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Re: cost-sharing question Victoria Jensen 10 Nov 2008 12:45 EST

Dear Peg and Kristy,

I looked this up last year, because I was also thinking that even if the
effort is not in the budget (as requested or in-kind), the PI still is
indeed spending time administering the grant.  However, I found that the OMB
guidelines on "voluntary uncommitted cost-share" state that you do NOT have
to track this effort.

The pertinent OMB clarification is located here:
http://www.whitehouse.gov/omb/memoranda/m01-06.html

"Clarification. Voluntary uncommitted cost sharing should be treated
differently from committed effort and should not be included in the
organized research base for computing the F&A rate or reflected in any
allocation of F&A costs. Furthermore, such faculty effort is excluded from
the effort reporting requirement in section J.8. This treatment is
consistent with the guidance in section J.8.b (1).c, "Payroll Distribution,"
that a precise documentation of faculty effort is not always feasible, nor
is it expected, because of the inextricably intermingled functions performed
by the faculty in an academic setting (i.e., teaching, research, service and
administration). "

Best regards,

Vicky Jensen
Interim Director, Office of Research and Sponsored Programs
California State University, East Bay

On 11/10/08 7:19 AM, "Vigiolto, Margaret" <xxxxxx@DREXEL.EDU> wrote:

> Hi Kristy,
>
> In the situation you describe, there is an implicit commitment. I agree
> with your logic. Drexel University requires a reasonable estimate of
> effort to be recorded in the payroll distribution system.
>
> Peg Vigiolto
> Associate Vice Provost
> Office of Research
> Drexel University
> 3201 Arch Street, Suite 100
> 215.895.2311 phone
> 215.895.6699 fax
> xxxxxx@drexel.edu
>
> -----Original Message-----
> From: Research Administration List [mailto:xxxxxx@hrinet.org] On
> Behalf Of Kristy Ford
> Sent: Monday, November 10, 2008 9:56 AM
> To: xxxxxx@hrinet.org
> Subject: [RESADM-L] cost-sharing question
>
> Hello all!  I could not find this detail in the regulations, unless I'm
> missing something somewhere.  So, I am interested in knowing how your
> institutions handle situations involving uncommitted effort.  Some
> agencies still do not require that a PI commit a certain amount of
> effort to a project, even though, as a PI, he/she is obviously going to
> spend time on it.  Therefore, the proposal and budget does not request
> reimbursement towards the PI salary/fringe and does not specify a
> percentage of time committed to the project.  The budget also does not
> include a portion of the PI salary/fringe in the match either.  Do you
> require that the PI verify his/her time and effort (as an in-kind
> contribution) on a project in this situation?  I'm inclined to say
> "yes," because obviously he/she has to spend time on the project as the
> PI.  Even if it isn't stated in the proposal or budget, time is
> committed by virtue of being the PI.  The PI must, then, verify his/her
> effort on this projec!
>  t after it is awarded, how ever much it may truly be.  Am I correct in
> my thinking?
>
> I know this was discussed before, but I could not find the e-mails.
> More than anything, I want to know that I am correct in my thinking
> before telling people they cannot apply for more grants when they have
> no time available for more projects.
>
> Thanks!
> Kristy
>
> Kristy Ford
> Grant Management Manager
> Financial Reporting Administration
> Memorial University Medical Center
> Savannah, GA  31404
> (912)350-6379
>
>
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