Academic journal article Journal of Research Administration

Ask an Expert: Tips and Tools of the Trade, Series 2

Academic journal article Journal of Research Administration

Ask an Expert: Tips and Tools of the Trade, Series 2

Article excerpt

I. Cost Shore Planning

Q: How do you plan cost share?

A: Carefully and completely! First, is cost sharing necessary? A Pi's desire to "sweeten the pot" seldom gives a proposal an advantage. No cost sharing should be included on a for-profit sponsored project. Meeting "Mandatory Cost Sharing" is necessary for the proposal to be considered for review; federal project announcements will specify if there is Mandatory Cost Sharing. For federal awards with Mandatory Cost Sharing a record of the cost sharing must be kept and the cost sharing must be reported as part of the project financial report.

"Voluntary Committed Cost Sharing" (VCCS) is cost sharing written into the proposal when it is not required and should be clearly stated in the budget. A promise made in the proposal text is just as binding as an item in the budget. VCCS also must be recorded. At post award, it is not counted in the project financial report, but it is entered into the cost sharing pools when computing FScA under long form. Salaries paid above a sponsor's cap (e.g., NIH cap on rate of reimbursement for salaries) are VCCS, but are often accounted differently from other VCCS for administrative convenience. Cost sharing is usually accompushed with faculty time and benefits and related F&A. Remember, you don't record FScA on cost shared items, but it is a real cost buried in your accounts, so you can impute it.

You can include other costs as cost sharing. Faculty time is usually easiest to account; others may require special record keeping. You can cost share with uncollected F&A, but be sure that is within institutional policy. You cannot cost share with space if you charge on-campus F&A. You can use the difference between your on- and off-campus F&A rate to account for space cost shared on campus, if the sponsor needs that part of foregone F&A separately documented. If the work is off-campus, you may be able to count third party provided space; be sure to document the value carefully. You can count a closely related non-federal award as cost sharing for a federal award-and vice versa, but it's not usually needed. You can count third party cost sharing, but carefully, usually when the third party is a subawardee and the requirement for documenting the cost sharing is written into the subaward agreement.

2. "Cash" vs. "In-Kind" Cost Sharing

Q: My PI wants to propose "in-kind" cost sharing; how do I handle this?

A: "Cash" and "in-kind" have a very precise meaning for cost sharing: "cash" cost sharing can be documented in the cost sharer's books with an exact value, whereas "inkind" cost sharing is the value of donated goods and services. OMB Circular A-110 specifies how to evaluate in-kind cost sharing. For example, the cost sharing value of 50 hours of carpentry is that of a carpenter on the local market even if a brain surgeon does the work. Although many people use the term in-kind to refer to any cost sharing, research administrators should use these precise meanings to know what records are needed for audit.

3. Export Controls: ITAR, EAR, and OFAC

Q: What should I know about the export regulations ITAR and EAR?

A: ITAR, EAR, and OFAC are the law of the land. Each institution should have a policy statement and a knowledgeable empowered official. The U.S. Department of Commerce regulates certain dual-use technologies by the Export Administration Regulations (EAR). The U.S. Department of State controls the export of defense articles, defense services, and defense related technical data through the International Traffic in Arms Regulation (ITAR). The Treasury Department's Office of Foreign Assets Controls (OFAC) limits "foreign" payments.

Under ITAR and EAR, the institution, and each employee personally, is responsible for safeguarding sensitive and export-controlled objects, data, and information from disclosure to foreign persons without prior approval. …

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