AGENDA

1
AGENDA

• Cost Sharing Basics
• Ann Holmes, University of Maryland
• Jerry Fife, Vanderbilt University

2
AGENDA contd.

• Federal Perspective
• Jean Feldman, National Science Foundation
• One Universitys Perspective
• Michèle Goetz, San Diego State University
  Foundation

3
WHAT IS COST SHARING?

• A-110
• A.2(i) Cost sharing or matching is the portion of
  project or program costs not borne by the Federal
  Government.

4
DEFINITIONS

• Cash The recipient's cash outlay contributions
  under the direct control of the recipient.
• In-Kind Value of non-cash contributions provided
  by non-Federal third parties.

5
THIRD PARTY IN KIND

• Websters Definition with goods or produce
  rather than money

6
THIRD PARTY IN KIND contd.

• Volunteer Services
• Based on rates paid for similar work
• Associated Benefits
• can not include FA see A-110 c23(e)

7
THIRD PARTY IN KIND contd.

• Donated Equipment Supplies
• At current fair market value

8
CASH CONTRIBUTIONS

• A-110 Definition the recipients cash outlay,
  including money contributed to the recipient by
  third parties.
• Salaries benefits of University employees

9
CASH CONTRIBUTIONS contd.

• University purchased equipment
• Facility Administrative costs on the above
• Waived F A Costs (with permission of the
  sponsor)

10
SOURCES OF CASH CONTRIBUTIONS

• University unrestricted funds contributed to
  project
• State funds
• Gift accounts
• Endowment funds

11
SOURCES OF CASH CONTRIBUTIONS contd.

• FA recovered and returned to departments
• Program income

12
Acceptable Cost Sharing (A-110 C.23)

• Be verifiable from the official University
  records
• Not be used as cost sharing for any other
  sponsored program

13
Acceptable Cost Sharing (A-110 C.23) contd.

• Be necessary and reasonable for proper and
  efficient accomplishment of the project
• Allowable under A-21, the agreement and public
  laws

14
Acceptable Cost Sharing (A-110 C.23) contd.

• Be incurred during the effective dates of grant
• Not be paid by Feds under another award

15
How Is Allowability Determined?

• Allowable Under the agreement, regulations and
  public laws
• Reasonable A prudent person would have purchased
  this item and paid this price

16
How Is Allowability Determined? contd.

• Allocable They can be assigned to the activity
  on some reasonable basis

17
How Is Allowability Determined? contd.

• If a cost cannot meet the above criteria, it is
  UNALLOWABLE, no matter what it is for.

18
Recent Federal Changes

• Actions to Strengthen the University Federal
  Partnership
• NSTC PRD-4 Report (April 1999)

19
Recent Federal Changes contd.

• Cost Sharing Policies and Practices
• The federal requirement that institutions absorb
  the overhead costs associated with voluntary

20
Recent Federal Changes contd.

• Cost Sharing Policies and Practices
• cost sharing in the direct costs of a research
  project can create a disincentive against

21
Recent Federal Changes contd.

• Cost Sharing Policies and Practices
• voluntary contributions of faculty time

22
New Definitions

• Voluntary uncommitted cost sharing
• university faculty effort over and above that
  which is committed and budgeted for in a
  sponsored agreement

23
New Definitions contd.

• Committed (Mandatory and Voluntary) Cost Sharing
• cost sharing specifically pledged in the
  proposals budget or award

24
What Do These Definitions Mean?

• (Voluntary) Uncommitted
• All effort over and above that agreed to as part
  of the award is faculty-donated effort (not
  university-donated effort)

25
What Do These Definitions Mean? contd.

• Since faculty-donated effort is not subject to
  the requirements of Circular A-21, there is no
  need to document uncommitted cost sharing for
  cost accounting purposes

26
What Do These Definitions Mean? contd.

• Committed (Voluntary and Mandatory) Cost Sharing
• Committed and budgeted for in a sponsored award
  refers to budget or budget justification

27
What Do These Definitions Mean? contd.

• Does not include expressions of support included
  in proposal narrative or current and pending
  support pages

28
What Do These Definitions Mean? contd.

• Should not include of effort required in NIH
  modular grant applications (since no cost sharing
  is required by NIH).

29
Accounting Treatment Committed

• Committed Cost Sharing
• Whether mandatory or voluntary, commitments are a
  condition of award, must be captured in the
  accounting system

30
Accounting Treatment Committed contd.

• Must be properly documented for cost accounting
  purposes (i.e. FA rate calculation)
• Committed faculty effort must be captured in
  payroll distribution system

31
Accounting Treatment Uncommitted

• (Voluntary) Uncommitted Cost Sharing
• Treated differently from committed cost sharing

32
Accounting Treatment Uncommitted contd.

• Not included in organized research base for FA
  rate purposes
• Not reflected in any allocation of FA

33
Other Considerations

• Most Federal projects have some level of
  committed effort, paid or unpaid
• Effort can be provided at any time of the year
  summer months or academic year (or both)

34
Other Considerations contd.

• Example If a research proposal includes a
  commitment for direct-charged summer salary only,
  no academic year organized research effort needs
  to be captured

35
Three Categories of Research Effort

• Sponsor-paid Salary
• Unaffected by OMB clarification

36
Three Categories of Research Effort contd.

• Committed Cost Sharing
• Must be accounted for in the payroll distribution
  system and included in the organized research
  base
• Actual salary budgeted (committed) salary

37
Three Categories of Research Effort contd.

• Uncommitted Cost Sharing
• No salary identified in payroll distribution
  system or organized research base

38
Cautions.....

• Committed faculty effort should not be excluded
  from the organized research base by declaring it
  to be voluntary uncommitted cost sharing

39
Cautions ..... contd.

• If a research sponsored agreement shows no
  faculty effort an amount should be included on
  the project and included in the OR base

40
Cautions ..... contd.

• In the future (2 years), OMB and the research
  agencies will evaluate the impactof this
  clarification memorandum.

41
Cautions ..... contd.

• when an institution reduces a faculty members
  level of activities dedicated to other
  institutional responsibilities in order to shift
  his/her activities to organized research
  activities, the institution must reflect

42
Cautions ..... contd.

• this reduction in the payroll distribution
  system.. and in the FA proposals.
• Requires an action by the institution, e.g. a
  reduction in teaching load

43
Precautions...

• Institutions should continue to review for
  expressions of support in proposal narratives,
  etc. Auditors will likely review proposals for
  commitments that are not reflected in the budget.

44
Precautions... contd.

• Increases in FA rates may be scrutinized to
  determine the impact of cost sharing
• Despite the OMB clarification and
  interpretations, audit and negotiation issues are
  inevitable

45
Common Challenges

• There is a lack of clarity in policies among
  funding agencies
• Tracking can be difficult for many institutions -
  administrative burden

46
Common Challenges contd.

• Cost sharing can force a shift of resources from
  other institutional priorities
• Cost sharing auctions can distort the merit
  review process

47
Common Challenges contd.

• Whose dollars will be used to make the match (and
  who approves of the commitment)?

48
Common Challenges contd.

• What happens when our research base grows by the
  50 we planned, and our cost sharing commitments
  grow the same amount?
• Do we really have to track voluntary cost
  sharing?

49
Common Challenges contd.

• Whose responsibility is it to track cost sharing?
• Departments must be involved
• Central must be involved

50
Common Challenges contd.

• How do we track it?
• Separate accounts?
• Separate object codes?
• The infamous shadow systems?
• Must be verifiable

51
Where Things Go Wrong

• There is no cost sharing policy
• Cost sharing is not recorded and included in the
  base
• Both mandatory and committed cost sharing are not
  being captured

52
Where Things Go Wrong contd.

• Proposal commitments do not match amounts
  recorded in financial system or effort system
• Effort system does not capture or segregate
  different types of cost sharing

53
What You Can Do

• Develop a policy
• Mandatory, Voluntary Committed, Voluntary
  Uncommitted
• What can be cost shared
• Who approves cost sharing

54
What You Can Do contd.

• Communicate policy and train
• Research Administration personnel
• P.I.s
• Departmental Administrators

55
What You Can Do contd.

• Establish an accounting methodology to capture
  cost sharing
• Manage cost sharing
• Budget for institutional cost sharing

56
What You Can Do contd.

• Monitor cost sharing in relation to the research
  enterprise

57
Cost Sharing Effort Reporting

• Effort reporting is often used to capture
  committed cost sharing
• Effort reporting is necessary to capture
  voluntary cost sharing - additional effort
  provided by faculty

58
Cost Sharing Effort Reporting contd.

• Additional time spent on a project leads to a
  lower FA rate

59
Effort Reporting

• What is effort reporting?
• A means of verifying that appropriate salary and
  wage expenses were charged to sponsored programs
• A means of verifying that cost sharing was
  performed as promised

60
Effort Reporting contd.

• A means of verifying that total effort
  commitments were met
• A means of verifying that labor costs supporting
  sponsored activity was appropriately classified
  in the facilities and administrative (FA) cost
  rate

61
Effort Reporting Federal Requirements

• OMB Circular A-21, Section J.8 (Compensation for
  Personal Services)
• Audience Educational Institutions

62
Effort Reporting Requirements contd.

• Effort reporting requirements are in section
  J.8.b c
• After-the-fact confirmation of personnel costs
  charged to sponsored agreements

63
Effort Reporting Requirements contd.

• The system must be incorporated into the official
  records of the institution

64
Effort Reporting Requirements contd.

• Must reasonably reflect the activity for which
  the employee was paid
• Must include both sponsored projects and other
  activities

65
Effort Reporting Requirements contd.

• Certification to be performed by an individual
  with knowledge of all the employees activities
• See OMB A21 J.8.c.2.c

66
Cost Sharing at the National Science Foundation
67
Coverage

• The development, issuance, and subsequent
  revision of the NSF Cost Sharing Policy
• NSFs Statutory Cost Sharing Requirement

68
Coverage contd.

• NSF Specific Cost Sharing Requirements
• Audit Issues

69
Pre-Important Notice 124

• In May, 1998, NSF senior management commissioned
  an internal working group to examine NSFs
  existing policies, practices, and concerns from
  the community about the cost sharing issue.

70
Pre-Important Notice 124 contd.

• Charter requested that the working group develop
  a strategy to address legitimate concerns.

71
NSF Working Groups Recommendations

• NSF adopt a clear statement of policy on cost
  sharing
• NSF inform the community of its policy on cost
  sharing via appropriate mechanisms

72
NSF Working Groups Recommendations contd.

• NSF ensure that program officers are aware of the
  guidelines on cost sharing and

73
NSF Working Groups Recommendations contd.

• NSF ask for vigilance on the part of all staff to
  reduce arbitrary and confusing communication of
  NSFs cost sharing policies in all dealings with
  the community.

74
Important Notice 124

• Cost sharing is considered an eligibility
  criterion rather than a review criterion.
• Cost sharing requirements beyond the statutory
  (1) must be clearly stated in the funding
  opportunity.

75
Important Notice 124contd.

• NSF requires only statutory cost sharing for
  unsolicited research projects.

76
Important Notice 124contd.

• Any negotiation with proposers as to the level or
  amount of NSF required cost sharing will occur
  either prior to the review process to establish
  the projects eligibility for consideration or
  after merit review

77
Important Notice 124contd.

• has been completed to adjust cost sharing to
  the agreed-upon amount of the award.

78
Important Notice 124contd.

• NSF program officers must follow the current
  guidance which states that they may discuss with
  PIs the bottom line award amount, but may not
  renegotiate or impose other institutional
  commitments.

79
Important Notice 124contd.

• In budget negotiations, any reduction of 10 or
  more should be accompanied by a corresponding
  reduction in the scope of the project, unless the
  PO, PI and institution clearly agree that the
  project

80
Important Notice 124contd.

• as proposed can be carried out at a lesser
  level of support from NSF with no expectation of
  any uncompensated institutional contribution
  beyond that formally reflected as cost sharing.

81
Reassessment of Cost Sharing Policy

• Even with issuance of the cost sharing policy.
• NSF continued to receive negative feedback
  related to the cost sharing issue from the
  community

82
Reassessment of Cost Sharing Policy contd.

• NSF remained an outlier with respect to the cost
  sharing issue among research funding agencies

83
Reassessment of Cost Sharing Policy contd.

• DOE, NIH, DOD, USDA, and NASA do not regularly
  impose non-statutory programmatic cost sharing
  requirements

84
Reassessment of Cost Sharing Policy contd.

• There continued to be a significant number of
  awards made that included cost sharing on Line M
• The OIG included cost sharing in its 2002 list of
  Management Challenges for the agency

85
Community Feedback

• Program staff continued to negotiate cost sharing
  
• There is too much emphasis on accounting rather
  than results and outcomes

86
Community Feedback contd.

• The role of cost sharing in the merit review
  process remains ambiguous
• The role of cost sharing vs. scientific merit in
  funding decisions by program staff is unclear

87
Community Feedback contd.

• Documenting in-kind contributions remains
  problematic
• Different NSF requirements are established for
  like programs

88
Cost Sharing Challenge

• Audits continued to reveal problems with cost
  sharing that include
• Shortfalls in contributions
• Instances of missing or insufficient documentation

89
Cost Sharing Challenge contd.

• Systems that are inadequate to ensure their
  proper accounting

90
Cost Sharing Challenge contd.

• OIG recommended that NSF re-examine its policies
  on the reporting of cost sharing and resolve any
  questioned costs to better ensure compliance with
  Federal guidelines.

91
Options

• Maintain the status quo
• Defer the decision until further analysis can be
  completed
• Permit imposition of statutory cost sharing
  requirements only, thereby eliminating all
  program specific cost sharing

92
Options contd.

• Require NSB approval prior to imposing program
  specific cost sharing requirements
• Permit imposition of cost sharing only in
  circumstances identified in IN 124, i.e., where
  there is a tangible benefit to award recipients

93
Options contd.

• Infrastructure awards (instrumentation,
  equipment, centers)
• Awards where there is clear potential to generate
  income.

94
Results of Review

• Based on a recommendation by the National Science
  Board Audit and Oversight Committee at their
  August 2002 meeting, BFA reexamined the Cost
  Sharing policy previously issued in June 1999.

95
Results of Review contd.

• Results revealed issues that have surfaced are
  related to enforcement and implementation.
• Basic components of the policy remained valid.

96
Proposed Resolution

• Revise the following aspect of the cost sharing
  policy
• In budget negotiations, any reduction of 10 or
  more should be accompanied by a corresponding
  reduction in the scope of the project, unless

97
Proposed Resolution contd.

• the PO, PI and institution clearly agree that
  the project as proposed can be carried out at a
  lesser level of support from NSF with no
  expectation of any uncompensated

98
Proposed Resolution contd.

• institutional contribution beyond that formally
  reflected as cost sharing.
• Replace with the following language

99
Proposed Resolution contd.

• In budget negotiations, any reduction of 10 or
  more should be accompanied by a corresponding
  reduction in the scope of the project.

100
Important Notice 128 January, 2003

• Cost sharing is an eligibility rather than a
  review criterion
• NSF cost sharing requirements beyond the
  statutory (1) will be clearly stated in the
  relevant program solicitation

101
Important Notice 128 January, 2003 contd.

• NSF can require cost sharing only when there is a
  tangible benefit to the awardee
• For unsolicited research projects, only statutory
  cost sharing will be required

102
Important Notice 128 January, 2003 contd.

• NSF Program Officers may not negotiate or impose
  additional institutional commitments -- however,
  they may discuss the bottom line

103
Important Notice 128 January, 2003 contd.

• Any reduction of 10 or more of the proposed
  budget should be accompanied by a corresponding
  reduction in scope of the research

104
Implementation Progress

• Issued Important Notice 128 (01/03), Revision of
  the NSF Cost Sharing Policy, to clarify position
• Revised Grant Proposal Guide to include cost
  sharing instructions for proposers

105
Implementation Progress contd.

• Do not include voluntary cost sharing amounts on
  Line M of the proposal budget
• Do not exceed the cost sharing level or amount
  specified in the solicitation

106
Implementation Progress contd.

• Do not include voluntary cost sharing amounts on
  Line M of the proposal budget
• Do not include statutory cost sharing on Line M

107
Implementation Progress contd.

• Strengthened review process for solicitations
  that require cost sharing
• FastLane system has been revised to mask Line M
  from reviewers

108
Implementation Progress contd.

• Specific focus has been on internal and external
  training
• Next Use solicitation data to make Line M
  unfillable if cost sharing is not required

109
And the saga continues.
110
NSF Statutory Cost Sharing Req.

• The appropriations providing funds to NSF and
  other independent agencies contain the following
  language

111
NSF Statutory Cost Sharing Req. contd.

• None of the funds provided in this Act may be
  used for payment, through grants and contracts,
  to recipients that do not share in the cost of
  conducting

112
NSF Statutory Cost Sharing Req. contd.

• research resulting from proposals for projects
  not specifically solicited by the Government
  Provided, that the extent of cost sharing by the
  recipient reflect the

113
NSF Statutory Cost Sharing Req. contd.

• mutuality of interest of the grantee or
  contractor and the Government in the research.

114
Documents for Statutory Cost Sharing

• Grantees can comply through use of two
  alternative methods
• Cost share a minimum of one percent on each and
  every project

115
Documents for Statutory Cost Sharing contd.

• Cost share a minimum of one percent on the
  aggregate total costs of all projects requiring
  cost sharing
• Decisions on the method to use are made by the
  grantee

116
Cost Sharing 500,000

• When cost sharing reflected on Line M of the
  cumulative award budget is 500,000 or more, the
  amount of cost sharing must be documented and
  certified by the Authorized Organizational
  Representative.

117
Cost Sharing 500,000 contd.

• Such certifications must be submitted
  electronically via FastLane at least
• 90 days prior to the end of the current budget
  period to meet the annual certification
  requirement

118
Cost Sharing 500,000 contd.

• 90 days following the expiration of the award to
  meet the final certification requirement.

119
If obligation cannot be met

• NSF Grant General Conditions (GC-1) Article 22.b.
  states

120
If obligation cannot be met contd.

• Should the awardee become aware that it may be
  unable to provide the cost sharing amount
  identified on Line M of the NSF award budget, it
  must

121
If obligation cannot be met contd.

• (The grantee must)
• Immediately provide written notification to the
  Grants Officer of the situation

122
If obligation cannot be met contd.

• Indicate steps it plans to take to secure
  replacement cost sharing
• Indicate the plans it has to either continue or
  phase out the project in the absence of cost
  sharing.

123
If obligation cannot be met contd.

• Should NSF agree to the organizations proposed
  plans, the NSF Grants Officer will
• Modify the award accordingly, including, if
  appropriate, reducing the amount of NSF support.

124
If obligation cannot be met contd.

• Should the organizations plans be unacceptable
  to NSF, the award may be subject to termination.

125
If obligation cannot be met contd.

• NSF modifications to proposed cost sharing
  revisions are made on a case-by-case basis.

126
If obligation cannot be met contd.

• Failure by the organization to notify NSF, may
  result in
• The disallowance of some or all of the costs
  charged to the award

127
If obligation cannot be met contd.

• The subsequent recovery by NSF of some or all of
  the NSF funds provided under the award
• Possible termination of the award

128
If obligation cannot be met contd.

• May constitute a violation of the terms of the
  award so serious as to provide grounds for
  subsequent suspension or debarment.

129
NSF Cost Sharing Audit Issues

• Cost Sharing At Risk if award still active or
  Questioned if award expired
• Percentage of total project cost and proportion
  offset to NSF funded share is amount of
  disallowance if inactive

130
NSF Cost Sharing Audit Issues contd.

• Types of cost sharing initially promised are not
  the types actually delivered
• Grantee accounting systems not capturing cost
  sharing identified with a particular project

131
NSF Cost Sharing Audit Issues contd.

• Failure to keep adequate source documentation for
  claimed cost sharing
• Unclear valuation of in-kind donated
  contributions
• Lack of support for cost sharing contributions by
  subrecipients

132
NSF Cost Sharing Audit Issues contd.

• Failure to complete annual certifications for
  awards with cost sharing requirements of 500,000
  or more
• Failure to apply due credits Educational
  Volume discounts

133
Where can I get help from NSF?

• A revised set of FAQs are available on the NSF
  website at
• http//www.nsf.gov/bfa/dga/policy/docs/csfaqs03_1.
  pdf

134
Where can I get help from NSF? contd.

• Types of questions include
• If, how and when cost sharing factors into the
  review process
• Scenarios encountered during pre-award budget
  negotiations

135
Where can I get help from NSF? contd.

• Documentation of cost sharing, including third
  parties
• Audit and Compliance issues, including voluntary
  and involuntary cost sharing situations

136
Final pieces of advice

• Bottom line only commit to cost share when it
  is required, and then, only at level or amount
  required!
• Document, document, document.

137
Cost Sharing Process _at_ SDSU Foundation
138
Who are We?

• California State University System 34,000
  students
• Instructional arm of state educational system
• Approximately 350 active research faculty

139
SDSU Foundation

• Separate 501.c.3 auxiliary to SDSU
• Mission To further the educational, research
  and community service mission of the University

140
SDSU Foundation contd.

• Primary function development and administration
  of grants and contracts
• 130 million in research awards last fiscal year

141
SDSU Foundation contd.

• 60 federal or federal pass-through
• 1100 active awards
• Approximately 165 with cost sharing valued at 19
  million

142
Campus Culture Before 2000

• Limited campus awareness or attention to cost
  sharing issues
• No guidance or restrictions on when cost sharing
  will be offered
• P.I.s offer cost sharing to make proposal more
  competitive

143
Campus Culture

• Cost share tracked on Excel spreadsheets on fund
  by fund basis by SDSU Foundation staff
• P.I.s not responsible for documentation of cost
  sharing
• Documentation typically done at end of project

144
Other Challenges

• Majority of cost share from University or other
  third parties
• Non-specific commitments for faculty effort in
  proposals
• University resistant to providing copies of
  source documents

145
Summer 2000.

• Audited by NSF Inspector General on cost sharing!

146
Audit Findings

• Late effort reports
• R D clustering for A-133 audits
• Cost sharing certification signed by P.I. and
  Administrator

147
Audit Findings contd.

• Unacceptable cost sharing of 1,061 - lost
  receipt for 69 - math error in valuation of
  effort

148
Campus Culture Post Audit

• Clear, articulated Institutional Cost Sharing
  Policies and Procedures
• Greater awareness and cooperation among
  University administration, faculty, and staff

149
Campus Culture Post Audit contd.

• Emphasis on training
• Shared responsibility for documentation

150
Current Policy

• Avoid offering cost sharing if not a requirement
• All cost share offered, voluntary or mandatory,
  must be documented regardless of funding source

151
Current Policy contd.

• Document cost share commitments throughout the
  life of award
• Communicate problems early

152
Cost Sharing Tools

• Training courses for central staff, faculty and
  project staff
• Revised proposal routing form

153
Cost Sharing Tools contd.

• Modified accounting software to track cost share
  commitments electronically
• Monthly reporting to management of documentation

154
Training Research Administrators

• Detailed training of all new central staff
  administrators
• Periodic refresher trainings for pre and
  post-award departments
• Other professional development conferences and
  workshops

155
Training Faculty and Project Staff

• Bi-annual cost sharing training sessions
• One-on-one training with Deans and P.I.s
• Transition meetings
• NCURA Videoconference series

156
Proposal Stage

• Check RFA/RFP to determine if cost sharing is
  required
• All voluntary cost sharing or amounts above
  required level must have Chair and/or Deans
  approval prior to submission

157
Routing Form Revisions

• Revised routing form to require detailed
  breakdown and source of cost sharing
• Salary commitments must identify individual by
  name
• P.I. certifies on routing no hidden cost share
  in proposal narrative

158
Proposal Documentation

• Cost sharing detailed budget signed by all
  contributing parties
• Actual cash match obligations must be certified
  by Department Chair or Dean

159
Proposal Documentation contd.

• Letter of commitment of resources from
  third-party contributors
• P.I. receives copy of cost sharing policies and
  procedures

160
Proposal Documentation

• Advised of the responsibility to provide
  appropriate documentation

161
Initial Post Award Review

• Identify commitments made in proposal
• Validate obligation in writing with P.I., Chair
  and/or Dean and require certification of
  availability of resources
• Input budget commitment into accounting system

162
The PI _at_ Post Award

• Redistribute policy/procedures to P.I.
• Transition meeting

163
Monitoring and Reporting

• Work with P.I. to track and document actual cost
  share expenditures throughout life of award
• Verify cost is allowable under applicable
  policies and valued appropriately

164
Monitoring and Reporting

• Monthly reporting of commitment vs. match
  documented to date
• Management review of progress
• Possible sponsor contact if match not obtainable

165
Subrecipient Match

• Assess subrecipient risk
• Cost share and audit clauses in subagreements
• Subrecipient training and sample documentation

166
Subrecipient Match contd.

• Require source documentation with invoices

167
Closeout Process

• Recheck of all source documents
• Compilation of summary of match obtained vs.
  required match
• Review by Management

168
Closeout Process

• Report to Sponsor Agency if required
• Possible carryover of unmet commitment to
  subsequent year of award
• Storage and retention of records for three years

169
On-going Challenges

• Still primarily a manual system
• Tracking of cost share commitments at Department
  and College level to ensure fulfillment
• Continuing education of faculty and project staff

170
Documentation Challenges

• Documentation of cost share commitments by
  subrecipients
• Identifying and capturing faculty time on effort
  reporting
• Gathering of source documents when expense
  incurred vs. end of project

171
Plans for Enhancement

• Modify accounting system to track total amount
  documented to date
• Exploring capability of booking third-party
  documentation in memo ledger

172
Summary

• Cost Sharing Policy Available at
  http//www.foundation.sdsu.edu/
• Click on Grant and Project Information
• Click on Project Administration Guide

173
Summary continued

• University of Maryland Cost Sharing Policy
• http//www.inform.umd.edu/CampusInfo/Departments/
  PRES/policies/iv400a.html

174
Special Thanks To

• Patrick Fitzgerald MIT
• Robert Hardy - COGR
• Robert Killoren Pennsylvania State
• Beth Mora Harvard University
• Michelle Vazin Vanderbilt University
• Laura Yaeger Huron Consulting Group