Cost Sharing Policy and Procedure Updates and Overview

Cost Sharing Policy and Procedure Updates and Overview Harvard Medical School Open Forum June 9, 2017 Marc Todesco Portfolio Manager Office for Sponsored Programs

General Definition Updated University Cost Sharing Policy Effective July 1, 2017 Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the federal or non-federal sponsored award. Sponsor $ $ Project

Uniform Guidance 200. 29 • “Cost sharing or matching means the portion of project costs not paid by Federal funds” 200. 306 • “Under Federal research proposals, voluntary committed cost sharing is not expected” Appendix I, C. 2. • “Required cost sharing must be indicated in Notice of Funding Opportunity” 3

Harvard Policy “Harvard strongly discourages cost sharing, unless such a commitment is required by the sponsor”

Types of Cost Sharing • Included in the proposal Mandatory Committed Cost Sharing • Required by the sponsor as a condition of the award • Must be tracked in GMAS and may require reporting • Pledged on a voluntary basis in the proposal's budget and/or narrative Voluntary Committed Cost Sharing • Binding requirement of the award • Must be tracked in GMAS and may require reporting

Types of Cost Sharing Voluntary Uncommitted Cost Sharing • Costs and effort that are not included as part of the submitted proposal or upon acceptance of the award • Does not need to be tracked or reported • Portion of salary and fringe that exceeds regulatory maximum imposed by the sponsor Over-the-Cap Salary • Cannot be used to meet a mandatory or voluntary committed cost sharing requirement • Considered an unallowable cost to the sponsor • Tracked via companion account for effort reporting

Types of Cost Sharing • Non-cash contribution of goods and services from the University or donations from third parties In-Kind • Volunteer services or donated equipment at fair market value • Must be tracked manually at the department/local unit managing the award

Recording and Tracking Cost Sharing Commitments at HMS Committed cost sharing must be recorded in GMAS at the proposal stage* HMS will no longer use the paper Cost Sharing Form Update cost sharing budgets and account strings in GMAS Add Rita Bergemann as the Cost Share Signatory to obtain approval Cost sharing expenditures must be allowable per the sponsor’s terms Must be tracked and updated throughout the award lifecycle * NOTE: Proposals which include cost sharing of any type are not part of the Efficiency Project (EP) list, and must be reviewed and authorized for submission by SPA

Tracking Cost Sharing Commitments in the GL and GMAS Utilize companion accounts Using a Non-Sponsored Fund with a Sponsored “Activity. Subactivity” SPONSORED ACCOUNT STRING Tub Org Object Code Sponsored Fund Sponsored Activity Sub. Activity 123456 0101 Root COMPANION ACCOUNT STRING Tub Org Object Code NON Sponsored Fund Root

Monitoring Cost Sharing Commitments Conduct regular reviews and reconciliations Ensure committed cost sharing expenses are posted to the applicable cost sharing account strings (companion accounts) Track and document any non-federal or in-kind contributions Reportable cost sharing on subawards Obtain reports from subawardee to confirm cost sharing commitment Provide OSP with supporting documentation when requested

Record Retention of Cost Sharing Commitments Uniform Guidance 200. 306 Cost sharing must be verifiable from the recipient’s records All allowable cost sharing expenditures are considered costs associated with a sponsored project and subject to audit All cost sharing supporting documentation must be retained and uploaded to GMAS Cost sharing transactions not posted to a companion account Reported In-Kind subaward cost sharing contribution detail

FY 16 Cost Sharing at HMS GL: Companion Account Transactions 360 Awards with Transactions in GL Totalling $4 M $17 M in Cost Sharing Expenses Over-the-Cap Salary $13 M is Non-Salary Mostly associated with one CTSA

Reminders on Key Updates “Harvard strongly discourages cost sharing, unless such a commitment is required by the sponsor” Cost sharing is not to be used as a factor in the review of applications or proposals or as merit criteria Committed cost sharing must be recorded in GMAS at the proposal stage and tracked throughout the award lifecycle HMS will no longer use the paper Cost Sharing Form Utilize Companion Accounts to track Cost Sharing

Resources & Support Online Content and Job Aids Cost Sharing Policy Cost Sharing FAQs Cost Sharing Online Training Cost Sharing Procedure Guide Recording Cost Sharing Commitment in GMAS Job Aid Companion Account Tracking Job Aid Contacts Rita Bergemann, HMS Director of Research, Finance, and Policy Compliance rita_bergemann@hms. harvard. edu Training June 12, 2017 9: 30 -11: 30 am at Lamont Library Forum Room, Cambridge

Questions?