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Handbook of Operating Procedures
Chapter 10 - Research
Publication Date: April 17, 2012
Responsible Executive: VP for Research


10.07 Cost Sharing on Sponsored Programs


I. 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. (See Section IX.C.3.a below.)

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.


II. RATIONALE


All Cost Sharing associated with each Sponsored Program must conform to the applicable requirements found in the Office of Management and Budget (OMB) Circular A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations (A-110). In addition, Cost Sharing associated with Effort must also comply with The University of Texas System (UT System) policy 163, Guidance on Effort Reporting and Certification Policies (UTS 163).

This policy provides the mandatory criteria and requirements that must be met regarding Cost Sharing on Sponsored Programs.


III. SCOPE


This policy applies to all UTSA employees involved with any proposal submitted for extramural funding consideration or with any awarded Sponsored Program if such proposals or Awards provide for Cost Sharing of any UTSA resources or third party resources.


IV. WEBSITE ADDRESS FOR THIS POLICY


http://www.utsa.edu/hop/chapter10/10-7.html


V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS


UTSA or UT System Policies or the Board of Regents' Rules & Regulations

  1. UT System policy 163, Guidance on Effort Reporting and Certification Policies
  2. UTSA Handbook of Operating Procedures (HOP) policy 10.05, Managing and Certifying Effort on Sponsored Programs
  3. UTSA HOP policy 10.06, Institutional Base Salary on Sponsored Programs
  4. UTSA HOP policy 10.08, Cost Transfers on Sponsored Programs

Other Policies & Standards

  1. OMB Circular A-110, Uniform Administrative Requirements for Grants & Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations (relocated to 2 CFR Part 215), http://www.whitehouse.gov/omb/circulars_a110/

VI. CONTACTS


If you have any questions about HOP policy 10.07, Cost Sharing on Sponsored Programs, please contact the following office(s):

Office of Sponsored Project Administration (OSPA)
210-458-4340

OSPA Research Service Centers (RSCs)


VII. DEFINITIONS


Award: Depending on its context, either:  (a) the terms and conditions associated with a Sponsor’s decision to select a UTSA Sponsored Program proposal or application for funding, or (b) the Notice of Award or other documentation reflecting such a decision by the Sponsor.

Committed Effort or Effort Commitment: The amount of Effort identified in a Sponsored Program Award agreement or in a Sponsored Program proposal that is submitted and accepted by the Sponsor for funding regardless of whether or not salary support is requested in support of that Effort. (For a more information regarding Effort, see UTSA HOP policy 10.05, Managing and Certifying Effort on Sponsored Programs.) 

Cost Shared Effort or Contributed Effort: The percent of Committed Effort that (1) is contributed by an Individual to a Sponsored Program and (2) is to be paid and cost shared by the University or a third-party. It represents Effort committed to the Sponsored Program with University or third-party resources.

Cost Sharing (or Matching): Obligating or committing UTSA or third-party resources to cover the portion of Sponsored Program costs that are not borne by the Sponsor. In this policy, the following subcategories of Cost Sharing will be used:

  1. Mandatory Cost Sharing: Cost Sharing that is required by the Sponsor as a condition of the award. For a description of one type of Mandatory Cost Sharing, see definition of Salary-Cap Cost Sharing below.
  2. Voluntary Committed Cost Sharing:  Cost sharing that is not required by the Sponsor but is voluntarily offered by the institution, is mentioned and quantified in the proposal, and is accepted by the Sponsor. This may include Minimum Effort committed by a PI that is not directly charged to a Sponsored Program or that is in excess of Mandatory Cost Sharing. This may also include in-kind non-cash Cost Sharing (such as volunteer time) provided by UTSA or third parties. 
  3. Voluntary Uncommitted Cost Sharing:  A cost associated with and expended on a Sponsored Program that was neither funded by the Sponsor nor committed as Cost Sharing by UTSA in the proposal or in any other communication with the Sponsor.

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.

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:

  1. 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.

    1. 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).
  2. A Collaborating Individual is an employee with an academic appointment who expends Committed Effort on a Sponsored Program but does not serve as a Primary Individual on such Sponsored Program.
  3. A Supporting Individual is an employee other than a Primary Individual who does not have a faculty appointment and has expended Committed Effort on a Sponsored Program.

Institutional Base Salary (IBS): The total guaranteed* annual compensation an Individual receives from UTSA, whether the Individual’s time is spent on research, teaching, public service, a continuous university responsibility. (For a more information regarding IBS, see UTSA HOP policy 10.06, Institutional Base Salary on Sponsored Programs.) 

Minimum Level of Effort Commitment:  The minimum Effort every Primary Individual is required to expend on each of the Primary Individual’s Sponsored Program(s), which is generally at least 1% - see HOP policy 10.05, Managing and Certifying Effort on Sponsored Programs, Section IX.B.1.

Salary Cap Cost Sharing:  This mandatory form of Cost Sharing occurs when an Individual’s Institutional Base Salary exceeds the limit or “cap” on the annual rate of salary that a Sponsor will reimburse UTSA for such Individual’s given amount of Effort [which limit is referred to as the Sponsor’s (Salary Cap)].

Sponsors:  Entities, including government, industry, private entities or UTSA, that provide Awards to fund Sponsored Programs at UTSA.

Sponsored Programs: Activities conducted in research, instruction, training, or public service as a result of a formal written agreement (such as a grant, contract, or cooperative agreement), which agreement is typically obtained as a result of a formal application and approval process. These activities can be funded either externally by government, industry, or private sponsors; or, internally by UTSA. Sponsored Programs are separately budgeted and accounted for, meaning there is a defined scope of work, a budget that identifies the costs to be incurred in the performance of the work, and the accumulation of costs actually incurred in support of the project. Sponsored Programs usually involve a specific commitment of time for each Individual involved in achieving the aims of the project. Sponsored Programs may be thought of as transactions in which there are specified statements of work with a related, reciprocal transfer of something of value.

*The Effort-Related Policies are not intended to and will not in any way change the employment relationship between UTSA and any of its employees. Therefore, no language in this policy can support or serve as the basis of any employment-related claim of any UTSA employee.


VIII. RESPONSIBILITIES


    1. The PI/PD
      1. Ensures that any Cost Sharing found in his/her Sponsored Program proposal or application complies with this policy;
      2. 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;
      3. Works with his/her supervisor to obtain necessary approvals for Mandatory Cost Sharing and Voluntary Committed Cost Sharing;
      4. Ensures Mandatory Cost Sharing and Voluntary Committed Cost Sharing on an Award is provided by either UTSA or a third party and is documented; and
      5. Works with their Research Service Center (RSC) to ensure Cost Sharing is appropriately adjusted.
    2. The PI/PD's Supervisor (dean, department chair, Center/Institute director, or appropriate vice president)
      1. Ensures all personnel are familiar with the Cost Sharing policy; and
      2. Commits funding, as appropriate, to meet Cost Sharing requirements.
    3. Office of Sponsored Project Administration (OSPA): Research Service Centers (RSC)
      1. Advises the PI/PD of Cost Sharing requirements;
      2. Reviews proposals to assure that Cost Sharing commitments are fully documented and that all necessary approvals have been obtained;
      3. Identifies, monitors and tracks Cost Sharing to assure all requirements are being satisfied;
      4. In conjunction with Grants and Contracts Financial Services, obtains documentation and certifications as needed for reporting;
      5. Verifies throughout the life of the Award that the Cost Sharing remains available to be used in meeting Cost Sharing commitments under the terms of the Award;
      6. Provides all information necessary to PI for the administration of Cost Sharing; and
      7. 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.
    4. Grants and Contracts Financial Services
      1. Sets up Cost Sharing Account in UTSA's financial system; and
      2. Reports and certifies Cost Sharing to Sponsors as required.
    5. The Vice President for Research (VPR) or his/her Designee
      1. Approves Mandatory Cost Sharing if VPR resources are committed to the Sponsored Program proposal.
    6. The Provost or his/her Designee
      1. Approves all Voluntary Committed Cost Sharing.

    IX. PROCEDURES


    1. Mandatory Criteria/Requirements for Cost Sharing
      To satisfy OMB Circular A-110, OSPA requires that all Cost Sharing associated with a Sponsored Program meet the following criteria:
      1. Be approved by the appropriate department, college and OSPA; [See also Section C, below.]
      2. Be verifiable from UTSA records;
      3. Not be included as a contribution on any other Federally Sponsored Program Award;
      4. Be necessary and reasonable for proper and efficient accomplishment of the project or program objectives associated with the Sponsored Program;
      5. Be allowable under the applicable cost principles;
      6. Not be paid by the Federal Government under another Award, except where authorized;
      7. Be provided for in the approved budget for the Sponsored Program when such Cost Sharing is required by the federal awarding agency; and
      8. Conform to other provisions of A-110, as applicable.
    2. Special Concerns relating to Cost Shared Salary
      Given that the resource UTSA most frequently contributes to Cost Sharing is the salary of Individuals who commit Cost Shared Effort to Sponsored Programs, anyone dealing with Cost Shared Salary should familiarize themselves with UTS 163 and should be aware of the following areas of concern.
      1. Ensure that all Voluntary Cost Sharing is intentionally Pledged
        The PI/PD must carefully handle all discussions regarding Effort and the contributions of other UTSA faculty/staff. Any Cost Shared Effort must be documented and approved though the UTSA cost sharing form by both the Individual providing services to the Sponsored Program and by the Individual’s supervisor or the account owner in advance of the submission of a proposal to a Sponsor. If the potential contributions of a UTSA faculty member are mentioned and quantified in the narrative or other descriptive parts of a proposal (even if the faculty member is not included in the budget or listed as key personnel), then Voluntary Committed Cost Sharing (in the form of the faculty member’s Cost Shared Effort) will likely have been committed to the Sponsored Program.
      2. Quantifying Salary Cap Cost Sharing
        If an Individual must commit Effort to a Sponsored Program, but such Individual’s IBS exceeds the Salary Cap set by the Sponsor, then the prorated, unreimbursable excess is a form of Mandatory Cost Sharing that must be accounted for.
      3. Effort Commitment on Multiple Projects
        Effort commitments used as Mandatory Cost Sharing or Voluntary Committed Cost Sharing on an Award must be used only once and cannot be used against multiple Sponsored Programs. (This requirement also applies to all other types of Cost Sharing - see Section A.3, above.)
      4. Voluntary Uncommitted Effort
        A PI/PD should consult with the RSC in those rare instances that may involve Voluntary Uncommitted Effort, which is not charged to a Sponsored Program or tracked.
    3. Review and Approval of a Cost Sharing found in a Proposal
      1. Identifying and Quantifying Cost Sharing associated with a Proposal
        The PI/PD, working with the RSC, must appropriately value Cost Shared Effort and other in-kind Cost Sharing. Such valuation may require identifying and quantifying Minimum Level of Effort Commitments, quantifying an Individual’s IBS, quantifying Salary Cap Cost Sharing, or assigning an appropriate valuation to equipment or supplies provided by a third party.    
      2. Identifying a Funding Source for Cost Sharing
        1. The financial contributions necessary to support Mandatory Cost Sharing and Voluntary Committed Cost Sharing normally come from internal resources of the PI/PD,  his/her department, or his/her dean. Only in rare cases and only with approval by the VPR or his/her designee, will the Office of the Vice President for Research support any portion of the Mandatory Cost Sharing committed in a proposal.  
        2. 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.)
      3. Receiving Approval for Cost Sharing found in a Proposal
        1. In addition to approving Effort Commitments found in a PI/PD’s proposal, the PI/PD’s supervisor must review and approve the cost sharing 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. 
        2. 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 the RSC.    
    4. Tracking Cost Sharing
      1. Verifying that Cost Sharing Amounts remain available and appropriate
        1. As the Award is being finalized and accepted, 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. 
      2. Monitoring and Reporting Cost Sharing
        1. All PI/PDs, with appropriate oversight from the 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. 
        2. Depending upon a particular Sponsor’s requirements or policies and upon the nature of the Cost Sharing (i.e., whether it is Mandatory or Voluntary Committed), UTSA may also be required to file reports relating to Cost Sharing with a Sponsor.

    X. SPECIAL INSTRUCTIONS FOR IMPLEMENTATION


    None


    XI. FORMS AND TOOLS/ONLINE PROCESSES


    See http://research.utsa.edu/osp/forms.php


    XII. APPENDIX


    None

    Editorial Amendment: December 11, 2013