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

2. 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

3. Uniform Guidance
200.29
“Cost sharing or matching means the portion of project costs not paid by Federal funds”
“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”

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. Record Retention of Cost Sharing Commitments
Uniform Guidance
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

12. 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

13. 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

14. 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
FAS – All of these documents will be complete at the time of presenting, correct?
Training
June 12, :30-11:30am at Lamont Library Forum Room, Cambridge

16. Questions?