Uncommitted cost sharing (effort) does not have to be certified -- does this apply to PIs and other faculty and anyone working on a sponsored project, or only to the PI?
The University of Minnesota interprets the January 7, 2001 OMB clarification language to mean voluntary uncommitted cost sharing by ANY project personnel does not need to be certified. However, if voluntary uncommitted cost sharing by any project personnel is used to meet effort obligations to the sponsor, it becomes voluntary committed cost sharing and must be tracked in a cost share chart string and certified as effort associated with the sponsored project.
My proposal seeks funding for a research project that will be primarily conducted by a postdoc. I do not want to charge any of my salary to the project and in the proposal I describe my effort in terms of "as needed to complete the objectives of the project." Is any effort that I put in to the project cost sharing and will I have to certify it?
Unquantified general expressions of support in the proposal are not cost sharing commitments. However, University policies as well as federal regulations require the project PI devote 1% effort during one effort period per year. If it is not charged to the project, it must be certified as committed cost sharing. Only student support (e.g., fellowship or doctoral dissertation), equipment, conference, master agreements, and training grants are excluded from this regulation.
Any effort you put into the project above and beyond that 1% is uncommitted cost sharing and you do not have to add it to the effort statements. This effort should be accounted for on non-sponsored fund sources.
I am a faculty member working on a sponsored project. If I don't have to certify uncommitted cost sharing (effort), will I still be reporting 100% effort on my effort statement?
Yes. You will still be reporting 100% of your effort on the effort statement. You will not, however, be identifying and assigning uncommitted cost shared effort to specific projects. Uncommitted cost shared effort is lumped together in an unidentified way with all other effort on non-sponsored accounts.
My budget justification includes the statement that as the PI, I am willing to volunteer 5% cost sharing (effort) as one of the conditions of receiving the award. The agency subsequently awards this project and includes the 5% cost share (effort) in the notice of grant award.
Is this committed cost sharing or uncommitted cost sharing?
This is committed cost sharing because it was included in the proposal. This cost sharing will be listed on the NOGA and certified in the effort reporting system. Note that this would be true even if you volunteered that effort in the proposal and the agency were silent on the matter of your cost sharing in the award documents; the presumption would be that the agency "took you up on your offer" to commit 5% of your effort.
Assume that a Co-PI has committed 10% cost sharing (effort) on a sponsored agreement and is to direct charge another 10% (effort) to the grant. These arrangements were incorporated into the proposal and the award. However, during the effort period, the researcher works not only the required 20% but also voluntarily expends another 52 hours on the project.
How should the Co-PI certify the effort that is in excess of the mandatory percentages that has been committed/budgeted for?
If the Co-PI is a faculty member, the hours/effort over the committed level would be an example of uncommitted cost sharing and need not be incorporated into the effort certification system. Normally, this researcher would certify only the 10% direct charged and the 10% committed cost sharing on the effort statements. If, however, the Co-PI wished to use these additional hours to satisfy the Co-PI's overall effort obligations on the project (e.g. potentially reduce the Co-PI's 20% effort in a future effort period but still be able to claim an average effort of 20% for the year), it is permissible to certify the extra effort as belonging to the project. In this case, the effort should be treated as committed cost sharing (charged to a cost share chart string for that project and certified as project effort).
I have an award with a cost sharing (effort) commitment of 30%. During the project, some of the other project costs were less than expected and I have room in my budget to direct-charge this 30% effort. Can I direct charge these salary expenses and is sponsor approval necessary?
You may be able to direct charge those costs, if the sponsor allows flexibility in how cost sharing commitment is fulfilled; check your sponsor's terms and conditions or consult Sponsored Projects Administration (SPA) for assistance. However, unless you receive approval from the sponsor, you cannot reduce your overall 30% cost sharing commitment. In this situation, you may wish to write to the sponsor (with countersignature from SPA) to request a reduction in your level of cost sharing.
A research proposal includes a commitment for direct charging of faculty and research staff salaries during the summer months only. Must the PI's effort statements show 1% effort during the academic term?
Most federal projects require some level of effort but this can be provided at any time of the year (summer, academic term or both). Since 2012, the effort periods have been constructed so that some of the summer time period is included in each of the two cycles; you should therefore be able to certify the minimum 1% by the effort that was devoted in either or both of the two effort periods.
What happens if the proposal included 20% cost sharing and the award arrives with a reduction of 15% funding?
If the proposal included the recommended statement that the University will reduce its cost sharing proportionate to any funding reduction awarded by the sponsor, then the SPA Grant Administrator will automatically reduce the cost sharing commitment to 17% (.85 of the 20%). If the original award amount was going to be $100,000, this means that the $20,000 cost share originally contemplated would be reduced to 17% of the $85,000 award, or $14,450.
However, if the statement was not included in the proposal, 20% cost sharing will still be required, unless the PI requests agency approval to reduce it. Note, however, that the actual dollars needed to fulfill the cost sharing will be lower (e.g., 20% of 100,000 requested = $20,000 whereas 20% of $85,000 awarded = $17,000).
What happens if I get to the end of my award and I haven't fulfilled my cost sharing requirement?
If you get to the end of an award and haven't fulfilled your cost sharing requirement, the agency may take any number of actions, up to requiring the University to pay back the full amount of the award. More commonly, an agency might consider a request from the University to reduce or eliminate cost sharing following receipt of an explanation of why we were unable to fulfill our original commitment, particularly if the commitment was not a statutory or RFP-level requirement for cost sharing to have taken place. Another possibility is that the agency will reduce its final award to be proportional with the level of cost sharing that was achieved. (e.g., if we were required to do $75,000 of cost sharing but could only do $50,000, the agency might reduce the final dollar value of its award by 1/3.) Another possibility is asking the agency to allow a retroactive no-cost time extension to allow the PI more time to fulfill the cost sharing requirement. PIs and their department administrators should confer closely with Sponsored Financial Reporting (SFR) and SPA if this problem arises, in order to determine what might be the best solution for their particular circumstance.
Offering Cost Sharing (including Matching and In-Kind Contributions) on Sponsored Projects
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