Does this policy cover Multiple-Principal Investigators and Co-Principal Investigators?
Yes. However, it does not apply to Co-Investigators and other senior project roles.
What do our peers do?
Other universities have implemented similar policies to achieve these goals, for example:
Who is affected?
Researchers in the following situations are potentially affected.
What are the key components of the policy?
A key requirement of the new policy is that payroll records (for those paid on sponsored funds) must reflect the effort actually spent on sponsored projects during the pay period. Faculty and research staff salary that is paid from sponsored projects should correspond to work that they do, during the period that they actually do it.
If I include or increase effort in my NIH Just in Time (JIT) budget, is it considered committed cost share?
If you make a budget change at JIT to include or increase effort, it may be considered voluntary committed cost share and could become a binding requirement of the award.
My award does not reference the cost share commitment in the budget/budget justification, does it need to be tracked?
Yes. Upon receipt of an award based on a proposal that included voluntary cost sharing in the budget or budget justification (whether or not the agency explicitly calls out the cost sharing), the cost sharing becomes "committed" and an obligation that is subject to audit and must be fulfilled.
Do any sponsors or programs prohibit voluntary committed cost share?
Yes. For example, as a policy, the National Science Foundation (NSF) prohibits Voluntary Committed Cost Sharing. NSF policy further states that resources not included in the Budget or Budget Justification should be listed in the Facilities, Equipment, and Other Resources section, but should not contain “quantifiable financial information” for those resources.
Does Voluntary Committed Cost Sharing include commitments in the proposal’s budget justification?
Yes. The budget justification is treated the same as the budget in this definition.
Why is the university concerned with excessive cost share?
The university is required to provide the stated resources that are committed as Cost Sharing in a proposal, whether the commitment of resources is Mandatory Committed Cost Sharing or Voluntary Committed Cost Sharing. Excessive or unnecessary cost share limits the university’s capacity to commit resources when required for eligibility of submission, increases our administrative burden, and reduces the availability of resources for other purposes.
Are there limits to what I can propose as Cost Sharing?
Given that Cost Sharing frequently involves the use of departmental or college resources, Unit Executive Officers, deans or institute directors may impose limits on the contributed amount of Cost Sharing.