Procedure: 8-32	Effective: October 22, 2009
Owner: Office of Sponsored Programs	Latest Revision:

Cost Share Contributions To Federally Funded
Sponsored Activities

Scope

This procedure describes the management of cost share contributions made to federally funded sponsored activities. It further defines the types and methods of providing cost share toward sponsored projects and responsibilities in proposing, documenting, tracking and reporting these costs.

For the purposes of this document, the requirements and standards set forth in the Office of Management and Budget (OMB) Circular A-110, Section .23 (and a subsequent clarification issued by OMB on January 5, 2001 through a Presidential Review Directive) will be applied to federally sponsored awards, unless the sponsor provides specific guidance regarding its own requirements. In addition, OMB Circular A-21 will be applied in determining the allowability of costs claimed as cost shared contributions.

As prescribed by the above regulatory documents, all contributions including cash and third party in-kind shall be accepted as part of the recipient’s cost sharing or matching when such contributions meet all of the following criteria:

· Are allowable in accordance with OMB Circular A-21 (Reasonable, Allocable, Necessary, Timely);

· Are verifiable from the recipient's records;

· Are not included as contributions for any other federally funded project (If allocable to more than one project, the cost should be prorated accordingly);

· Are necessary and reasonable for proper and efficient accomplishment of project or program objectives;

· Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching;

· Are provided for in the approved budget when required by the Federal awarding agency.

Additional Considerations:

· When committing cost share in a proposal, considerations about sponsor expectations, internal budget impacts and resulting administration should be weighed. Cost sharing is usually only necessary when mandated by the sponsoring agency or by the competitive nature of the proposal.

· Cost Sharing of un-recovered or waived facilities and administrative (F&A) costs are not always permitted by federal sponsors and may require prior approval before including these costs toward a commitment. The terms of the award and/or the Funding Opportunity Announcement/Request for Proposal may address this specifically.

Definitions [Top]

Cost Share – The portion of total project costs of a sponsored project that is not borne by the Federal sponsor. These costs are also referred to as recipient share or matching and are representative of the institution’s financial contribution toward a sponsored project. Those costs included in the proposal are referred to as committed cost share. There are primarily two (2) types of cost share that may occur on sponsored projects:

1) Mandatory Cost Share – Requires a financial contribution from the recipient as a condition of award from the Federal sponsor, either by statute or by administrative regulation. The requirement for such commitments is normally set forth in funding announcements or sponsor guidance and is therefore necessary for eligibility to participate in the project. This financial requirement can be expressed as a dollar amount or as a percentage of total project costs or the award amount.

NOTE: Sponsor ‘encouraged’ cost share not required as a condition of receiving an award is not considered mandatory.

2) Voluntary Cost Share – Financial contributions included in a proposal that were not mandated by the Federal sponsor. Once the sponsor has accepted a proposal that includes these unsolicited financial contributions, the recipient is then obligated to meet those commitments.

Voluntary Uncommitted Cost Share – Voluntary uncommitted cost sharing is defined as the effort of Principal Investigators/Project Directors and key personnel that is over and above that which is committed and budgeted in the proposal, but not charged to the sponsored project.

In-Kind Cost Share – Non-cash contributions.

Aggregate Cost Share – A financial contribution in total on Federal awards instead of requiring the same on an award-by-award basis. This is also referred to as institutional cost share and is considered mandatory cost share.

Third-Party Cost Share – Financial contributions made by parties external to the university that directly support specific sponsored projects. These contributions are not recorded in the recipient’s accounting system but should be supported through documentation.

System References [Top]

Procedure 8-31, "Time & Effort Certification"

Policy [Top]

Policy VIII.C.1, "A Compliance with Federal Sponsor Requirements"

Responsibility [Top]

Principal Investigators/Project Directors:

· Determine and verify any cost-share requirements on proposals

· Ensure that cost share contributions are documented on Part IV of the Internal Proposal Approval Form - Goldenrod)

· Ensure adjustments to salary/effort committed as cost share are made as approrpriate

· Ensure that cost share commitments are met

· Attest to cost share expenditures on the Statement of Cost Sharing Certification, when required

Department Chair/Dean and/or Vice President:

· Commit/ Approve resources as cost share

· Ensure that resources are available to support proposed cost share contributions

· Approve the Internal Proposal Approval Form

Research Administrators and/or Fiscal Contacts:

· Assist the PI/PD in determining and verifying any cost-share requirements on proposals submitted

· Assist with or complete Part IV of the Internal Proposal Approval Form

· Ensure that cost share commitments are adequately documented

· Ensure that labor schedules are adjusted as necessary when salary/effort is committed as cost share

· Monitor cost share throughout life of the project

· Maintain documentation in support of cost share contributions in accordance with OSP’s document retention procedure

School/College Research Administration Offices:

· Review proposed cost share commitments as listed on Part IV of the Internal Proposal Approval Form

Office of Sponsored Programs:

· Review proposal packages and related forms for cost share commitments

· Review sponsor’s notices of award for cost share commitments

· Document cost share requirements in the Integrated System upon official award

· Record cost share commitments from Part IV of the Internal Proposal Approval Form in institutional records

· Review and report cost share per sponsor requirements

Ownership [Top]

The Office of Sponsored Programs is responsible for ensuring that this procedure is necessary, reflects actual practice, and supports University policy.

Procedure Steps [Top]

PRE-AWARD

When identifying and providing resources for cost share commitments of direct costs (including equipment) funds provided from other federal awards may not be used unless specifically approved in advance by the sponsor contributing the funds. Funding sources available for cost share expenditures are typically identified from among department funds, local funds, gift accounts, endowment income, and others.

In preparing proposal packages, the Internal Proposal Approval Form is completed by the responsible PI/PD with assistance from the responsible departmental/school research administrators. In instances when mandatory or voluntary cost share commitments have been made in the proposal budget or narrative, Part IV of the approval form should reflect the types and level of the commitments to the sponsor’s project. The form should be approved by the responsible departmental/school official.

The entire proposal package is forwarded to the Office of Sponsored Programs (OSP) for further review. Sponsor proposal documents are then submitted for award.

NOTE: The School of Medicine Office of Grants and Contracts has delegated institutional authority in the review and submission of assistance types of proposals. Subsequent to proposal submission, the proposal package, including the Internal Proposal Approval Form is forwarded to OSP.

Upon award from the agency, OSP completes denotes the type(s) of cost sharing present in the award as part of the establishment of the award in the Integrated System.

POST-AWARD

Departments monitor, track and document commitments of cost share. The PI/PD is responsible for ensuring that commitments are met.

OSP will request the Statement of Cost Sharing Certification be completed when required for sponsor reporting of committed cost share.

The Office of Sponsored Programs reports cost sharing to sponsors in accordance with their specific requirements.

When at the close of a project’s period of performance, unanticipated project expenses result in more allowable charges to a sponsored project than were funded (cost overruns), the amount of the overrun is considered voluntary cost sharing and must be accounted for appropriately. Notations of cost share are to be documented in the university’s cost transfer process to adequately identify and record these contributions toward the sponsored project.

End of Activity

Cost Share Contributions To Federally Funded Sponsored Activities

Cost Share Contributions To Federally Funded
Sponsored Activities