Cost Sharing Policy and Procedure Updates and Overview Harvard Medical School Open Forum June 9, 2017 Marc Todesco Portfolio Manager Office for Sponsored Programs

General Definition Sponsor Project $ $ Updated University Cost Sharing Policy Effective July 1, 2017 Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the federal or non-federal sponsored award. $ $ Sponsor Project

Uniform Guidance 200.29 “Cost sharing or matching means the portion of project costs not paid by Federal funds” 200.306 “Under Federal research proposals, voluntary committed cost sharing is not expected” Uniform Guidance reinforces the fact that voluntary committed cost sharing IS NOT expected under Federal research proposals Cost sharing is not to be used as a factor in the review of applications or proposals or as merit criteria Federal agencies must require mandatory cost sharing or not consider at all; if mandatory must be included in the funding opportunity announcement. Appendix I, C.2. “Required cost sharing must be indicated in Notice of Funding Opportunity”

Harvard Policy “Harvard strongly discourages cost sharing, unless such a commitment is required by the sponsor” Explicitly stated in the policy Can be helpful when discussing cost sharing with PI’s

Mandatory Committed Cost Sharing Voluntary Committed Cost Sharing Types of Cost Sharing Included in the proposal Required by the sponsor as a condition of the award Must be tracked in GMAS and may require reporting Mandatory Committed Cost Sharing Pledged on a voluntary basis in the proposal's budget and/or narrative Binding requirement of the award Voluntary Committed Cost Sharing

Voluntary Uncommitted Cost Sharing Types of Cost Sharing Costs and effort that are not included as part of the submitted proposal or upon acceptance of the award Does not need to be tracked or reported Voluntary Uncommitted Cost Sharing Portion of salary and fringe that exceeds regulatory maximum imposed by the sponsor Cannot be used to meet a mandatory or voluntary committed cost sharing requirement Considered an unallowable cost to the sponsor Tracked via companion account for effort reporting Over-the-Cap Salary Over-the-Cap is not tracked in GMAS, but it is tracked in the General Ledger using Companion Accounts

Types of Cost Sharing In-Kind Non-cash contribution of goods and services from the University or donations from third parties Volunteer services or donated equipment at fair market value Must be tracked manually at the department/local unit managing the award In-Kind Little or none at HMS Rare

Recording and Tracking Cost Sharing Commitments at HMS Committed cost sharing must be recorded in GMAS at the proposal stage* HMS will no longer use the paper Cost Sharing Form Update cost sharing budgets and account strings in GMAS Add Rita Bergemann as the Cost Share Signatory to obtain approval Cost sharing expenditures must be allowable per the sponsor’s terms Must be tracked and updated throughout the award lifecycle * NOTE: Proposals which include cost sharing of any type are not part of the Efficiency Project (EP) list, and must be reviewed and authorized for submission by SPA

Tracking Cost Sharing Commitments in the GL and GMAS Utilize companion accounts Using a Non-Sponsored Fund with a Sponsored “Activity.Subactivity” Root Sub-Activity 0101 Sponsored Activity 123456 Sponsored Fund Object Code Org Tub SPONSORED ACCOUNT STRING COMPANION ACCOUNT STRING Tub Org Object Code NON Sponsored Fund Sponsored Activity 123456 Sub-Activity 0101 Root

Monitoring Cost Sharing Commitments Conduct regular reviews and reconciliations Ensure committed cost sharing expenses are posted to the applicable cost sharing account strings (companion accounts) Track and document any non-federal or in-kind contributions Reportable cost sharing on subawards Obtain reports from subawardee to confirm cost sharing commitment Provide OSP with supporting documentation when requested

Record Retention of Cost Sharing Commitments Uniform Guidance 200.306 Cost sharing must be verifiable from the recipient’s records All allowable cost sharing expenditures are considered costs associated with a sponsored project and subject to audit All cost sharing supporting documentation must be retained and uploaded to GMAS Cost sharing transactions not posted to a companion account Reported subaward cost sharing In-Kind contribution detail

FY16 Cost Sharing at HMS GL: Companion Account Transactions 360 Awards with Transactions in GL Totalling $17M in Cost Sharing Expenses $4M Over-the-Cap Salary $13M is Non-Salary Mostly associated with one CTSA

Reminders on Key Updates “Harvard strongly discourages cost sharing, unless such a commitment is required by the sponsor” Cost sharing is not to be used as a factor in the review of applications or proposals or as merit criteria Committed cost sharing must be recorded in GMAS at the proposal stage and tracked throughout the award lifecycle HMS will no longer use the paper Cost Sharing Form Utilize Companion Accounts to track Cost Sharing

Resources & Support Online Content and Job Aids Contacts Training Cost Sharing Policy Cost Sharing FAQs Cost Sharing Online Training Cost Sharing Procedure Guide Recording Cost Sharing Commitment in GMAS Job Aid Companion Account Tracking Job Aid Contacts Rita Bergemann, HMS Director of Research, Finance, and Policy Compliance rita_bergemann@hms.harvard.edu FAS – All of these documents will be complete at the time of presenting, correct? Training June 12, 2017 9:30-11:30am at Lamont Library Forum Room, Cambridge

Questions?