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The Office of the Comptroller

To: Deans, Chairs, Directors, and Officers
Date: June 20, 2003
From: Keith Moffat, Deputy Provost for Research
Subject: Clarification of OMB A-21 Treatment of Voluntary Cost Sharing on Federal Research Projects

Please share this letter with all principal investigators and all other individuals in your unit who are involved with the preparation of proposal budgets

On January 5, 2001, the Office of Management and Budget published a clarification on the treatment of voluntary cost sharing that specifically dealt with faculty effort on federal research projects. We had hopes that the clarification would not require additional campus record keeping and therefore delayed implementing stricter effort commitment and reporting practices. However, it is now clear that the University must put systems in place that track certain "voluntary" commitments. This memo explains the impact of the new clarification on investigator effort and provides general University guidelines for committing and documenting voluntary effort on federal research proposals.

OMB uses a number of terms that may not be familiar to academic administrators. To make this arcane subject somewhat more understandable, we define them here.

  • Cost Sharing: sponsored award costs born by the University
  • Mandatory Cost Sharing: that cost sharing required by the sponsor as a condition of award (Example - NSF requirement that applicant provide 30% cost share on Science & Technology Center applications). Mandatory cost sharing is stated in the award notice.
  • Voluntary Committed Cost Sharing: University-paid cost sharing committed voluntarily in the proposal budget or anywhere else in the application, such as in the Current & Pending Support documents. (Example - Commitment by PI to spend 15% of effort during the academic year, when the University pays compensation.)
  • Voluntary Uncommitted Cost Sharing: cost sharing that is over and above any amounts or commitments of effort identified as mandatory or voluntary in the application. (Example - faculty-donated time above that identified in the application, often informally referred to as "nights and weekends.")
  • Faculty Effort - the % of time spent on a research project, paid by the sponsor or paid by the University.

When mandatory or voluntary committed cost sharing involves effort commitments of faculty or researchers, these obligations are part of the conditions of the award and must be properly documented in University's effort reporting and accounting systems. This is true even if the voluntary committed cost sharing is not spelled out on the Budget or Budget Justification pages, but is identified as effort on the project on a Current or Pending Support Page, or elsewhere in the application. The OMB clarification states that only voluntary uncommitted cost sharing is free from an institutional record-keeping obligation. Currently the University's effort reporting system captures only mandatory cost sharing. Changes are being implemented so that beginning July 1 2003, all voluntary committed cost sharing on new awards will be identified and tracked.

OMB's clarifications will impact how we propose and account for faculty effort. Sponsor-paid effort in the proposal budget has always been identified and then accounted for in the University's effort reporting system. Now because of OMB's clarifications, the voluntary committed effort contained in the proposal budget must also be identified and then accounted for in the effort reporting system.

Because there are burdensome effort reporting and accounting requirements implicit when voluntary effort moves from uncommitted to committed, we suggest certain general practices.

  1. In general, proposals should request the sponsor to fund committed faculty effort. Additional faculty effort may be committed and formally documented by the University when necessary to meet mandatory cost sharing requirements. Although additional faculty effort beyond that funded by the sponsor or used to meet mandatory cost sharing requirements is not prohibited by the University, it should not be described anywhere in the proposal.
  2. For faculty with 9-month appointments, faculty time and effort for which funding is requested is usually summer effort. Where greater commitments of effort are necessary for a project, a proportional increase of sponsor-funded effort should be requested.
  3. In those cases where no federal funds are requested for faculty research effort, the Principal Investigator is expected to commit some modest voluntary effort. To meet the government requirement that research projects must have some Principal Investigator effort, 0.5 months of effort would represent a typical voluntary commitment and should be so indicated in the proposal. Excessive voluntary commitments of University-paid effort should be avoided.
  4. Some types of federal research programs such as programs for equipment, instrumentation, doctoral dissertations, and student augmentation, do not require any committed faculty effort, whether paid or unpaid by the government.

Questions may be directed in the first instance to Mary Ellen Sheridan, University Research Administration.

Specific instructions for unit administrators on how to implement the OMB A-21 clarification, from the proposal stage through award management, will be forthcoming immediately from URA and the Comptroller's office.