Rick,

Once the cost sharing is "offered up", it must be documented.  Also, you
need to ensure that they are not using the same cost sharing again.  I
will defer to someone who is an expert regarding the F & A implications.

Sandra M. Nordahl, CRA
Manager, Sponsored Research Administration
San Diego State University Foundation
5250 Campanile Drive
San Diego, CA  92182-1934
619.594.4172 (voice)
619.582.9164 (fax)
e-mail:  xxxxxx@foundation.sdsu.edu

-----Original Message-----
From: Research Administration List [mailto:xxxxxx@HRINET.ORG] On
Behalf Of Smiley, Rick
Sent: Thursday, December 02, 2004 7:58 AM
To: xxxxxx@HRINET.ORG
Subject: [RESADM-L] HRSA Training Grants & Cost Sharing

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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