Slide 1

NCURA Regional Conference, April 5, 2011 Denver, Colorado COST SHARE COMMITMENTS JUST A SUGGESTION? Presenters (from University of Colorado Boulder): Patricia Dodson, Financial Compliance Coordinator Diane Przygocki, Manager of Customer Support Brian Rogers, Proposal Analyst Jennifer Ward, Assistant Director for Post Award Services 1

Slide 2

Agenda Definitions What kinds of costs qualify as cost share? Proposal Process Award Process Documenting committed C/S Reporting and Closeout 2

Slide 3

Definitions Pat Dodson 3

Slide 4

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 4

Slide 5

Definitions (contd) 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 5

Slide 6

Key Points to Remember Once committed, becomes binding not just a suggestion Doesnt matter if sponsor wants report or not youve created a binding obligation University needs to ensure fulfillment requires documentation and record-keeping records are auditable & need to be retained 6

Slide 7

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 7

Slide 8

What Costs Qualify as Cost Share? Pat Dodson 8

Slide 9

C/S Sources Cash or cash equivalent cant 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 isnt formally committed but must be captured In-kind donations need to have accurate/valid dollar equivalent 9

Slide 10

C/S Sources (contd) 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 10

Slide 11

Proposal Process Brian Rogers 11

Slide 12

Proposal Process: Commitment Commitment can be intentional or inadvertent: Intentional: Read sponsor guidelines, announcements, RFPs, RFAs, and POs Mandatory cost share Suggested cost share Showing of University commitment to project Inadvertent: Sections to review: Budget Budget Justification Resources Facilities 12

Slide 13

Proposal Process: Commitment (contd) 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 13

Slide 14

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 14

Slide 15

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 15

Slide 16

Award Process Jennifer Ward 16

Slide 17

Identify the Commitment Where should you look? Award Document* Budget Budget Justification Cost Share Addendum (or equivalent)* 17

Slide 18

Commitment Identified in Award Document Examples NSF grant DOE grant Interagency Agreement Subaward Agreement Subcontract Agreement 18

Slide 19

19 NSF Grant 1 of 2

Slide 20

20 NSF Grant 2 of 2

Slide 21

21 DOE Grant

Slide 22

22 Interagency Agreement

Slide 23

23 Subaward Agreement

Slide 24

24 Subcontract Agreement

Slide 25

Commitment Identified in Cost 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 25

Slide 26

If Commitment is Not Documented You become the P.I.... a Private Investigator, that is. 26

Slide 27

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) 27

Slide 28

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. 28

Slide 29

Role of Messenger It is your duty to Clarify COMMITMENT Document THOROUGHLY Document CLEARLY 29

Slide 30

Dont 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. 30

Slide 31

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. 31

Slide 32

Documenting Fulfillment Pat Dodson 32

Slide 33

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 33

Slide 34

Documentation (contd) Therefore: Segregate cost sharing into separate accounts Dont 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 doesnt care about our cost share 34

Slide 35

Documentation (contd) 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 35

Slide 36

Documentation (contd) 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 36

Slide 37

Documentation (contd) 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 37

Slide 38

Documentation (contd) Remember: Teamwork is important Educate PIs, admin staff, and campus administrators why its better not to cost share Learn to say no Once its formally committed, must be fulfilled Document, document, document 38

Slide 39

Reporting Costshare Sponsored Projects Diane Przygocki 39

Slide 40

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/costs hare.pdf http://abs.colorado.edu/ABS_WEB/policies/costs hare.pdf 40

Slide 41

COST SHARING (contd) 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 --- doesnt need tracking PI can report that in progress reports but isnt quantified by SPA This isnt subject to audit 41

Slide 42

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. 42

Slide 43

Reports SF-425 included under Recipient Share SF-270 11f. Non-Federal Share SF-270 specific Certification letter Sent with Invoice 43

Slide 44

SF-425 44

Slide 45

SF-270 45

Slide 46

SF 270 Specific 46

Slide 47

Certification Letter 47

Slide 48

NSF Cost Share > $500,000 Annual Report submitted through FastLane Email Notification Each award on individual schedule 48

Slide 49

49 Annual Cost Sharing Report

Slide 50

Closeout Diane Przygocki 50

Slide 51

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 51

Slide 52

Web Site & Contact Information http://abs.colorado.edu/ http://www.colorado.edu/VCResearch/ pat.dodson@colorado.edu diane.przygocki@colorado.edu brian.p.rogers@colorado.edu jennifer.ward@colorado.edu 52