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

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

3. Definitions Pat Dodson 3

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

5. 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 5

6. 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 6

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

8. What Costs Qualify as Cost Share? Pat Dodson 8

9. 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 9

10. 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 10

11. Proposal Process Brian Rogers 11

12. 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 12

13. 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 13

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

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

16. Award Process Jennifer Ward 16

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

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

19. 19 NSF Grant – 1 of 2

20. 20 NSF Grant – 2 of 2

21. 21 DOE Grant

22. 22 Interagency Agreement

23. 23 Subaward Agreement

24. 24 Subcontract Agreement

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

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

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

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

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

30. 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. 30

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

32. Documenting Fulfillment Pat Dodson 32

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

34. 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” 34

35. 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 35

36. 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 36

37. 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 37

38. 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 38

39. Reporting Costshare Sponsored Projects Diane Przygocki 39

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

41. 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 41

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

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

44. SF-425 44

45. SF-270 45

46. SF 270 Specific 46

47. Certification Letter 47

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

49. 49 Annual Cost Sharing Report

50. Closeout Diane Przygocki 50

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

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