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/
>
>
>
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--
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

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