Cost Sharing Restriction: Cost sharing as a whole is being restricted as of July 1, 2015
Go here for further information 04-40-001.200 - Cost Sharing on Sponsored Projects
As of July 1, 2015 there are two requirements for cost sharing at OHSU. Please refer to the Cost Sharing on Sponsored Projects Procedure/Guideline for full details.
1. All new proposals submitted through OPAM may not include any voluntary committed cost sharing. Only mandatory cost sharing or cost sharing explicitly stated in the funding opportunity as a factor of review of the proposal will be allowed.
a. Exceptions: F&A waivers, and effort commitments of salaries supported by outside entities.
2. All NEW awards (including competing segments) will require the use of an OGA Cost Sharing project for any cost sharing committed in the proposal.
a. All non-competing years for an A-year award issued prior to 7-1-15 do not require a cost share projects
b. If cost sharing was previously tracked on the GL a cost share project does not need to be set up, since
it qualified under a. above.
For some of the reasons why cost sharing is being restricted see below:
- Negative impact on OHSU's F&A rate. Cost sharing commitments are required to be included in OHSU's direct cost base when developing Facilities and Administrative (F&A) rates with the government. This lowers OHSU's F&A rate and also reduces OHSU's F&A cost recovery.
- Federal Regulation Regarding Cost Sharing Use - The Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (2CFR200) require that Funding Opportunity Announcements (FOA) state whether there is mandatory cost sharing, matching, or cost participation without which an application would be ineligible. If cost sharing is not required, the announcement must explicitly say so ~ 2 CFR 200.Appendix I C.2. In addition, voluntary committed cost sharing cannot be used as a factor during the merit review of applications or proposals unless it is specified in a notice of funding opportunity. Criteria for considering voluntary committed cost sharing as a factor to determine who may receive a Federal award must be explicitly described in the notice of funding opportunity. ~ 2 CFR 200.306
- Fiduciary Responsibility - Once cost sharing is committed in a sponsored project, OHSU is legally bound to provide that cost sharing, as well as provide the same fiduciary responsibilities in expending and accounting for those commitments, as is done for sponsored project funds.
- Change in Federal Climate Towards Cost Sharing: Federal Agency's (including NIH) are moving away from allowing or even permitting voluntary cost sharing on applications unless mandated in the program announcement.