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COVID-19: Information from SPA/OSP/CGA

NSF Cost Sharing Policy

  • NSF 2013 Cost Share FAQs http://www.nsf.gov/pubs/policydocs/csfaqs_jan13.pdf
  • Mandatory programmatic cost sharing will rarely be approved for an NSF program.
  • Inclusion of voluntary committed cost sharing (see MSU definition) is prohibited in solicited and unsolicited proposals (unless required in the solicitation).
  • Organizations may, at their own discretion, continue to contribute any amount of voluntary uncommitted cost sharing to NSF-sponsored projects.
  • NSF Program Officers may discuss the "bottom line" award amount with Principal Investigators, but may not renegotiate or impose cost sharing or other organizational commitments.
  • NSF Program Officers may not impose or encourage programmatic cost sharing requirements.
  • Violations to the revised cost share policy may cause a proposal to be returned without review or declined.

Can senior project personnel (including the PI and any co-PIs) donate time to the project and not request salary support?

The NSF Grant Proposal Guide (GPG) is very clear that inclusion of voluntary committed cost sharing is prohibited in NSF proposals (unless specifically required by a program solicitation).

  • Chapter II.C.2.i of the GPG directs proposers to include:
    • An aggregated description of the resources that the organization and its collaborators will provide to the project, should it be funded.
    • Such information must be provided in the Facilities, Equipment and Other Resources section, in lieu of other parts of the proposal such as the budget justification or project description.
      • The aggregate description should be narrative in nature and must not include any quantifiable financial information.
      • Reviewers will be directed to the Facilities section of the proposal and will be asked to evaluate the information during the merit review process.

How should this be reflected on the budget?

Specifying person-months on the budget form and leaving the salary input box at $0 would constitute prohibited voluntary committed cost sharing and therefore could result in the proposal being returned without review.  In these situations, please use the following guidelines:

  • The lead PI's name is pre-populated on the NSF budget form form the NSF Cover Sheet form and cannot be removed from the budget form.  Therefore, if person-months are listed, the equal amount of salary support must be included on the budget form so as to be compliant with NSF's policies.  Otherwise, the person-months must be removed from the budget form.
  • Co-PIs names must be removed from the NSF budget. This can be done by clicking on the co-PIs name in the NSF budget format and then clicking ‘Check to remove’.
  • A biographical sketch and Current and Pending Support information are still required for them.  Their name(s) will remain on the Cover Sheet and the individual(s) role on the project should be described in the Facilities, Equipment and other Resources section of the proposal.

How does this affect the Current & Pending forms?

NSF does not consider the current and pending support section to be an auditable document. The purpose of the current and pending support section is to assess possible PI and other senior personnel commitments and get a general sense of what other projects require a portion of their time. The section may include everything from planned, to pending, to current projects and NSF uses it strictly for informational purposes. Current and pending support is not part of the budget and so does not meet the definition of cost sharing in 2 CFR § 215.23. Therefore NSF would not consider effort shown on the current and pending support section to be voluntary committed cost sharing.

  • However, for NSF proposals, MSU requires that any unbudgeted cost sharing effort listed in the current and pending form be noted on the Custom Data tab of the Proposal Development document and approved by the department and college.

How does MSU handle proposals requesting no effort or salary on the budget?

MSU understands that should an award be made, it will be subject to federal provisions which require ‘some level’ of faculty (or senior researcher) effort to be committed and tracked as part of the organized research base (see MSU cost sharing requirements faqs).

These questions are from the FAQs posted on the NSF’s website: http://www.nsf.gov/publications/pub_summ.jsp?ods_key=costsharefaqs . Additional information on the NSF cost sharing policy can be found in Chapter II.C.2.g(xi) of the Grant Proposal Guide in the NSF Proposal & Award Policies & Procedures Guide.

General References

 

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