Rick, Yes, this is definately an issue at MUSC. HRSA officials (a Senior Program Management Officer) recently told us that we should propose voluntary cost share to show the reviewers our commitment to the project. We cited the June 23, 2003, OMB policy directive (see Federal Register, pages 37369-37379) and explained all the reasons why voluntary cost share should not be encouraged by HRSA: it creates a bidding atmosphere; it adversely affects our F&A rate; it creates an increased workload because the cost share has to be tracked (our Office of Grants and Contracts Accounting does consider voluntary cost share "committed" when it is detailed in the proposal, and requires that it be tracked and documented). The HRSA officials were unfazed by our comments and said they were merely telling us what the reviewers look for. Tony DeCrappeo, the Director of Cost Studies and Policies and Vice President for Business Operations for the Council on Governmental Relations (COGR) has recently e-mailed HRSA to object to its practice. He e-mailed Nancy McGinness, Director of Financial Policy and Oversight at HRSA (xxxxxx@hrsa.hhs.gov). Tony encourages institutions to voice their objections to HRSA's cost share policy by writing Nancy McGinness at HRSA, and also sending copies to Jean Augustine, Director of Audit Resolution and Cost Policy, DHHS (xxxxxx@hhs.gov) and the OMB person named in the Federal Register announcement, Elizabeth Phillips (xxxxxx@omb.eop.gov.) On page 37378 of the OMB directive, Section V.1., third paragraph, it states: "If an applicant's proposed cost sharing will be considered in the review process (as opposed to being an eligibility criterion described in Section III.2), the announcement must specifically address how it will be considered (e.g., to assign a certain number of additional points to applicants who offer cost sharing, or to break ties among applications with equivalent scores after evaluation against all other factors). If cost sharing will not be considered in the evaluation, the announcement should say so, so that there is no ambiguity for potential applicants. Vague statements that cost sharing is encouraged, without clarification as to what that means, are unhelpful to applicants." HRSA is in violation of the OMB directive when it encourages voluntary cost share, but does not specifically address in its program announcement how cost share will be considered. Laurie Smiley, Rick wrote: >I have encountered an issue into which I would like some insight. We >submit training grant proposals to HRSA from the Schools in our Medical >Sciences Division. In these proposals, our PIs regularly include large >amounts of detailed "In-Kind Contributions" in the narrative (mostly the >salaries of teaching and clinical faculty). These add up to large sums - >over $250,000 in the most recent proposal. Our investigators do this in >close consultation with HRSA program officers and feel strongly that >HRSA expects to see this sort of detail in the proposal. It must be >noted that these Schools have been very successful in winning these >grants, so they are clearly doing a great many things right and well. > >The investigators also argue strongly that HRSA does not consider these >representations to constitute committed cost-sharing and note that the >program guidance specifically states that cost-sharing is not required >(they recognize that the latter statement does not prove the former). >Rather, they argue that HRSA wishes to see the level of institutional >resources available to the program, while not requiring they be >dedicated solely to the grant objectives. > >The firm assertions that these resources will be provided, coupled with >the detail in which they are listed, raises a red flag here in OSP - >this seems to us to be indistinguishable from committed cost sharing. >Regardless of what HRSA may think or say, we think an auditor would be >expecting, based upon any number of rationales, effort reporting and >other documentation of the expenditures so boldly detailed in the >proposal. We will skip the implications of this amount of voluntary cost >sharing for our F&A negotiations. > >Our PI notes that she has attempted to raise this issue in off-campus >professional meetings and has found no other University where OSP >considers this an issue (with regard to HRSA training grants). Does >anyone have any insight into this? I am especially interested in anyone >with experience with HRSA training grants specifically. > >Riddick S. Smiley >Grant & Contract Officer >Office of Sponsored Programs >Greenville Centre, Rm 2906 >East Carolina University >Greenville, NC 27858-4353 >(252) 328-9539 office >(252) 328-4363 fax >xxxxxx@mail.ecu.edu >http://www.research2.ecu.edu/osp/ > > > >====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") >====================================================================== > > -- Laurie Chamness Assistant Director Office of Research and Sponsored Programs Medical University of South Carolina PO Box 250808 Charleston, SC 29425 Ph (843) 792-3832 Fax (843) 792-6447 E-Mail: xxxxxx@musc.edu ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
