Institutional Sponsored Project Cost Sharing Policy

Policy Date: November 2018     Revision: 4     Last Review: October 2018

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Purpose

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.

Responsibilities

All employees must comply with this policy. It is the responsibility of the dean/vice president or chair/director to implement and maintain this policy within their unit. 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. Principal investigators must maintain oversight of all cost share obligations from all sources.

Definitions

Cost sharing is that portion of a sponsored project related to cost that is contributed by parties other than the primary sponsor and is not directly charged to a sponsored project award. 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 project and is subject to audit.

Three types of cost sharing are defined as follows:

  • Mandatory Cost Sharing is cost sharing that is required by the sponsoring agency and included in the proposal budget. 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 included in a sponsored project budget. It does not need to be tracked for cost accounting purposes and is generally not reported to the sponsor. An exception is salary expenses that are in excess of a sponsor's salary cap; over-cap salary is cost share that must be certified on an effort report and will be reported to the sponsor but cannot be used to meet a cost sharing requirement.

Policy

Cost sharing (regardless of type) should only be provided when required by the sponsoring agency. 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:

  1. When the agency or specific program requires that cost share be provided, and the documented departmental and/or college support is insufficient. 
  2. If the proposal is selected in an internal competition as a University proposal for a limited submission solicitation. 
  3. If the proposal has the potential of leading to significant external funding.
  4. 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 proposed 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 unit 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.

Cost Share Components

The following expenditures may be used to meet a cost share obligation:

  1. Effort and the corresponding salary and fringe benefit costs paid by the University to University employees.
  2. Travel, equipment and material costs paid by the University.
  3. F&A on costs paid by the University.
  4. Unrecovered F&A on the sponsor's portion of the project expenditures if allowed by sponsor.
  5. Salary (non-University employees), travel, equipment and material costs paid by a third party.
  6. Third party donated space.

Cost Share Expenditure Eligibility

An expenditure must meet all of the following eligibility criteria to be used to meet a cost share obligation:

  • 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.
  • Allowable under the applicable cost principles and institutional policies.
  • Documented in the approved budget when required by the sponsor.
  • 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.

Ineligible Expenditures

The following expenditures are not eligible to be used in meeting a cost share obligation:

  • Costs incurred outside the start and end dates of the project.
  • Costs already used as cost share on another project or for another institutional purpose.
  • Restricted or unallowable expenses under the Uniform Guidance such as entertainment or food costs and salary expenses over a sponsor's salary cap.
  • Costs that do not benefit the project.
  • Administrative and clerical salaries, office supplies, memberships, subscriptions, etc., unless these costs have been fully justified and approved by the sponsor in advance.
  • Existing space, facilities, equipment, supplies and utilities.

Third Party Cost Share

In addition to University resources, it may be permissible to utilize expenditures by a third party to meet a cost share obligation. All third party cost share must be valued based upon reasonableness given the type of third party service provided and properly documented in compliance with the Sponsored Projects Cost Share Accounting procedures.

It is the responsibility of the PI to obtain proper documentation of third party cost share and provide it to Sponsored Projects as required by project terms.

Failure to Meet a Cost Share Obligation

Failure to meet a cost share obligation can result in a disallowance of costs paid by the sponsor. The sponsor may reduce its support and/or require reimbursement if the University fails to meet its cost share obligation. In these instances, the PI's department and/or college are required to cover the deficit.