FAQs - Cost & Cost Share Questions.pdf

Department of Energy/National Nuclear Security Administration (DOE/NNSA)

NOFO DE-FOA-NA0003284

FAQs – Cost & Cost Share Questions

1. Can universities designate part of the nine-month salary also as cost share? Or can only the summer salary be cost shared?

Designation of cost share is determined by the rules governing the institution. How you designate the number of months for salaries on cost share is a decision made by the prime institution. Note that the minimum cost share is 10 percent of the total allowable as per Section III Part D of the NOFO.

2. Can Co-PI salaries be included as cost-share: that is if a co-PI does two months on the PSAAP project, can one be included as cost-share?

Salaries are allowable as cost share. If salaries are used for cost share, time and effort must be documented and the rate of the salary at the time a claim for reimbursement must be part of the documentation. Cost share or "matching" refers to the resources a recipient contributes to the total cost of an agreement. It becomes a condition of an award when it is part of the approved award budget. It is verifiable from the recipient's records, i.e., it CAN be audited. Includes all cash and in-kind contributions from the recipient or third parties and must be allocable, allowable and reasonable. Refer to Section III Part B of the NOFO and ensure that those with the Co-PI title meet the eligibility requirements.

3. The NOFO mentions that every research staff member and postdoc (funded half-time or greater) supported by a PSAAP-IV award will be required to spend one week collaborating with an NNSA National Laboratory. Can you tell me whether the PIs or Co-PIs qualify as "research staff members?"*

Yes, PIs and co-PIs qualify as “research staff members” for the purposes of the annual 1-week visit requirement.

However, as faculty members the majority of their time (typically 9 months) is paid by the university, so they are only funded for 1-3 months per year from the PSAAP grant and thus don’t meet the 50 percent threshold. All Time & Effort must be documented with actual salary costs.

4. Seeking clarification on a sentence in the C. Award Size section (Page 11 and 12 of the DE-FOA-

NA0003284). Does this “total cost” represent DOE Share plus our cost share or does “total cost” mean the total DOE requested funding?

“The ceiling and floor represent the expected range of award sizes and apply to the total costs in the application submitted by the lead institution for multi-institution teams.” An applicant may request up to the ceiling amount of federal funds. According to our guidance, the total amount awarded (direct plus indirect costs) less any applicable recipient cost share constitutes a ceiling on the amount payable to the recipient for a cooperative agreement DEPARTMENT OF ENERGY GUIDE TO FINANCIAL ASSISTANCE (4.4) - Search (bing.com)

5. We have a professor submitting to the DE-FOA-NA0003284 solicitation pre-application. We have a question about the cost share. We have 3 subcontractors on our proposal and wanted to clarify the below.

Does this mean that only the Prime can commit cost share or just that b/c we are where all of the funding will be sent to that the subcontractors can commit cost share as well, but we are responsible for making sure we have the 10% annually and for reporting where it is spent.

This Solicitation requires a 10% cost share amount and that is 10% of the Total Budget Cost (Budget plus cost share amount). The NOFO states that recipients may support research staff, does this include academic year salary for PIs and Co-PIs? Funds that are requested and approved are allowed to be used for federal or cost share. Cost share is required of the prime applicant. Thus, if the PI and Co-PI are approved and are the prime recipient’s staff members then the salary used for them may be utilized as cost share. The Guidelines indicate that a minimum cost sharing of 10% of the total allowable cost of the project (i.e., the sum of the Government share and the recipient share of allowable cost equals the total allowable costs of the projects) must come from non-Federal sources unless otherwise allowed by law. Further, 1) The prime recipient will be required to contribute a minimum of 10% as cost sharing to the DOE/NNSA award on an annual basis; 2) The prime recipient will be required to maintain records of how the cost-

FAQs – Cost & Cost Share Questions share was spent; 3) Program Income funds may be used to meet the cost share requirement. However, costs incurred to generate Program Income may not qualify as cost share; 4) Cost share funds, including any program income, are restricted to the same use of funds as allowed for the federal funds on the award. For example, prime recipients may support research staff, post docs, and students through their 10% cost sharing contribution.

Cost share may be provided by the prime recipient or subrecipients, but the prime recipient is ultimately responsible for all cost share per Section III Part D of the NOFO.

6. Can the funds for DEIA efforts be requested from NNSA, or are those required to be in the form of cost share?

Funds for DEIA efforts be requested can be either from federal or cost share. Every cost share contribution must be allowable under the applicable federal regulations on cost principles. In general, if a cost is allowable under the cost principles applicable to the organization incurring the cost and is eligible under a DOE/NNSA cooperative agreement, then it is allowable as cost share. Conversely, if the cost is not allowable under the cost principles and not eligible for reimbursement, then it is not allowable as cost share. In addition, costs may not be counted as cost share if they are paid by the federal government under another award unless authorized by federal statute to be used for cost sharing. The rules associated with what is allowable as cost share are specific to the type of organization that is receiving funds under the grant or cooperative agreement. Regulations addressing the allowability of cost share, commonly referred to as the cost principles, include:

eCFR :: 2 CFR Part 200 Subpart E -- Cost Principles eCFR :: 2 CFR 200.306 -- Cost sharing or matching eCFR :: 2 CFR 910.130 -- Cost sharing (EPACT) And the Funding Opportunity.

Cost share contributions must be specified in the project budget, verifiable from the prime recipient’s records, and necessary and reasonable for proper and efficient accomplishment of the project. As all sources of cost share are considered part of total project cost, the cost share dollars will be scrutinized under the same federal regulations as the project’s federal dollars. Cost share contribution will be reviewed and approved in advance by the Grants Officer and incorporated into the project budget and award before the expenditures are incurred.

7. Per the Cost Share (Section III – Article D) section on Pg. 15 of the Announcement, (shown below) -- to make sure we interpret details a little differently and want to make sure the proposal pre-application is done correctly. The required 10% Cost Share allows non-federal In-Kind support. Do we need to put Cash on the table or is the Cost Share via salary support, student support, goods and services, etc. sufficient and allowable? Is Cash-Designated Cost Share looked at more favorably than In-Kind? For this particular program are there any specifics that are more favorable than In-kind program support and costs?

Cash is not essential or required. Cost share via salary support, student support, goods and services, etc. is allowable and sufficient. Regarding your last question about specifics more favorable than In-kind program support and costs, the answer is No. As long as they meet 2 CFR 200.306 and are reasonable, allowable, and allocable. Also provided below is the following information for your reference:

Cost Share, as per eCFR :: 2 CFR 200.306 -- Cost sharing or matching. In-kind contributions are defined as third-party in-kind contributions and as the value of non-case contributions that benefit a federally assisted project or program and are contributed by non-Federal third parties, without charge, to a non-Federal entity under an award.

In-kind contributions are third party donations of goods, facilities, or services used to meet the cost share/matching requirement. The use and value of such third-party must be properly documented using fair-market values (they must also show how they derived at the amount or what website they used to get the information from such as the DOL for volunteers). They must meet the criteria as defined in 2 CFR 200.306.

2 CFR 200.306 (b) For all Federal awards, any shared costs or matching funds and all contributions, including cash and third-party in-kind contributions, must be accepted as part of the non-Federal entity's cost sharing or matching when such contributions meet all of the following criteria:

(1) Are verifiable from the non-Federal entity's records.

(2) Are not included as contributions for any other Federal award.

(3) Are necessary and reasonable for accomplishment of project or program objectives.

(4) Are allowable under subpart E of this part.

(5) Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs.

(6) Are provided for in the approved budget when required by the Federal awarding agency; and

(7) Conform to other provisions of this part, as applicable.

8. Are the ceiling/ and floor budgets of $3.5M and $1.5M per year for PSCs referring to DOE funds? So, our cost share added to the ceiling will be a minimum of $388,889 per year? When graduate students and post-docs travel to the labs for internships, can their travel expenses be considered "participant costs"? These are not subject to indirect costs by university rules.

The ceiling and floor amounts for PSCs and FICs are referring to DOE/NNSA funds. Cost sharing of at least 10 percent of the total allowable cost of the project is not included in the ceiling and floor amounts stated in the NOFO. It is allowable for the travel expenses to be considered as participant costs when graduate students participate at the NNSA Labs for internships and postdocs participating in lab visits.

9. In Section III.C.1 of the NOFO it is stated that foreign persons supported on an award must be reviewed by DOE/NNSA. And in Section III.D.4 is is stated that any cost share funds are restricted to the same use allowed for Federal funds. Do these statements mean that any personnel paid from cost-share funds must be vetted by DOE/NNSA before they are able to participate in the project?

The Department of Energy (DOE) will need to be made aware of all those who are supported under Federal funds as well as cost share in the full application. The positions must be clearly defined as U.S. Persons, as well as foreign persons including full name, countries of birth and citizenship, and U.S. status that are planned to be supported in this application, either through Federal funds or IHE cost-share funds as described in Appendix 7, Item 6. Appendices to Project Narrative Information” in Section IV Part B of the PSAAP IV NOFO. If selected for an award, every position whether funded by Federal funds or non-Federal funds (Cost Share), all positions in the application will need approval before participating in an FFRDC.

10. Can sub-recipients contribute cost-share to meet the requirement? Or is it required that the prime (lead)

IHE contribute the entire cost-share?

It is allowable to have sub recipients contribute to cost sharing. The approach of collecting and maintaining the cost share from the prime and sub recipients is acceptable. It is the prime recipient’s responsibility to make sure that the cost sharing requirements are met and to maintain records of how cost share is spent.

11. The NOFO for the PSAAP IV competition mentions a Budget Justification Workbook is included as

Attachment C. However, I don’t see an Attachment C in the NOFO or in Fed Connect or Grants.gov. Can you please tell me where to find it?

On the Front Page of the Announcement, CLICK ON PACKAGE, SCROLL DOWN & CLICK on PREVIEW OR APPLY for a sample document.

A reminder from the NOFO: A sample Budget Justification Summary workbook is included as Attachment C to this NOFO for use and describes the level of detail required in the budget justification. The data requested is required but the use of the budget justification workbook is not. The budget justification must contain the level of detail instructed in the workbook. If you choose to use Attachment C for your Budget Justification Narrative, note that there are several tabs to complete including the Equipment Estimates Summary, Travel Summary, and Materials and Supplies Summary. If funding is requested on the R&R Budget form for personnel, equipment, travel, participants, materials, supplies, or other direct costs (the budget justification is to be reflected in the associated tabs).

12. Is there a limit on the portion of the budget the experimental side can ask for?

There is no limit on the portion of the budget, but it is expected the Predictive Simulation Centers (PSCs) use the experiments to verify and validate the computational simulations (which is the main focus of the program). As mentioned in NOFO, Focused Investigatory Centers (FICs) will not necessarily have a tie to an application or be required to demonstrate a verified, validated predictive simulation with uncertainty quantification.

13. Is it acceptable if the budget we submit in the full application differs slightly from the budget we submit in the pre-application?

The pre-application and the full application will not be compared at the merit review. Hence, you can submit a different budget.

14. Is there a preference towards projects that ask for the lower end of the year budgets?

There is no preference towards projects that ask for the lower end of the year budgets.