Labor Cost Sharing From Start to Finish

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Labor Cost Sharing ---From Start to Finish

• Kevin McKoskey
• Steve Bradley
• Office of Sponsored Projects Administrations (SPA)

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Agenda

• Definitions
• Fed Regs (A-110)
• Mandatory vs. Voluntary
• Committed vs. Uncommitted
• SPA Grant Administrator (GA) processing
• Proposals Awards
• Labor C/S on Effort Statements
• Impact on Fac. Admin. (FA) Rates
• Compliance Monitoring
• Resources

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Definitions A-110

• Portion of project/program costs not borne by
  the Federal Government (i.e., must be paid from
  institutional, non-sponsored accounts)
• Verifiable from recipient's records
• Not included as contribution for any other
  federal project
• Necessary and reasonable for project
• Allowable under applicable cost principles (i.e.,
  A-21)
• Not paid by Fed Govt under another Award
• Provided in approved budget (when required by Fed
  sponsor)

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Definitions U Policy

• Mandatory Sponsor-driven, required by sponsor
  as condition for proposal submission
• Voluntary Investigator-driven, not required by
  sponsor as condition for proposal submission
• Committed Mandatory or Voluntary C/S pledged in
  proposal budget, budget justification or stated
  in award documents
• Uncommitted Voluntary C/S not pledged in
  proposal and not in award documents
• Above that agreed to as part of award
• Referred to as Voluntary Uncommitted C/S
• Does not have to documented or reported (i.e., in
  Effort system)

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SPA GA Processing at time of Proposal

• Verify C/S has been approved by Dept Head and
  Dean
• Via PRF sign-off
• Verify listed C/S meets sponsor requirements, if
  program announcement indicates C/S in required
  (i.e., Mandatory)

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SPA GA Processing at time of Award

• Review proposal budgets, budget justifications
  and award documents for C/S
• Confirm Committed C/S is documented on the Notice
  of Grant Award (NOGA)

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Labor C/S on Effort Statements

• SPA Effort Unit
• Takes C/S from Award/NOGA by Budget Period
• Inputs to SPA C/S file
• From non-sponsored account deduced via payroll
• NOGA does not show this
• To sponsored account from NOGA
• Pre-prints To From s on quarterly Eff
  Stmts

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Labor C/S on Eff Stmts (cont.)

• Example NOGA states ---
• Prof. Jones cost sharing 5
• from non-sponsored 1003-000-1234
• to sponsored 1999-000-6999
• Effort Statement for FY2004 Qtr 1
• Payroll C/S
  Effort
• 1003-000-1234 10 -5
  5
• 1999-000-6999 90 5 95

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Changes to Labor Cost Sharing

• Generally, C/S to sponsored account is set for
  a Budget Period
• Reduction in time gt 25 for PI/Key personnel
  require federal sponsor approval (see A-110,
  agency policies)
• Changing the non-sponsored from account
• Per U Policy
• Depts send letter/e-mail to SPA Effort unit staff
• SPA will change on C/S database for pre-printing
  on future Eff Stmts

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C/S Impact on FA Rate Proposal

• Per A-21, Labor C/S benefits Research Mission
• Must add to FA rate RES base
• Denominator in rate calculation
• 14M in last FY98 proposal (8 of total 190M
  base)
• Tendency to reduce proposed FA rate
• Reduced last proposal by estimated 1-2 (vs.
  current 48.5)
• NOTE Impact is from unnecessary Voluntary C/S
• Must honor Mandatory C/S

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Compliance Monitoring

• U C/S Policy Roles Responsibilities
• PI and Depts must ensure requirements are met
• Internal Audit
• OAR
• Recent Federal audits
• NSF
• Ofc. Of Inspector Gen. (OIG) Reviews at 8 Us
• Lack of proper accounting, lack of
  Policies/procedures and failure to meet committed
  C/S levels
• HHS / NWU 5.5M False Claims Act (FCA) penalty
• C/S part of condition

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Resources

• A-110 (section 23)
• http//www.whitehouse.gov/omb/circulars/a110/a110.
  html
• U C/S Policy
• http//www.fpd.finop.umn.edu/groups/ppd/documents/
  policy/cost_sharing.cfm
• Agency specific
• NSF Grnts. Pol. Man.
• http//www.nsf.gov/pubs/2002/nsf02151/start.htm
• NIH Grnts. Pol. Stmt.
• http//grants.nih.gov/grants/policy/nihgps_2001/in
  dex.htm