The National Science Foundation (NSF) has changed its cost sharing policy effective with proposals submitted on or after January 18, 2011. NSF no longer allows voluntary committed cost sharing unless specifically required by a program solicitation. However, despite the NSF proposal process change, the University must still calculate and track cost shared principal investigator for effort certification and inclusion in the F&A base calculation.
The following guidelines and examples are provided to ensure UA maintain compliance with both the NSF cost sharing policy and the OMB Clarification memorandum. The OMB Clarification memorandum is the Federal policy that requires some level of faculty (or senior researcher) effort on most Federally-funded research programs. This effort must be tracked and certified, and then used in the calculation of the institutional F&A rate. Please also see the NSF’s Frequently Asked Questions (FAQs) on the revised cost sharing policy.
Example 1: No salary support requested
The PI is submitting a NSF proposal and does not want to request salary support from NSF.
The PI should list zero person-months and $0 salary on the budget page. Listing quantified person months and 0$ salary is an example of voluntary committed cost share, and is no longer allowed. The PI’s contribution to the project should be described in the Facilities, Equipment and Other Resources section. The description should be narrative in nature and must not include any quantifiable financial information. Do not include a description of the PI’s contribution in the budget justification or project description. The person-months should be listed on the Current and Pending support page, an equivalent effort percentage should be listed in the internal UAccess Research (UAR) proposal document, and the cost share committment should be included in the UAR proposal budget distribution and income tab. During postaward monitoring, the actual effort devoted to the project should be tracked and certified in the UAccess Financials effort and cost share system.
Example 2: Requesting additional salary support
A Principal Investigator (PI) has an existing NSF program that funds two months of her salary. The PI is submitting an additional NSF proposal and will request additional salary support from NSF.
The PI should list the person-months and salary on the budget page. The budget justification should include a description of the PI’s commitment and why support greater than two months is needed. The person-months should be listed on the Current and Pending support page and an equivalent effort should be listed in UAccess Research. During postaward monitoring, the actual effort devoted to the project should be tracked and certified in the UAccess Financials effort and cost share system.
Example 3: Doctoral dissertation or fellowship proposal
The faculty advisor should be listed as the Principal Investigator on the cover sheet and budget with zero person-months and $0 salary. The student should be listed on the cover sheet but will need to be removed from the budget. The Facilities, Equipment, and Other Resources section should include a non-quantifiable description of the contribution by the faculty advisor and student. The person-months should be zero on the Current and Pending Support section for the faculty advisor and estimated for the student. The effort in UAccess Research should be equivalent to the Current and Pending Support section for both the faculty advisor and student. In postaward monitoring, faculty advising effort for a doctoral dissertation or fellowship project generally does not need to be tracked and certified in the Financial system, according to the OMB Clarification memorandum