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

CommittedMandatoryVoluntary

UncommittedVoluntary (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 documentsMust be reported to the sponsor in the

financial reportMust 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 applicationInternal agreement between the PI and OHSUNot reported to the sponsorDoes not become part of our “research base” and

has no impact on OHSU’s F&A rateStill 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:EffortSupplies or equipment contributed to the

project by the institutionServices or supplies donated by a third partyReduced or waived F&A rates

C/S Requirements

Costs used for committed C/S must be:Allowable per sponsor guidelinesVerifiableIncurred within the project periodProvide 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/docs/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

projectsShows costs associated with various university

activitiesProvides data to help develop the university’s

Facilities & Administrative (F&A) ratesProvides data for various management reportsDocuments 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/docs/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 effortSigned by PISigned by department/institute head;

(Dean if this is also PI)

Effort Reporting

Questions?