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Many questions have surfaced recently concerning investigators collaborating in research, but not seeking salary support
for their effort. The purpose of this document is to clarify the issues raised and put them in perspective in terms of current federal regulations and OHSU policy.
It is well understood that when an OHSU investigator proposes to collaborate with an OHSU colleague in a grant application, the
advance consent of the colleague is required both for the collaboration and for the level of effort that he or she is expected to
contribute to the project. This effort, stated as a percentage of the investigator’s time, is a real commitment. As long as
the application is still active, the collaborating investigator must keep track of the commitment and is required to account
for it, with full grant details, whenever asked by a sponsor to report on his or her pending research support.
When the application is awarded, this committed effort must be tracked by the investigator as a part of his or her active support and
by the university, which has a responsibility to ensure that the effort and the salary charged to support it are in agreement. The
federal government holds the university responsible for complete and accurate effort reporting and for seeing to it that each
investigator’s complement of support accurately reflects their actual programmatic activities. Organizations
that fail to do so are subject to heavy fines and sanctions that inhibit their ability to receive federal funds for research.
Cost sharing is another aspect of research support that OHSU is required to account for by federal regulation. This is the portion
of the budgeted costs of a sponsored project that is not borne by its sponsor. Most often these costs are supported by the university
itself in the form of in-kind contributions of personnel time, space, equipment use, and services. Sometimes the university’s
accounting of cost sharing is used to satisfy a mandatory matching requirement. But whether the cost sharing is mandatory or voluntary,
if it is committed in advance, its source, quantity, and nature must be reported and accounted for to the federal government.
Whenever effort is proposed on an application without a request for salary support, this constitutes committed cost sharing. Given that
this cost sharing must be accounted for, such proposed effort requires more than just the consent of the person whose effort is being
committed. If the effort is not to be supported by the grant, it will need to be supported by another source and the person or persons
who are responsible for that source need to approve the proposed use of their resources. This approval needs to be obtained whether
the employee committing unsupported effort is in the department of the principal investigator or is a member of another department.
RSO relies on information provided in answers to Question 12 of the Proposed Project Questionnaire to monitor departmental approvals for
cost sharing. Previously, Question 12 asked for the account number to which the cost sharing was to be charged once an award is made.
But recent suggestions from investigators and department administrators have prompted a change in procedure. Because the appropriate
account numbers may not be available at the pre-award stage, they will no longer be required on the PPQ. Question 12 now asks for the
signatures of department administrators with budgetary responsibility for cost sharing committed on the application. See the
RDA Forms page for the updated PPQ.
At the time the grant is funded, RSO will contact the relevant department administrators to obtain the account numbers to which
cost-shared effort will be charged. This information is provided to Sponsored Projects Administration (SPA) when the grant award material
is forwarded for account set up. SPA then handles the charges for this time, the post-award tracking of the investigator’s effort,
and accounts for the cost sharing information that is reported to the federal government.
If the application commits the effort of an outside investigator and that effort is not to be funded by the grant, these details must
be acknowledged in the collaborator’s letter of support. For the strength of the application, it is advised, but not required,
that this letter be co-signed by the collaborator’s institutional official.
It is worth noting that, in the accounting process, committed cost sharing reduces the university’s ability to recover its full
indirect costs. So unless the cost sharing is mandatory, these are costs that have a negative fiscal impact twice, once when the
university uses internal resources for purposes that could be supported externally and again when we experience
a shortfall in the recovery of facilities and administration expenses.
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