Presenters (from University of Colorado Boulder):

NCURA Regional Conference, April 5, 2011Denver, Colorado

COST SHARE COMMITMENTS – JUST A SUGGESTION?

Presenters (from University of Colorado Boulder):

Patricia Dodson, Financial Compliance CoordinatorDiane Przygocki, Manager of Customer Support

Brian Rogers, Proposal AnalystJennifer Ward, Assistant Director for Post Award Services

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Agenda

• Definitions• What kinds of costs qualify as cost share?• Proposal Process• Award Process• Documenting committed C/S• Reporting and Closeout

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Definitions

Pat Dodson

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Definitions

What is cost share?• Project-related costs used to fulfill award

objectives but not paid by sponsor• Specifically committed and quantified at proposal– In proposal budget, or– In budget justification, or– Proposal narrative regarding project SOW

• Or, if or if an explicit dollar value can be assigned to the cost share commitment

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Definitions (cont’d)

• required as a condition of award -- Mandatory– either fixed percentage of total project cost, or– Set dollar amount, negotiated at proposal

• offered by recipient when not specifically required -- Voluntary Committed

• over and above what was agreed upon, or incidental -- Voluntary Uncommitted

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Key Points to Remember

• Once committed, becomes binding– not just a “suggestion”

• Doesn’t matter if sponsor wants report or not– you’ve created a binding obligation

• University needs to ensure fulfillment– requires documentation and record-keeping– records are auditable & need to be retained

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Key Points to Remember

• Expenses are project-related– now part of SOW– “Costs used to satisfy matching or cost sharing

requirements are subject to the same policies governing allowability as other costs under the approved budget”.

• Therefore, need to follow sponsor rules

• Also need to comply with “like” circumstances of University accounting standards

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What Costs Qualify as Cost Share?

Pat Dodson

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C/S Sources

• Cash or cash equivalent– can’t use federal dollars as C/S on another federally funded

award, except where authorized• It can be OK for another sponsored award to act as C/S with prior

approval from both parties

• Cost sharing effort• Can only be offered if have institution salary to cover it• Salary exceeding NIH cap should be captured as cost share

• It isn’t formally committed but must be captured

• In-kind donations– need to have accurate/valid dollar equivalent

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C/S Sources (cont’d)

• Unrecovered Indirect or Facilities and Administration (F&A) costs– A-110, Section C.23.(b): unrecovered indirect costs may be

included in C/S only with prior approval of Federal awarding agency• In other words, put it into the budget

• A sponsored award• Subcontractors

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Proposal Process

Brian Rogers

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Proposal Process: Commitment

Commitment can be intentional or inadvertent:• Intentional:

– Read sponsor guidelines, announcements, RFP’s, RFA’s, and PO’s• Mandatory cost share• Suggested cost share• Showing of “University commitment” to project

• Inadvertent:– Sections to review:

• Budget• Budget Justification• Resources• Facilities

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Proposal Process: Commitment (cont’d)

Example:• Budget Justification: “I will commit 1.5 academic months to this project

without sponsor funding.”– Effort – NSF:

• Voluntary Cost Sharing is not allowed– PI must now have effort and requested salary

• Do not quantify effort in time or amount– Administer the dose provided to the lab mice.– Monitor the results of the data collection center.– Oversee the graduate research assistant in his/her tasks.

• State qualitative attribute in “Resources” section– Effort – NIH:

• PI must state level of effort, even if not requesting funding• Quantify the amount of time

– 1.5 AY months– 100% time, 3 Summer months

• State quantitative attribute in “Budget” section

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Proposal Process: What to Document

1. Determine Type and Amount: – Effort;– Equipment; and/or– Salary/Fringe

2. Determine Source: – University Money

• Department-level; • Dean of college-level; and/or• Vice chancellor-level

– Third-Party Money– In-kind (Non-cash)

• University• Third-Party

3. Ensure Proper Approval: – Signature of Deans/Directors/Chairs; and/or– Third-Party Commitment Letters

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Proposal Process: Where to Document Commitment

• Budget– Three columns per year• Sponsor funds• Cost share funds• Total project funds

– Shows the type and amount of cost share• Cost Share Commitment Form– Shows the source of cost share– Shows the approval for the cost share

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Award Process

Jennifer Ward

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Identify the Commitment

• Where should you look?

– Award Document*– Budget– Budget Justification– Cost Share Addendum (or equivalent)*

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Commitment Identified inAward Document

• Examples

– NSF grant– DOE grant– Interagency Agreement– Subaward Agreement– Subcontract Agreement

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NSF Grant – 1 of 2

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NSF Grant – 2 of 2

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DOE Grant

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Interagency Agreement

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Subaward Agreement

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Subcontract Agreement

Commitment Identified inCost Share Commitment Form

• Having some standard form of documentation makes identification of a commitment much easier– Details to be documented are:

• type of cost share• source• amount• approval (i.e. signatures)

• Without some form of written documentation, the commitment can be misinterpreted or forgotten altogether

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If Commitment is Not Documented

• You become the P.I....

…a Private Investigator, that is.

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If Commitment is Not Documented

• Speak with anybody who may have been involved in making the commitment to get more information

• Principal Investigator• Department Staff• Proposal Analyst• Executive Office (i.e. Office of the Vice Chancellor for Research)

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Role of Messenger

• If the project was awarded as proposed, relay the commitment to the financial staff.

• We do this, currently, via routing sheet and cost share addendum

• If the award was not awarded as proposed, how is the commitment affected?

• Commitment can be reduced proportionately.• Sponsor may expect the commitment to stay exactly

the same.• If not clear, ask the Sponsor what they expect.

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Role of Messenger

• It is your duty to…

– Clarify COMMITMENT

– Document THOROUGHLY

– Document CLEARLY

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Don’t Forget Your Subcontractors

• Do they also have a cost share commitment?– If so, make sure their commitment and reporting requirements

are clear in the subcontract agreement.

• If the prime award has been reduced, has their commitment also been reduced?– It is your responsibility to communicate changes to them.

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Things Can Change

• During the project, circumstances can change.– PI changes– Scope of Work changes– PI transfers to new institution– Funding is reduced

• Communicate with Sponsor to determine how commitment is affected.

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Documenting Fulfillment

Pat Dodson

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Documentation

Sections C.20 & 21, OMB Circular A-110 give required standards for accounting system:

• Track costs related to an award• Separate project-related costs from other cost

purposes– This would also include cost share, because specifically

related to award• Need adequate documentation of project-related

expenses– including cost share

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Documentation (cont’d)

Therefore:• Segregate cost sharing into separate accounts– Don’t commingle with unrelated costs

• Ensure costs are used only once for C/S fulfillment

• Record & track C/S throughout the life of award• All this must be done even if “the sponsor

doesn’t care about our cost share”

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Documentation (cont’d)

A-110, Section C.23:• Section on cost sharing or matching• Lists 7 criteria • University C/S or matching must meet all 7 • Also provides language on determining

valuation of donated services or materials– Would be helpful if your institution had policy

statement regarding donations

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Documentation (cont’d)

Additionally:• C/S should be spent concurrently with award fund– unless there are special terms

• Only commit to C/S when it is required• Educate PIs about C/S– Documentation of in-kind and subs are responsibility

of PI• Get C/S clearly defined at proposal stage with

signed commitments

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Documentation (cont’d)

Additionally:• Contact sponsoring agency for guidance if you

need to deviate from proposed amounts on mandatory C/S

• Remember --- Documented cost share will be included in direct cost base for developing F&A rate

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Documentation (cont’d)

Remember:• Teamwork is important • Educate PIs, admin staff, and campus

administrators why it’s better not to cost share• Learn to say “no”• Once it’s formally committed, must be fulfilled• Document, document, document

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Reporting Costshare Sponsored Projects

Diane Przygocki

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Cost Sharing

• Once we have COMMITTED Cost Share at the proposal stage, we are obligated to ensure we have fulfilled the commitment, whether or not the sponsor asks for a report

• Cost sharing expenses have specific requirements. See UCB policy for more details.

• Policy: http://abs.colorado.edu/ABS_WEB/policies/costshare.pdf

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COST SHARING (cont’d)

• NOTE: – The tracking, reporting, and certifying of cost sharing are subject to

audit. Therefore, records for all cost sharing commitments are to be retained for the same period as the records for its related sponsored agreement.

– Sometimes University contributions to a project were unplanned• Known as “incidental” --- doesn’t need tracking• PI can report that in progress reports but isn’t quantified by SPA• This isn’t subject to audit

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Failure to

• provide the level of cost sharing required and reflected in the approved award budget may result in

– termination of the award

– disallowance of award costs and/or

– refund of award funds by the awardee.

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Reports

• SF-425 – included under Recipient Share

• SF-270 – 11f. Non-Federal Share

• SF-270 specific

• Certification letter – Sent with Invoice

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SF-425

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SF-270

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SF 270 Specific

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Certification Letter

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NSF

• Cost Share > $500,000• Annual Report submitted through FastLane• Email Notification– Each award on individual schedule

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Annual Cost Sharing Report

Closeout

Diane Przygocki

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Closeout

• Review Award to determine that– Expenses are accurate and allowable– Cost Share commitment has been fulfilled– Cost Share has been Reported to Sponsor if

required– Cost Share expenses have been documented and

are accessible with the main Award records

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Web Site & Contact Information

http://abs.colorado.edu/

http://www.colorado.edu/VCResearch/

[email protected]

[email protected]

[email protected]

[email protected]

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