Policy Statement
Overview
Definitions
Roles and Responsibilities
Procedures
Policies and Forms
Policy Statement
It is the policy of The University of Texas at San Antonio (UTSA) to provide only the minimum Cost Sharing required on extramurally funded Sponsored Programs, whether such Cost Sharing is in the form of salary associated with Cost Shared Effort or the Cost Sharing of other resources. Voluntary Cost Sharing is highly discouraged; however, with documentation showing that Voluntary Cost Sharing is needed for a proposal to be competitive, the provost or his/her designee may approve Voluntary Cost Sharing.
If (a) Cost Sharing is included in a proposal or an Award document and (b) UTSA either formally accepts the Award or spends the Sponsor’s funds when no formal acceptance of the Award is required, then UTSA is obligated to provide the financial or other resources that have been pledged and to track the Cost Shared resources in a consistent and reasonable manner that complies with applicable federal, state, The University of Texas System (UT System) and UTSA regulations, polices, and guidelines.
Overview
Requests for cost sharing/matching must meet The University of Texas at San Antonio (UTSA) “Cost Sharing on Sponsored Projects” policy as provided in the UTSA Handbook of Operating Procedures (HOP 10.07). Based on the Uniform Guidance, 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards the Office of Sponsored Project Administration (OSPA) requires that all cost sharing on sponsored projects meet the following criteria:
- Be verifiable from university records
- Not be included as contributions for any other federally assisted project or program
- Be necessary and reasonable for proper and efficient accomplishment of the project or program objectives
- Be allowable under the applicable cost principles
- Not be paid by the Federal Government or other sponsoring agency under another award, except where authorized
- Be provided for in the approved budget when required by the sponsoring agency
- Conform to other provisions of 2 CRF Part 200, as applicable
In order to meet the requirements of UTSA policy and other federal, state, local and sponsor requirements, UTSA will create cost share accounts to provide accounting for cost share funds on sponsored projects. All cost sharing expenses must be treated in a consistent manner in proposal preparation and in the financial accounting and reporting to the sponsor.
Definitions
Cost Sharing (or Matching): The portion of project or program costs not borne by the sponsoring agency.
Mandatory Cost Sharing: Cost sharing required by the sponsor as a condition of the award.
Voluntary Committed Cost Sharing: Cost sharing that is not required by the sponsor but is voluntarily offered by the institution, documented and quantified in the proposal and accepted by the sponsor.
Minimal Effort: UT System Policy 163 requires that Primary Individuals include at least a minimum level of effort on a sponsored project. At a minimum, a Primary Individual should include at least one percent (1%) of his/her time and effort on a sponsored project for the period of performance. If a sponsored project does not include a direct charge to the budget for a portion of the Primary Individual’s salary, then a portion of the salary must be committed to the sponsored project as voluntary committed cost sharing
Voluntary Uncommitted Cost Sharing: A cost associated with the sponsored project and not funded by the funding agency, which was not committed in the proposal or in any other communication with the funding agency.
Salary Cap: A limit or “cap” on the annual rate of salary reimbursement for a given amount of effort. The difference between the reimbursed salary and the unreimbursed salary above a sponsor imposed salary cap will be considered a mandatory cost share of effort.
In-Kind Contributions: Non-cash contributions provided by the university or third parties.
Individual: An Individual is any UTSA employee who has Committed Effort (whether paid by the Sponsor or Cost Shared) on a Sponsored Program. Where appropriate in this policy, the following subcategories will be utilized:
- A Primary Individual has some responsibility for the overall conduct and management of the research or activity as described in the proposal/application or as identified in the Notice of Award of a Sponsored Program. A Primary Individual is typically identified in the Sponsored Program Award as the principal investigator, project director, co-investigator, or co-project director and typically, but not always, carries an academic (i.e., faculty) appointment.
- The PI/PD: In the Effort-Related Policies, when a duty or responsibility falls squarely on only one Primary Individual, that individual may be referred to as The PI/PD (Principal Investigator or Project Director).
Effort: the amount of time spent on any activity for which an Individual is compensated by UTSA. Effort is expressed as a percentage of the Individual’s Total Institutional Activities, which Total Institutional Activities typically include work on Sponsored Programs, teaching and instruction, service, or other duties for UTSA. The minimum effort every Primary Individual is required to expend on each of the Primary Individual’s Sponsored Program(s), is generally at least 1%, either directly charged or cost-shared. The minimum effort and a PI’s actual effort should be commensurate with his/her responsibilities. Exceptions to the minimum level of effort may be permitted for equipment and instrumentation grants, doctoral dissertation grants, augmentation grants and special institutional and training awards.
Roles and Responsibilities
Principal Investigator/Project Director (PI)/(PD)
- Ensures that any Cost Sharing found in his/her Sponsored Program proposal or application complies with this policy;
- Clearly identifies Cost Sharing in proposals and includes in the narrative or other descriptive parts of the proposals only Mandatory Cost Sharing or Cost Sharing that is approved and intended to become a binding commitment on UTSA;
- Works with his/her supervisor to obtain necessary approvals for Mandatory Cost Sharing and Voluntary Committed Cost Sharing;
- Ensures Mandatory Cost Sharing and Voluntary Committed Cost Sharing on an Award is provided by either UTSA or a third party and is documented
- Works with the Office of Sponsored Project Administration (OSPA) and its Research Service Centers (RSCs) to ensure that Cost Sharing is appropriately adjusted.
College/Department/Center/Institute
- Ensures all personnel are familiar with the Cost Sharing policy; and
- Commits funding, as appropriate, to meet Cost Sharing requirements.
- Transfers funds to the cost sharing account
Office of Sponsored Project Administration (OSPA)/Research Service Centers (RSC)
- Advise Principal Investigators of cost sharing requirements; and
- Review proposals to assure cost sharing commitments are fully documented, all necessary approvals have been obtained, and proposal commitments match the Cost Sharing/Matching Funds Request Form.
- Provides information necessary to PI and departmental staff for the administration of Cost Sharing
- In coordination with the PI/PD, verifies that Cost Sharing funds are available and verifies the account number(s) from which the funds will be transferred to a cost sharing account
- Identifies, monitors and tracks Cost Sharing to assure all requirements are being satisfied
- In conjunction with Grants and Contracts Financial Services, obtains documentation and certifications as needed for reporting
Grants and Contracts Financial Services (GCFS)
- Set up cost sharing accounts and transfer funds;
- Notify RSC of companion account numbers; and
- Report and certify cost sharing to funding agencies as required by award terms and conditions.
Procedures
Proposal Routing
- The PI/PD, working with OSPA/RSC staff, must identify any Cost Sharing.
- The PI/PD must identify the source of funds necessary to support Mandatory Cost Sharing and Voluntary Committed Cost Sharing. Commitments of Cost Sharing from a third party must be delineated and documented in a Letter of Support issued by an authorized official who can legally bind the third party organization (e.g. Company President or Non-Profit Organization Director.)
- A Cost Sharing/Matching Funds Request Form must be completed for all Mandatory and Voluntary Committed Cost Sharing including Minimum Level of Effort Commitments, Salary Cap Cost Sharing, other non-effort Cost Sharing provided by UTSA and Cost Sharing provided by a third party, identifying all cost share commitments and source of funding.
- In addition to approving Effort Commitments found in a PI/PD’s proposal, the PI/PD’s supervisors (dean, department chair, Center/Institute director, and/or appropriate vice president) must review and approve the Cost Sharing/Matching Funds Request Form for all Mandatory Cost Sharing and Voluntary Committed Cost Sharing found in a proposal. Such approval includes a review and approval of all funding sources identified to support such Cost Sharing. The PI/PD’s supervisor should also cross-check for inadvertent quantified references to Effort by other faculty/staff that could result in unintended Voluntary Committed Cost Sharing.
- Voluntary Committed Cost Sharing will not be allowed except in very rare situations where (a) the PI/PD’s department chair or Supervisor recommends it and supplies written documentation showing that such Voluntary Cost Sharing is needed for the proposal to be competitive, (b) the dean or the supervisor of The PI/PD’s Supervisor recommends such Voluntary Cost Sharing to the provost and (c) the Provost, or his/her designee, approves such Cost Sharing. The supporting documentation, recommendations, and provost approval relating to authorized Voluntary Cost Sharing shall be retained in the applicable Sponsored Program file retained by OSPA.
Post Award Monitoring
- At the time of award, the PI/PD must ensure that the Cost Sharing amounts are still supported by the identified funding sources and that the Cost Sharing amounts are appropriate, especially when the awarded budget is less than the proposed budget.
- OSPA will submit a copy of the completed, signed Cost Sharing/Matching Funds Request Form with cost share budget to GCFS to request set up of the sponsored project account and the cost share account.
- GCFS will set up the necessary cost share account(s).
- Upon account set up, OSPA will provide a copy of the INOA and award documents to the PI/PD and request that all personnel assignments and other relevant expenses be charged to the new cost share account(s) provided by GCFS.
- Awards requiring cost share/match will not be processed until complete cost share information has been received.
- All PI/ PDs, with appropriate oversight from OSPA/RSC, will ensure Mandatory Cost Sharing and Voluntary Committed Cost Sharing is provided, tracked, monitored, and recorded in documents that are retained for audit purposes.
Reporting/Closeout
- OSPA/RSC will obtain certification of cost share/match from the PI, in accordance with the sponsoring agency’s award terms and conditions and will provide the cost sharing information to GCFS.
- GCFS will be responsible for reporting cost sharing to the sponsoring agency as required by the agency’s terms and conditions.
- Closeout of the companion account(s) will be processed at the same time as closeout of the sponsored project account.
Policies and Forms | |
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UTSA HOP 10.07, Cost Sharing on Sponsored Programs |
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Cost Sharing/Matching Funds Request Form (xlsx) |
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Documented Cost Sharing Form (xls) |