Policies & Procedures

Research, Grants and Export Control

Cost Sharing on Sponsored Projects - 1M8

Introduction

Regulations require the University to substantiate, through adequate records, cost sharing expenditures for both direct and indirect (facilities and administrative) costs associated with all external grants and contracts. The records must reflect that direct cost sharing expenditures are appropriate, necessary, and incurred within the related project period. Records must also provide evidence that the cost sharing expenditures incurred in a particular fiscal year are included in the development of the University's facilities and administrative cost rate for the same fiscal year.

Definition of Cost Sharing

The Office of Management and Budget's (OMB) "Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" defines cost sharing or matching as "the portion of project costs not paid by federal funds or contributions (unless otherwise authorized by federal statute)." Specific categories of cost sharing are defined as follows.

1. Mandatory, or required, cost sharing is:
   
   1. mandated by law or regulation
   2. stated in a program or project announcement.
2. Voluntary committed cost sharing is:
   
   1. solicited or suggested in the program or project announcement
   2. specifically pledged in the proposal's budget or award by the institution.
3. Voluntary uncommitted cost share is:
   1. personnel effort that is over and above that which is committed and budgeted for in a sponsored agreement.

Cost sharing may be in the form of in-kind contributions, cash, and/or donated property. In-kind contributions may include but are not limited to the following cost elements:

1. salary and wages
2. employee benefits
3. other expenses (such as equipment and supplies)
4. tuition remission
5. indirect costs associated with direct costs listed above
6. unrecovered indirect costs.

Cash cost sharing contributions include:

1. cash contributions from unrestricted accounts and/or third-party sources
2. matching funds - cash contributions from unrestricted accounts and/or third party sources. (Matching funds typically require a dollar-for-dollar ratio to qualify for funding.)

Cost sharing must be:

1. verifiable from the institution's records
2. not included as contributions for any other federal award
3. necessary and reasonable for accomplishment of the project or program objectives
4. directly identifiable with the project
5. incurred during the period of performance of the award
6. financed from non-federal funds, 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
7. provided for in the approved budget when required by the awarding agency
8. compliant with federal cost principles.

Policy

University policy requires that (a) the Office of Research and Projects (ORP) review agency program guidelines and policy requirements to determine whether cost sharing is mandatory and (b) the Associate Provost for Research (APR) or designee review and approve all cost sharing commitments.

Proposed voluntary committed cost share requires additional written justification. "Under Federal research proposals, voluntary committed cost sharing is not expected" (OMB Uniform Guidance § 200.306). 

When cost sharing is required and/or proposed, the program or project budget will specifically identify the source of funds that will be used to satisfy the cost sharing commitment. Grant accounts will not be activated and/or spending will not be permitted on an award until all cost sharing resources are identified. 

Voluntary uncommitted cost share is not tracked.

Responsibilities and Authority

When a sponsor does not provide rules or guidelines that require cost sharing but encourages it in writing, the principal investigator shall consult with his/her Dean or Vice Chancellor and the APR or designee to determine if cost sharing is appropriate and, if so, at what level.

In instances when program guidelines require a level of mandatory cost sharing and a commitment is made to cost share funds to a project, the Dean(s) or Vice Chancellor(s) of the principal investigator and co-investigator(s) as well as their Department Chair(s) and/or Director(s) must verify the availability of such funds before submitting the proposal for review to the ORP.

If needed, the APR or designee shall assist with identification of appropriate University funds. If a proposal is not submitted due to lack of mandatory cost sharing funds, the APR must notify the Provost before the submission deadline and notify the Graduate Council at their next scheduled meeting.

In order to identify and document cost sharing expenditures from state funds, each school/college or unit will establish prior to expending cost share funds a state (2) ledger cost share account that will clearly be identified as such in the university's financial accounting system and in which cost sharing expenditures for each sponsored program within that school/college or unit will be recorded. The school/college or unit is responsible for maintaining separate records and supporting documentation of cost sharing expenditures posted in this account for each sponsored program and providing such documentation to ORP. The school/college or unit is also responsible for maintaining separate records and supporting documentation of all non-state cost sharing expenditures posted in other accounts for each sponsored program and providing such documentation to ORP.

The ORP is responsible for preparing reports to sponsors with regard to cost share expenditures.