Proposal Related

Unified Policy and Procedure Guide to Cost Sharing

Reason for Policy and Procedure Guide

Cost sharing requires advanced notice and approvals from various stakeholders. This guide provides clarifying and updated information to the official Policy on Cost Sharing dated July 1, 1998. This guide also consolidates previous guidance and procedures into a single document.

Applicability

This policy applies to all sponsored projects, federal and non-federal.

Effective Date: July 1, 2021

 

Quick links

Official 1998 Cost Share Policy and Procedure Guide
Kuali Build Form Repository

Definitions, Processes and Approvals

Table of Contents

Cost Sharing

  • Cost sharing is defined as the portion of the total project costs of a specific sponsored project that is borne by the Amherst campus (or in some cases, a third party), rather than the sponsor.
  • Cost sharing normally represents a reallocation of departmental or campus resources to partially support an externally sponsored project.
  • All cost share used on a project must directly benefit that project.
  • Cost sharing is classified as either mandatory or voluntary.
  • It is the policy of the Amherst campus to assume a cost sharing commitment only when required by the sponsor or when necessitated by the competitive nature of the award, and then to cost share only to the extent necessary to meet the specific requirements.
  • An agreement to cost share, whether voluntary or mandatory, represents a binding legal commitment, subject to audit, on behalf of the Amherst campus to provide the stated resources, services or assets during the performance of the project.
  • Certain types of expenses are very difficult to track and therefore are discouraged as a source of cost share. See below for the types of costs that are most commonly used to meet cost share commitments.
  • Cost sharing is typically funded by non-grant sources; Federal funds cannot be used to match other Federal funds.
  • Cost sharing can be provided through in-kind contributions and/or through new outlays of real cash funding used specifically for the project.
  • Cost shared personnel and items must contribute directly to the project and be credited in accordance with the benefits received.
  • Administrative support is allowable if it meets Office of Management and Budget (OMB) Uniform Guidance, Federal cost accounting principles and can be treated as a direct cost.
  • Cost sharing must be expended and incurred during the project's period of performance.
  • Most sources of cost share require upstream review and approval. See below for more information.

Mandatory Cost Sharing

  • Mandatory cost share is a written requirement of the sponsor detailed in program announcements; typically, it is an eligibility requirement, and any award is contingent upon the campus' ability to fulfill its cost share obligation.
  • Mandatory cost sharing can include most typical direct cost budgeted items and indirect costs depending upon the specific requirements of the sponsor and/or source of cost share.

PROCESS:
The campus accepts mandatory cost sharing requirements when the following conditions have been met:

  • The cost sharing requirement is documented in the written application guidelines of the sponsor and those policies are available to the Office of Pre-Award Services (OPAS) in its review of the proposal.
  • The person(s) responsible for contributing the funds to cover the cost sharing has reviewed and approved the proposal to signify the ability and willingness to provide the required cost sharing resources (e.g., percent of principal investigator's salary to cover the effort devoted to the project).

Voluntary Cost Sharing

  • Voluntary cost share is NOT a requirement of the sponsor, but rather an offer by the campus to voluntarily cost share the project, whether the cost share is shown on the budget page or only in the text of the proposal.
  • Voluntary cost sharing also includes situations where a commitment is not made in a proposal, but the campus absorbs costs which directly benefit the project.
  • Voluntary cost share is EXTREMELY rare and the Office of Management and Budget (OMB) Uniform Guidance prohibits Federal agencies from allowing voluntary cost share in proposals.
  • Once volunteered, like any cost share, voluntary cost sharing becomes a legal and binding commitment to track and account for the cost share.
  • Cost sharing should not be included in proposals unless mandated in the program announcement or required by the competitive nature of the award. This does not mean that investigators should not devote effort to projects that do not supply salary, nor does it mean that the university should not contribute resources toward the project. If there is no mandatory cost share requirement, PIs should instead describe their participation in terms that do not commit the institution to a specific percentage of effort or to specific amounts of other non-salary expenses.
  • If you believe your circumstance requires voluntary cost share, please make a request for review and approval through the process described below.

PROCESS:

  • Request for approval must be received 10 business days PRIOR to the OPAS 5-day deadline.
  • Requests must include a robust justification of competitive need to voluntary cost share.
  • Include the sponsor solicitation for analysis.
  • Fill out the Cost Share Request Form.

Sources of Cost Share

Third Party Cost Share

  • Consists of contributions, cash or in-kind, from non-university sources and entities. Note that the university is obligated to provide the cost-sharing if the third party does not meet the obligation, and in such cases, the department or PI must cover those costs.
  • There is inherent risk in cost share from third parties, and therefore it requires approval and liability acceptance from an appropriate administrator as well as final approval from the Vice Chancellor for Research and Engagement (VCRE).
  • Liability acceptance includes any financial contributions needed to meet cost share thresholds if the third- party contributor(s) fail to meet their documented obligations.
  • Third party cost share provided under an award agreement, via subcontractors or subrecipients, do NOT need separate prior approval.
  • Third party cost share sources are not subject to UMass indirect costs. If the third-party includes in the total its own indirect cost, that is allowable. In the Kuali cost-share budget, the total third-party cost should be reflected as non-personnel object code “other direct no F&A” to be exempted from UMass indirect costs. Should the project be awarded, the third party, or parties, would be required to enter into a formal agreement with the university indicating commitment to provide the university reports and supporting documentation on its contribution for auditing purposes.

PROCESS:
The PI should provide:

  • A justification with specific details why the third-party cost-share is needed and documentation for how the match will be tracked and reported.
  • A copy of the detailed budget with the third-party match and a version without that match
  • A letter from the third-party contributor that provides details about the resources committed and should be signed by the individual authorized to make such commitments (sponsored program office, OPAS equivalent, contracting officer, business official, etc.). Costs must be auditable and directly allocable to the project and documented in the letter of support/commitment.
  • Upload a written statement from an authorized UMass person, typically a Department Head/Chair or Dean, who will assume liability of the third-party cost share in terms of oversight and responsibility for any disallowed costs.
  • Fill out the Cost Share Request Form.

Tuition Credit Cost Share

  • Tuition credits are the amount between actual tuition and what is normally charged on proposals.
  • Currently, UMass does not recoup full tuition from sponsored agreements even though students can receive a full tuition waiver for their work on a project.
  • The current tuition amount can be found on the UMass Sponsored Activities Fact Sheet.
  • Whenever possible, tuition credits should be used to cover mandatory cost share.

PROCESS:

  • The graduate school must be included on the Kuali routing map for approval. Luke Iain, Director of Finance and Administration in the Graduate School, is currently assigned to approve.
  • No other approvals are necessary.

Academic Year (AY) Salary Cost Share

  • Since AY salary is typically paid by state funds, this cost share comes in the form of in-kind contribution.
  • When cost sharing AY salary, PI, Department Heads and Deans agree that the effort will not be used for other activities based on the workload of the faculty involved.
  • This effort must be included in the overall allocation of activities and cannot be added by working additional hours. Fill out the

PROCESS:

Graduate Student, Faculty Summer, and Other Non-faculty Salary Cost Share

  • These types of salaries and associated benefits can be used as cost share if a university source can cover the real cost and provide cash from non-grant or RTF funds.

PROCESS:

  • In Kuali, include the appropriate speed type for the salaries to be cost shared.
  • Include any party that is contributing cash to the Kuali proposal routing MAP.
  • Upload any additional approvals, MOU, etc. to the Kuali internal attachment area.
  • NOTE: Grad Student tuition CANNOT be cost shared. Only associated tuition credits.

Associated Fringe benefits and F&A Cost Share

  • Unless sponsor guidelines explicitly state otherwise, cost sharing can be claimed on associated fringe benefits and the indirect costs associated with any direct charges that are shown as UMass cost share.
  • No pre- approval is necessary.

Unrecovered F&A Cost Share

  • When the sponsor requires a lower rate than our Federally approved rates, the amount of the F&A reduction from the full rate may be used towards cost share requirements unless there is a documented restriction from the sponsor or solicitation.
  • No pre-approval is necessary.

F&A (Indirect Cost) Waiver or Reduction Cost Share

  • An F&A waiver is when the sponsor allows the use of approved F&A rates but UMass elects not to charge the full rate to the sponsor.
  • The difference can be used to meet cost share requirements based on recommendations from the Department and School/College with final approval from the Vice Chancellor for Research and Engagement.
  • It is rare that the VCRE approves F&A waivers in general and/or for use as cost share.
  • Departments and Colleges should be aware that any F&A waiver also reduces their F&A return on the award.

PROCESS:

  • Please ensure the Kuali Build request form arrives to the VCRE 10 business days prior to the OPAS review deadline. Build will automatically be routed to your Department Head/Chair and Dean’s office for review and approval prior to arriving at the VCRE approval stop. Please note that Department Head/Chair and Dean’s approvals should be done to meet the 10-day VCRE deadline.
  • Department Head/Chairs and Deans will have opportunities to provide additional justifications in the designated comments section.
  • Requests with inadequate justifications will be returned via Build for clarifications.
  • Include budgets that show how the project would be funded with and without the waiver.
  • The form submitter will receive an automated email from Kuali Build indicating whether the request has been approved along with comments provided by the VCRE on their determination.
  • Fill out the F&A (Indirect Cost) Waiver or Reduction Cost Share Request Form.

Equipment

  • The equipment must be purchased within the proposed grant period to benefit the project and must be dedicated exclusively to the proposed project or pro-rated based on use for the project.
  • Ownership of equipment will remain with UMass at the end of the project period.

PROCESS:

  • Include any party that is contributing cash to the Kuali proposal routing map.
  • Upload any additional approvals, MOU, etc. to the Kuali internal attachment area.

Requests for Cash Contributions from the Provost and VCRE

  • For some proposals there may be reason to request funding support from VCRE and/or the Provost. This may come in the form of mandatory cost share requirements or voluntary institutional commitments. Examples include Center grants, instrumentation projects, training programs support.
  • In order to obtain financial contributions, funding must also be committed by the PI, Departments, and Deans offices before making requests to the VCRE and Provost. It is expected that cost share needs less than $10,000 will be funded at the School/College level in its entirety.
  • Cost share needs for amounts greater than $10,000, where some portion is requested to be supported by the VCRE and/or Provost, will only be considered after filling out the Kuali Build request form
  • If approved, cost share support from the VCRE and/or Provost typically will not exceed 50% of the total cost-sharing. All PI, Department, and College level funding should be listed.

PROCESS:

  • All requests for cost share to the VCRE and Provost should be made as early as possible and no later than 10 business days prior to the OPAS 5-day deadline.
  • If inadequate time is given, even if requested 10 business days prior OPAS 5-day deadline, depending on the nature and extent of cost share, there is no guarantee that the proposal will be submitted to the sponsor.
  • Department Head/Chairs and Deans will have opportunities to provide additional justifications in the designated comments section of Kuali Build.
  • Requests with inadequate justifications will be returned via Kuali Build for clarifications.
  • The form submitter will receive an automated email from Kuali Build indicating whether the request has been approved along with comments provided by the VCRE on their determination.
  • Fill out the Cost Share Request Form.

Documentation Needed for OPAS Review and Submission

  • All parties who have agreed to cost share should be added to the Kuali routing map for approval UNLESS there is an attached signed MOU detailing the cost share commitments.
  • All cost share in the Kuali budget should be broken down by source and cost types and assigned appropriate speed types (see Kuali Guide on Cost share for specific instructions).

FAQ

  • My contract as a tenure track faculty for my 9-month academic appointment clearly states that I should devote a significant amount of my academic time to seek external funding and establish a strong research program. This clearly implies that a substantial part of my effort should be dedicated to research as part of my 9-month salary. Can I state this effort in a grant proposal, even though it isn’t funded or needed to meet mandatory cost-share?
    • How the commitment is worded will determine the allowability. You cannot directly commit quantifiable effort to any given project unless you are requesting the salary for effort from the sponsor or meeting mandatory cost share requirements. That does not mean that you cannot perform research activities that relates to a sponsored award. See examples of acceptable and unacceptable statements of uncompensated academic year effort.
    • Example 1 – Acceptable Statement: “Summer salary is requested for 2.4 months of time to conduct studies on …… The PI will be fully involved in the project throughout the year to ensure that the scope and objectives are met.”
    • Example 2 – Unacceptable effort statement: “Summer salary is requested for 2.4 months of time to conduct studies on ... In addition, the PI will devote a significant portion of academic year effort as part of their normal 9-month appointment research responsibilities.”
    • Example 3 – Unacceptable effort statement: “Summer salary is requested for 2.4 months of time to conduct studies on ... In addition, the PI will devote 1 month of academic year effort as part of their normal 9-month appointment research responsibilities.”
  • I have spoken with my Program Manager at NSF and they said it is fine for me to show unpaid effort in the summer and use funding to support my students. Why is the university telling me I can’t?
    • As an employee on a 9-month academic appointment your summer effort is unsupported unless you seek external funding. Committing unpaid effort in the summer is a violation of labor laws. In addition, there is no auditable way to track the unpaid committed effort without a payroll charge to an account code which will in turn flow through to the effort reporting system. Time and effort tracking and reporting has been the focus of many investigations by the Office of Inspector General (OIG’s) across the country and has resulted in some very high-profile publicized fines, penalties, and sometimes debarment to these institutions. The university has done a lot of research at other institutions on this item and our policies are in line with others.
    • An acceptable way to present such a situation would be to state in your proposal the following: Although I am not committing a specified level of effort and not requesting salary support in the summer, I as the PI will ensure the scope and objectives of the work are being met.
  • Why will the university not allow me to show voluntary cost share? To be competitive I must show that I am a good bargain, cost less on my grant and will provide resources to the project so that I have a better chance of receiving funding.
    • Some Federal Agencies prohibit the inclusion of voluntary cost share to level the playing field for all types of applicants and addressed a perceived unfair competitive advantage that larger institutions may have. The restriction of the utilization of non-mandatory cost share has been expanded to all federal agencies as of 12/31/14 as governed by the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR, Chapter I, Chapter II, part 20; The Uniform Guidance).
    • This does not mean that investigators should not devote effort to projects that do not supply salary, nor does it mean that the university should not contribute additional resources toward the project. If there is no mandatory cost share requirement, PIs should instead describe their participation in terms that do not commit the institution to a specific percentage of effort or to specific amounts of other non-salary expenses.
  • What is the difference between waived F&A and unrecovered F&A?
    • Waived F&A – the sponsor allows the inclusion of the federally negotiated rate in the budget however, the university has agreed to include a lower rate to meet a mandatory cost share situation.
    • Unrecovered F&A - A sponsor has a published F&A rate that is lower than our federally negotiated rate. The difference between the two rates is considered unrecovered F&A and can be used to meet mandatory cost share requirements, if allowed by the sponsor.

Link to Forms and Other Resources

Kuali Build Form Repository
OMB Uniform Guidance
5 Day Submission Policy
Proposal Preparation Guide
1998 Cost Share Policy
Fact Sheet
Cost Share Allowable Companion Funds (Controller's Office)
Cost Share Training (Controller's Office)

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UMA Sub-Recipient Commitment Form for FDP Institutions

Distribute this form to participating entities when setting up a subaward/ subcontract/sub-recipient agreement with UMass Amherst when the organization participates in the Federal Demonstration Project. In addition, download the organization's information from the FDP Clearing House and include in the sub-recipient package submitted to OPAS. For all other entities, the standard sub-recipient form must be used. See Subcontracts for additional guidance on required documents.

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Certificate of Confidentiality (CoC)

Notice/Policy:  https://grants.nih.gov/grants/guide/notice-files/NOT-OD-17-109.html

Summary: Effective October 1, 2017 CoCs will be issued automatically for any NIH-funded project using identifiable, sensitive information that was on-going on/after December 13, 2016

  • The CoC will be issued as a term and condition of award
  • There will be no physical certificate issued

To determine if this Policy applies to research conducted or supported by NIH, investigators will need to ask, and answer the following question:

  • Is the activity biomedical, behavioral, clinical, or other research?

If the answer to this question is no, then the activity is not issued a Certificate. If the answer is yes, then investigators will need to answer the following questions:

  • Does the research involve Human Subjects as defined by 45 CFR Part 46?
  • Are you collecting or using biospecimens that are identifiable to an individual as part of the research?
  • If collecting or using biospecimens as part of the research, is there a small risk that some combination of the biospecimen, a request for the biospecimen, and other available data sources could be used to deduce the identity of an individual?
  • Does the research involve the generation of individual level, human genomic data?

If the answer to any one of these questions is yes, then this Policy will apply to the research

Certificate of Confidentiality Assurance Template (required as a part of the CoC application)

https://humansubjects.nih.gov/coc/assurance-template

Suggested Language regarding CoC for Consent Document: (https://humansubjects.nih.gov/coc/suggested-consent-language )

Suggested consent language:

This research is covered by a Certificate of Confidentiality from the National Institutes of Health. The researchers with this Certificate may not disclose or use information, documents, or biospecimens that may identify you in any federal, state, or local civil, criminal, administrative, legislative, or other action, suit, or proceeding, or be used as evidence, for example, if there is a court subpoena, unless you have consented for this use. Information, documents, or biospecimens protected by this Certificate cannot be disclosed to anyone else who is not connected with the research except, if there is a federal, state, or local law that requires disclosure (such as to report child abuse or communicable diseases but not for federal, state, or local civil, criminal, administrative, legislative, or other proceedings, see below); if you have consented to the disclosure, including for your medical treatment; or if it is used for other scientific research, as allowed by federal regulations protecting research subjects. 

[Use the following language as applicable] The Certificate cannot be used to refuse a request for information from personnel of the United States federal or state government agency sponsoring the project that is needed for auditing or program evaluation by [THE AGENCY] which is funding this project or for information that must be disclosed in order to meet the requirements of the federal Food and Drug Administration (FDA).  You should understand that a Certificate of Confidentiality does not prevent you from voluntarily releasing information about yourself or your involvement in this research. If you want your research information released to an insurer, medical care provider, or any other person not connected with the research, you must provide consent to allow the researchers to release it.

[language such as the following should be included if researcher intends to disclose  information covered by a Certificate, such as potential child abuse, or intent to hurt self or others in response to specific federal, state, or local laws.] The Certificate of Confidentiality will not be used to prevent disclosure as required by federal, state, or local law of [list what will be reported, such as child abuse and neglect, or harm to self or others]. 

[language such as the following should be included if researcher intends to disclose information covered by a Certificate, with the consent of research participants.] The Certificate of Confidentiality will not be used to prevent disclosure for any purpose you have consented to in this informed consent document [restate what will be disclosed, such as including research data in the medical record].

** Please note that information listed here is subject to change based on additional guidance by NIH. Please continue to monitor this page for additional/updated guidance from NIH.**

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Single IRB (sIRB) Policy for Multi-site Research

Single IRB Policy: https://grants.nih.gov/grants/guide/notice-files/NOT-OD-16-094.html

Frequently Asked Questions on Use of a Single IRB for Multi-Site Research Costs: https://osp.od.nih.gov/clinical-research/nih-policy-on-the-use-of-a-single-irb-for-multi-site-research-faqs-on-costs/

Frequently Asked Questions on Implementation of the Single IRB Policy: https://osp.od.nih.gov/clinical-research/implementation-of-the-sirb-policy/

For applications with due dates on or after January 25, 2018, and contract solicitations published on or after January 25, 2018, NIH expects that all sites participating in multi-site studies, which involve non-exempt human subjects research funded by the NIH, will use a single Institutional Review Board (sIRB) to conduct the ethical review required for the protection of human subjects.

This policy applies to the domestic sites of NIH-funded multi-site studies where each site will conduct the same protocol involving non-exempt human subjects research. It does not apply to career development, research training or fellowship awards. Implementation of the NIH sIRB policy is expected to reduce unnecessary administrative burdens and systemic inefficiencies while maintaining appropriate human subjects protections.

Applicants will be expected to include a plan for the use of a sIRB in the grant applications and contract proposals they submit to the NIH (for due dates on or after January 25, 2018).

The NIH single IRB policy applies to the domestic sites of NIH-funded multi-site studies where each site will conduct the same protocol involving non-exempt human subjects research, whether supported through grants, cooperative agreements, contracts, or the NIH Intramural Research Program.

The NIH single IRB policy does not apply to studies conducted under career development, research training or fellowship awards. Under the policy, “multi-site” is defined as two or more sites. Foreign sites participating in NIH- funded, multi-site studies will not be expected to follow this policy.

The NIH single IRB policy applies to multi-site human subjects research regardless of the funding mechanism (e.g., grants, cooperative agreements, contracts or other mechanisms such as Cooperative Research and Development Agreements (CRADAs), and Interagency Agreements (IAA)). The policy applies whether the sites are subawards to a primary award recipient or separate awards are made for participating sites. The NIH Single IRB policy does not apply to Other Transaction Agreements (OTAs).

** Please note that information listed here is subject to change based on additional guidance by NIH. Please continue to monitor this page for additional/updated guidance from NIH.**

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Please remember to download the expanded guidance document linked on the right side of this webpage. The expanded guidance document outlines the following items:

NIH Revisions to the Policies on Definition of a Clinical Trial 

  1. Revised NIH Definition of Clinical Trial
  2. Determination If Your Human Subject’s Research Study Meets the Revised NIH Definition of a Clinical Trial?
  3. Good Clinical Practice (GCP) Training
  4. Data and Safety Monitoring of Clinical Trials
  5. Dissemination of NIH-Funded Clinical Trial Information

** Please note that information listed here is subject to change based on additional guidance by NIH. Please continue to monitor this page for additional/updated guidance from NIH.**

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Policy on requests for letters of support to the Chancellor, Provost, and Vice Chancellor for Research and Engagement

RE: Policy on requests for letters of support to the Chancellor, Provost, and Vice Chancellor for Research and Engagement

This memo outlines a new policy for faculty requesting letters of support on proposals that do not involve formal resource commitments or cost sharing (If resource commitments are required, please refer to our cost sharing policies here or write to vcre@umass.edu for more information).

For letters of support for fellowships and sponsored research grants, please submit requests with a draft letter at least 5 business days prior to the day it is due to the Office of Pre-Award Services (OPAS) for their review.  This will allow the necessary time needed to evaluate, ask for additional information, edit, and return the signed letter. All requests should include a scope of work and endorsement of the unit’s Associate Dean for Research or equivalent. We will not be able to sign support letters if the above criteria are not met.

Please send all requests for the Chancellor and VCRE to vcre@umass.edu. All requests to the Provost should be sent to provost@provost.umass.edu.

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