or “in kind” Cost sharing is defined as that portion of the total costs of a sponsored project or program not borne by the sponsor Types of Cost Sharing Committed Mandatory Voluntary Uncommitted Voluntary (VUCS) When Cost Sharing consists of effort, any of these three types should be identified and accounted for on effort certification statements Mandatory Cost Sharing Will be identified in the Request For Proposals (RFP) Required by the agency for the award to be given Will be identified in the award documents Must be reported to the sponsor in the financial report Must be accounted for on Effort Certification Statements as committed C/S—it has been committed to the project Voluntary Committed Voluntary Committed Cost Sharing is not explicitly required by the sponsoring agency but has been offered by the PI and OHSU in the application, proposal budget, or budget justification This commitment becomes binding once it is offered and the grant or contract has been awarded It must be accounted for in the Effort Certification process Voluntary committed cost sharing should be minimized at all times and is discouraged as it can lower OHSU’s F&A rate VUCS Voluntary Uncommitted Cost Sharing (VUCS) Not explicitly required on a program and over and above that which is offered in an application Internal agreement between the PI and OHSU Not reported to the sponsor Does not become part of our “research base” and has no impact on OHSU’s F&A rate Still should be captured in the Effort Certification process as Uncommittted C/S Examples of C/S Expenses Some examples of expenses that can be used to satisfy the cost sharing requirements are: Effort Supplies or equipment contributed to the project by the institution Services or supplies donated by a third party Reduced or waived F&A rates C/S Requirements Costs used for committed C/S must be: Allowable per sponsor guidelines Verifiable Incurred within the project period Provide a direct benefit to the project to which it applies Effort as Cost Sharing Committed effort on a sponsored project can be considered Cost Sharing If mandatory or voluntary committed, Cost Sharing must be tracked and reported, and it then becomes part of our “research base” OGA and Cost Sharing Awards with mandatory or voluntary committed cost sharing will have a Cost Sharing account set up in OGA Must provide a Cost Sharing account, usually a departmental general fund, at time of award OGA Numbering System Separate Cost Sharing accounts are set up in OGA using the following numbering system: 1st year of the award - GXXXX0001ACS Numbering System (cont.) 2nd year of the award - GXXXX0001BCS If the main account stays an “A“ throughout the competitive segment, the Cost Sharing account will also stay an “ACS“ Multiple cost sharing accounts will be set up if more than one general fund is provided Cost Sharing Questions? Effort Issues James Trotter Quality Standards Manager Sponsored Projects Administration Procedure Online The full text of OHSU’s Effort Certification Procedure is available on the SPA website: http://www.ohsu.edu/research/rda/spa/d ocs/effortcertproc.pdf The Basics Who? Why? What? When? How? Who? An employee is required to complete an Effort Certification Statement if… Activity is partially or totally devoted to a sponsored agreement (federal grant, contract or cooperative agreement, or federal money from a pass-through entity) AND, pay is partially or totally paid from such an agreement, or represents cost sharing Who Else? Deans, Directors, Department Chairs, and Division Heads must ensure that administrators, investigators, and employees in their units know, understand, and abide by Effort Reporting policy and procedures Principal Investigators (PIs) must understand and abide by Effort Reporting policy and procedures And Who Else? Departmental Effort Coordinators are generally responsible for the distribution, collection, and return of Effort Certification Statements to Sponsored Projects Administration (SPA) SPA is responsible for creation, distribution, and collection of Effort Certification Statements and for maintenance of the Effort Reporting system Why? OHSU’s Effort Certification system was developed in direct response to the Office of Management and Budget (OMB) Circular A-21 A-21 addresses “principles for determining costs applicable to grants, contracts, and other agreements with educational institutions” More Why? A-21 aims to ensure that the Federal Government bears its fair share of total costs The policies and provisions in A-21 are mandatory for institutions that receive federal funds Institutions must be able to document the distribution of charges using an acceptable method Failure to comply with A-21 can have very serious consequences What? The Effort Certification system: Documents effort expended on federally sponsored projects Shows costs associated with various university activities Provides data to help develop the university’s Facilities & Administrative (F&A) rates Provides data for various management reports Documents labor cost sharing on sponsored projects More What? Certification is the assertion, by an employee or a responsible official with suitable means of verification, that labor charges accurately reflect effort expended over the certification period When? OHSU Effort Certification Statements are processed semi-annually for all applicable employees Effort Certification Packets are distributed to Departmental Effort Coordinators approximately 30 days after the end of the effort period Cost Sharing on Effort Statements In absence of salary support on a project, the department can create an ECS to reflect mandatory or committed C/S: http://www.ohsu.edu/research/rda/spa/d ocs/ldesctemp.pdf When and How Soon? Departments have 35 business days from the receipt of Effort Certification materials to distribute, complete, collect, and return all Effort Certification Statements to Sponsored Projects Administration (SPA) Failure to meet the deadline will trigger various escalating “reminders” Normal Certification Removing Suspense Hand Correction Cost Sharing And How? Effort Certification Statement should be signed by the employee Otherwise, the Statement may be signed by a person with suitable means of verification— such as the PI or the employee’s direct supervisor In order to sign, the certifier needs direct knowledge of the employee’s effort How Else? It is generally inappropriate for a Departmental Effort Coordinator or a Department Chair to sign all of the Effort Certification Statements in the unit or department It is always appropriate for a PI to sign statements for employees on her/his projects How High? NIH prohibits employees from receiving a salary greater than the established cap (currently $191,300 annually) Any amount above this cap must be considered as Cost Sharing and charged to the appropriate non-federal account Better Think Twice! What do I do if an Effort Certification Statement must be amended? Make changes by hand and submit the amended Effort Certification Statement with all supporting documentation attached Supporting Documentation SPA Labor Cost Transfer Approval Form Written justification for change in effort Signed by PI Signed by department/institute head; (Dean if this is also PI) Effort Reporting Questions?
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