Institutional Sponsored Project Cost Sharing Policy
Date: March 2016 Revision: 3
The purpose of this document is to provide guidance to ensure that the University properly accounts for cost sharing expenditures and does not overburden department and/or college resources and facilities and administrative (F&A) recovery. This policy applies to all units of the University and all projects submitted by the University. Requests for institutional cost share from the Research & Innovation division must be received by Research & Innovation at least three weeks prior to the proposal submission deadline.
Cost sharing is that portion of a sponsored agreement related to cost that is contributed by parties other than the primary sponsor and not directly charged to sponsored agreement account(s). Cost share can include cash or in-kind contributions (such as the value of tuition waivers or salaries) to support a project. Cost sharing represents a legal commitment by the University to provide resources to a sponsored agreement and is subject to audit.
Three types of cost sharing are as follows:
- Mandatory Cost Sharing is cost sharing that is part of the proposal budget and is mandated by the sponsoring agency. This can be in the form of a specified dollar amount, a certain percentage of total costs or in-kind.
- Voluntary Committed Cost Sharing is cost sharing that the University contributes to a project on its own initiative and is included in the proposal budget or award. Once committed, this amount becomes a legal obligation on the part of the University.
- Voluntary Uncommitted Cost Sharing is cost sharing that is not committed to or budgeted for in a sponsored agreement. It need not be tracked for cost accounting purposes or reported to the sponsor, and if it arises from faculty or other personnel effort, it is excluded from separate identification in effort reporting. Voluntary Uncommitted Cost Sharing most commonly results from a cost overrun on a project or from research efforts which are over and above the effort committed to and budgeted for in a sponsored agreement. Another example would be the faculty oversight of student practicums where the specific percentage of effort for the faculty member’s time is not tracked on an individual project basis but is part of the faculty member’s overall teaching responsibility.
The University’s Research & Innovation division is committed to enhancing the research competitiveness of the University’s faculty. Research & Innovation encourages and supports development and submission of proposals for large multi-disciplinary research programs and those that have a strong record of generating significant F&A and investment into research infrastructure development that will facilitate significant extramural research funding.
Cost sharing (regardless of type) should only be provided when required by the sponsor. Because cost sharing typically involves the use of departmental and/or college funds, department heads and/or deans must approve cost share in proposals and may impose limits on the amount of cost sharing. Research & Innovation also reserves the right to impose cost sharing limits on proposals as situations warrant. Only after in-kind cost share from departmental and college resources is exhausted should cash cost share be considered.
Research & Innovation will provide cash cost sharing only under the following circumstances: when the agency or specific program requires that cost share be provided and the documented departmental and/or college support is insufficient, if the proposal is selected in an internal competition as a University proposal for a limited submission solicitation, if the proposal has the potential of leading to significant external funding or if the proposal is a request for equipment which will be shared by faculty in different units on campus.
Cost sharing by Research & Innovation will only be in proportion to the distribution of F&A dollars recovered under the F&A distribution policy that is in place at that time. Except under unusual circumstances as determined by the Vice President for Research and Innovation, Research & Innovation will not provide cash cost share in excess of the F&A collected and retained by the University. If an agency allows F&A costs and requires cost sharing, then a waiver of F&A costs is not an acceptable method of providing cost share. F&A recovery may be reinvested to meet the cost share requirements of the project.
When cash and in-kind cost sharing is accepted by the sponsor, it becomes a legal commitment by the University. Throughout the term of the project, the principal investigator (PI) and their college budget officer (along with oversight provided by Sponsored Projects) must maintain sufficient documentation to substantiate the actual cost sharing contribution in compliance with governmental regulations, primarily the Office of Management and Budget (OMB) 2 CFR Chapter I, Chapter II, Part 200, et al., Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards; Final Rule (Uniform Guidance) regarding allowability, allocability and reasonableness. When cost sharing expenditures are less than that agreed to in the award document, a loss or return of project funds to the sponsor may result. In these instances, the PI’s department and/or college are required to cover the deficit.
Cost sharing must meet all of the following criteria:
- Verifiable from the department’s accounting records, including appropriate documentation for in-kind cost sharing.
- Necessary and reasonable for proper and efficient accomplishment of project objectives.
- Represents types of charges that would be allowable under the applicable cost principles and institutional policy.
- Provided for in the approved budget when required by the federal agency.
- Expended during the sponsored agreement project period.
- Not paid by the federal government under another assistance agreement (unless the agreement is authorized by federal law to be used for cost sharing).
- Not included as contributions for any other sponsored agreement.
The cost sharing procedure development rests with Research & Innovation, and Sponsored Projects. Please refer to Cost Share Procedures below.
Cost share contributions from each unit must be documented in writing using the Cost Share Worksheet (SP-11), available on the University’s Sponsored Projects website, Policies and Forms page.
All employees must comply with this policy. It is the responsibility of the dean or director to implement and maintain this policy within their college. Responsibility for resolution of issues that arise regarding this policy rests with Research & Innovation and Sponsored Projects in consultation with the appropriate dean or vice president.