Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

12. Proposing and Tracking Committed Effort

Administrative Responsibilities/Issues:

Cost Sharing:

• Definitions of the various types of cost sharing (mandatory, voluntary, and voluntary uncommitted) are included in an informational tutorial on cost sharing at: http://www.rochester.edu/adminfinance/audit in the section entitled Cost Sharing/Conflict of Interest. At the proposal stage, cost sharing may be either mandatory or voluntary; however, voluntary cost sharing becomes mandatory if the proposal is awarded. Unfulfilled mandatory cost sharing can result in reduced budgets or non-payment to the University. Therefore, it is important to ensure that cost sharing commitments are appropriately carried out once an award is made (e.g., application of appropriate account numbers for salary cost sharing, as well as cost sharing of consumables and/or equipment. There is additional information regarding cost sharing at: http://www.rochester.edu/orpa/policies under the section entitled 'Costing and Financial Administration, Cost Sharing Policy and Procedures'.
  
  
• Cost sharing is most frequently fulfilled through salaries; however, it can also be fulfilled through consumables, equipment (not encouraged), and indirect costs. Federal dollars may not be used for cost sharing unless prior approval has been obtained from the sponsor, nor can faculty practice monies nor hospital monies.
  
  
• Early in the proposal stage, PIs should obtain approval from department chairs, including collaborating chairs, when cost sharing of their departmental faculty/staff salaries is being proposed. Simply translated, this means that a PI is proposing to request a faculty/staff member's effort without requesting the corresponding budget monies from the agency. It should be noted that when cost sharing involves less than 5%, it is not required to be documented and tracked at this institution. However, many departments/schools still require a notification and approval process and may or may not approve inclusion of even these small percentages of effort (>5%), without corresponding budget dollars, in proposals. In addition, the NIH K-Series awards, with their mandatory PI effort (75-85%, depending upon institute) and with a cap upon salary recovery, nearly always appear to involve cost sharing because of this unrecovered salary. This is not considered formal cost sharing and does not require monitoring/tracking. Unrecovered effort for salaries on training grants are, likewise, not considered formal cost sharing and do not need to be monitored.
  
  
• When cost sharing of salaries, other-than-personnel-costs, or indirect costs is involved in a proposal, it is necessary for the PI to submit a Cost Sharing Commitment Form to the Office of Research and Project Administration, signed by all appropriate chairs and Deans, at the time of proposal sign-off. This form is available at: http://www.rochester.edu/orpa/forms.
  
  
• When a proposal involves third party cost sharing (i.e., cost sharing from non-University of Rochester entities), it is important that the PI thoroughly discuss the meaning and implications of cost sharing with the third party(ies). The University's Third Party Commitment Form, as well as the Certification of Cost Sharing, (http://www.rochester.edu/orpa/forms) outline third party cost sharing and detail the reporting requirements to the University from the third party should an award be made. In some departments, a more detailed reporting form is utilized in addition to the above Certification of Cost Sharing, and that should also be shared with the third party in the pre-proposal stage. The Third Party Commitment Form should be signed by the third party and submitted by the PI at the time of proposal Sign-Off. It is very important that the third parties have a clear understanding of cost sharing, and particularly of their reporting requirements, prior to proposal submission. Failure of PI/department to achieve promised cost sharing commitment can result, in numerous agencies, in reduction of budget and/or failure of the University to recover payment for expenditures.
  
  
• When an award involving cost sharing is made, it is then the responsibility of the PI to ensure that the appropriate cost sharing actually occurs within the University and that it is traceable by the Office of Research Accounting and Costing Standards (ORACS). For example, if a faculty member has committed 30% effort to a research project with recovery of only 20% monies, his/her department is responsible to charge 10% of the faculty salary to an account that represents the 10% cost sharing and can support that research. This may not be a federal, hospital or faculty practice account. This is the account that should appear on the Cost Sharing Commitment Form. If the source of cost sharing changes during the budget/project period, the PI should submit a revised Cost Sharing Commitment Form. When the project period is completed, ORACS will send a Salary Certification Form to the PI/departmental administrators for verification and signature. It is this document that verifies the actual account sources of cost sharing with the University FRS system at the time of closeout.
  
  

General Issues:

• How is someone's time spent?

  • Salaries should be consistently allocated across functional process (e.g., teaching, administration, clinical (patient care), research).
  • Laboratory personnel should be appropriately charged across various projects if they perform duties for more than one funded project.
    • Staff should be aware of how their salary is paid.
    • Need to ensure appropriate spending off those projects (i.e., costs applicable only to the specific aims of the particular funding).
      
      
• Allocating appropriate percent of effort to varied projects.

  • PI Role.
    • PI signature should be obtained on all personnel action forms, including 800's.
  • Administrators are responsible for an awareness of proposed budget and compliance in charging of appropriate costs, in addition to ensuring that a cost overrun does not occur.
    
    
• Salary Cap Form:

  • The full effort must be charged to each funded source based upon the proposed/awarded effort. The Salary Cap Form then becomes the mechanism to reduce to the allowable dollar amount to be charged on the project based upon awarded effort times the allowable federal salary cap.
  • When budgeting (in a proposal) salary for individuals whose salary exceeds the federal salary cap, the actual fringe benefit rate should be used in the proposal, since that is the rate that will actually be applied to the capped amount charged to the account.
    
    

Budget Issues:

• When preparing sponsored budget proposals, it is important to base requested salary levels upon anticipated future University salaries. That includes projections for unusual increases due to anticipated promotions and/or equity adjustments.
  
  
• It is important to utilize a sponsored research database (e.g., COEUS, MI$ER, department-designed system) to track effort proposed and awarded/committed effort for faculty/staff, in order to ensure appropriate distribution of salaries once awards are made.