10.07 Cost Sharing on Sponsored Programs

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I. POLICY STATEMENT

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It is the policy of The University of Texas at San Antonio (UTSA) to provide only the minimum Cost Sharing required by a Sponsor in written Sponsored Program proposals, whether such Cost Sharing is in the form of salary or other resources. Offering to share costs is highly discouraged. Under certain conditions, if Cost Sharing is needed for a proposal to be competitive, the Vice President for Research, Economic Development, and Knowledge Enterprise (VPREDKE) or his/her designee may approve 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 and state laws and The University of Texas System (UT System) and UTSA regulations, polices, and guidelines. Tracking such Cost Shared resources requires “cost share cost centers” to be set up in connection the awarded Sponsored Program Project IDs in PeopleSoft.

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II. RATIONALE

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All Cost Sharing associated with each Sponsored Program must conform to the applicable mandatory requirements found in the Office of Management and Budget (OMB) Uniform Guidance (UG) 2 CFR 200.306 at https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.306

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III. SCOPE

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

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IV. WEBSITE ADDRESS FOR THIS POLICY

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http://www.utsa.edu/hop/chapter10/10.07.html

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V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS

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

1. HOP 10.06, Institutional Base Salary and Payroll Confirmation on Sponsored Programs
2. HOP 10.08 Cost Transfers on Sponsored Programs
3. Office of Management and Budget (OMB) Uniform Guidance (UG) 2 CFR 200.306:
   https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200/subpart-D/section-200.306

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VI. CONTACTS

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

A. Office of Sponsored Project Administration (OSPA):
1-210-458-8250
1-210-458-8575

B. Office of Research Finance and Operations (ORFO):
postaward@utsa.edu
1-210-458-5956
1-210-458-8144

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VII. DEFINITIONS

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1. 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.
2. Cost Sharing (or Matching): Obligating or committing UTSA or third-party resources to cover the portion of Sponsored Program costs 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.
   2. Voluntary Committed Cost Sharing: Cost sharing that is not required by the Sponsor but is voluntarily offered by UTSA, is mentioned and quantified in the proposal, and is accepted by the Sponsor.
   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.
3. Individual: An Individual is any UTSA employee who is paid (whether paid by the Sponsor or Cost Shared) on a Sponsored Program. In this policy, the following subcategories will be utilized:
   1. A Primary Individual has 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 (PI) or project director (PD).
   2. A Collaborating Individual is a UTSA employee who is paid on a Sponsored Program but does not serve as a Primary Individual on such Sponsored Program. A Collaborating Individual is typically identified in the Sponsored Program Award as the co-investigator (Co-PI).
   3. A Supporting Individual is an employee other than a Primary or Collaborating Individual, who does not have a faculty appointment and is paid on a Sponsored Program.
4. Institutional Base Salary (IBS): IBS is the base compensation set by UTSA for an Individual’s appointment (either 9 or 12-months), whether that Individual’s professional time for UTSA is spent on instruction/teaching, research, service, administration, or other activities, and whether that employee is appointed full-time or part-time. For faculty with a nine-month appointment, the IBS is annualized to equal a twelve-month total compensation for budget purposes. See HOP 10.06 Institutional Base Salary (IBS) and Payroll Confirmation on Sponsored Programs for details.
5. Sponsors: Entities, including government, industry, private entities, or UTSA, which provide Awards to fund Sponsored Programs at UTSA.
6. 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 involve a specific commitment of time for each Individual involved in achieving the aims of the project.

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VIII. RESPONSIBILITIES

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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):
   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. Office of Research Finance and Operations (ORFO)
   1. Sets up Cost Sharing Account in UTSA's financial system; and
   2. Reports and certifies Cost Sharing to Sponsors as required.
5. Vice President for Research, Economic Development, and Knowledge Enterprise (VPREDKE) or his/her Designee
   1. Approves Mandatory Cost Sharing if VPREDKE resources are committed to the Sponsored Program proposal; and
   2. Reviews and approves, if deemed appropriate, Voluntary Cost Sharing.

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IX. PROCEDURES

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1. Mandatory Criteria/Requirements for Cost Sharing
   1. To satisfy OMB UG 2 CFR 200.306, OSPA requires that all Cost Sharing associated with a Sponsored Program meet the following criteria:
      1.1 Be approved by the appropriate department, college and OSPA on the UTSA Cost sharing form;
      1.2 Be verifiable from UTSA records;
      1.3 Not be included as a contribution on any other Sponsored Program award;
      1.4 Be necessary and reasonable for proper and efficient accomplishment of the project or program objectives associated with the Sponsored Program;
      1.5 Be allowable under the applicable cost principles;
      1.6 Not be paid by the Federal Government under another Award, except where authorized;
      1.7 Be provided for in the approved budget for the Sponsored Program when such Cost Sharing is required by the federal awarding agency; and
      1.8 Conform to other provisions of UG 2 CFR 200, as applicable.
2. Special Concerns related to Cost Sharing
   1. Ensure that all Volunteary Cost Sharing is intentionally Pledge:
      1.1 The PI/PD must carefully handle all discussions regarding payroll charges and the contributions of other UTSA faculty/staff. Any Cost Sharing 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 will likely have been committed to the Sponsored Program.
   2. Payroll Charges on Multiple Sponsored Programs:
      2.1 Mandatory Cost Sharing or Voluntary Committed Cost Sharing on an Award must be used only once and cannot be used against multiple Sponsored Programs.
3. Review and Approval of a Cost Sharing found in a Proposal
   1. Identifying and Quantifying Cost Sharing associated with a Proposal:
      1.1 The PI/PD, working with OSPA, must appropriately value the amount of cost sharing. Such valuation requires quantifying an Individual’s IBS or assigning an appropriate valuation to equipment or supplies provided by a third party.
   2. Identifying a Funding Source for Cost Sharing:
      2.1 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.
      2.2 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:
      3.1 In addition to approving all types of 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.
      3.2 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 VPREDKE (c) the VPREDKE 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.
4. Tracking Cost Sharing
   1. Verifying that Cost Sharing Amounts remain available and appropriate:
      1.1 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
      2.1 All PI/PDs, with appropriate oversight from ORFO, will ensure Mandatory Cost Sharing and Voluntary Committed Cost Sharing is provided, tracked, monitored, and recorded in documents that are retained for audit purposes.
      2.2 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.

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X. SPECIAL INSTRUCTIONS FOR IMPLEMENTATION

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None

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XI. FORMS AND TOOLS/ONLINE PROCESSES

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None

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XII. APPENDIX

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None

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XIII. DATES APPROVED/AMENDED

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04-29-2022
04-17-2012