Cost Sharing Policy
|Section:||Research, Sponsored Program, Technology Transfer and Intellectual Property Policies|
|Policy Name:||Cost Sharing Policy|
|Policy Owner:||Vice President for Research, Scholarship & Innovation|
|Responsible University Office:||Research Office|
|Origination Date:||November 3, 2009|
|Revisions:||July 21, 2015; August 2020|
|Legacy Policy Number:||6-19|
- SCOPE OF POLICY
This policy establishes the requirements and procedures for proposing, approving, administering, and documenting Cost Sharing on Sponsored Projects, including all contributions, such as cash and in-kind, that a recipient makes to an award at the University of Delaware (“UD” or “University”). This policy also sets forth requirements to ensure compliance with Federal regulations (Office of Management and Budget (OMB) Circulars A-110 and A-21 or Uniform Guidance 2 CFR 200). This policy applies to all University departments, units, faculty, staff and students.
- “Cost Sharing,” also commonly referred to as “matching,” represents the portion of award costs not borne by a sponsoring agency. Any Cost Sharing committed on a proposal, if awarded, is an assumed/committed budget amount that must be identified, utilized and tracked in the award.
- The term “Allowable”, for purposes of this Policy, shall refer to costs that must be consistent with the terms and conditions of the specific award, University and Federal regulations.
- The term “Allocable”, for purposes of this Policy, shall refer to costs that must provide a sole benefit to the project or provide proportionately assignable benefits to the project and other work.
- The term “Reasonable”, for purposes of this Policy, shall refer to costs that are reasonable when the cost is necessary for the performance of the Sponsored Project, when an individual would normally purchase the item at that price given the circumstances, and when the cost is incurred consistent with established University policies.
- “Committed Effort” is the amount or percentage of time a University employee has agreed to work on a specific Sponsored Project. It is not necessarily the actual effort expended each month, but a projected amount to be achieved over a period of time (for example, a semester or a year). This commitment is set at the time of the award.
- Facilities and Administrative Costs (“F&A Costs”) are indirect costs that are incurred for common and joint objectives and therefore cannot be identified readily and specifically with a particular sponsored activity.
- “Effort Certification” is an employee’s documentation of his/her effort report and is an affirmation that his/her reporting of effort is accurate and complete.
- A Principal Investigator (“PI”) is defined as the individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the Sponsored Project (grant or contract) including programmatic reporting.
- POLICY STATEMENT
The University engages in Cost-Sharing when it is in the best overall interest of the University. Cost Sharing is limited to situations in which it is mandated by the sponsor per solicitation or policy guidelines or deemed appropriate in light of specific and compelling circumstances.
- POLICY STANDARDS AND PROCEDURES
- As a general rule, Cost Sharing should only be offered in a sponsored program proposal when it is mandated by the sponsor. Voluntary Cost Sharing is highly discouraged by the University, as it involves increased expenditure of scarce resources, liability for sponsored programs compliance, and administrative burden (especially for proposal submission, award setup, effort certification, and financial reporting).
- Approval for Cost Sharing should occur at the time of proposal submission via inclusion in the proposed budget. Cost Sharing represents a commitment of resources by the University that can be made through contributions of, but not limited to labor (effort provided on a project), tuition scholarships, equipment funds, or third party (sub-award or collaborator) contributions. Once Cost Sharing is specified and quantified in the proposed budget, budget justification, or budget narrative by the University, the institution is committed to Cost Sharing even if Cost Sharing is not required by a sponsor. Costs incurred by the University to fulfill Cost Sharing commitments must coincide with the budget period of the award.
- The PI on a Sponsored Project is responsible for maintaining records of all project-related costs for both the award and Cost Sharing components. In general, Cost Sharing must be identified and tracked within the general ledger so that it is verifiable and reportable by the University.
- The University reserves the right to proportionately reduce the Cost Sharing commitment if funds awarded are less than proposed.
- Categories of Cost Sharing
- Mandatory Cost Sharing
Cost Sharing should be provided only in sponsor-mandated instances. If Cost Sharing is mandated by a sponsor, it should be limited to the minimum amount necessary to meet the sponsor’s requirement.
- Voluntary-Committed Cost Sharing
Voluntary Cost Sharing is committed when the University has determined that a contribution of additional resources is necessary to ensure a competitive advantage for award. The University strongly discourages voluntary-committed Cost Sharing. Under 2 CFR 200, voluntary-committed Cost Sharing is not expected and will not be used by sponsors when evaluating proposal technical merit unless it is in accordance with the Federal awarding agency regulations (for example, to comply with a mandated salary cap) and notated in the Federal Funding Opportunity.
- Voluntary-Uncommitted Cost Sharing
A commitment of University resources beyond the budgeted commitments is considered voluntary-uncommitted Cost Sharing. An example includes effort provided by a faculty member beyond that which is budgeted. In these circumstances, it is not necessary to track or account for these costs.
- Mandatory Cost Sharing
- Allowable Cost Sharing
- Cost Sharing must be:
- Allowable and Allocable under federal cost principles as referenced in the above Scope of Policy section and as defined above;
- Verifiable from University records when applicable;
- Necessary and reasonable for proper and efficient accomplishment of project objectives;
- Identified in the approved award budget set up by the Research Office when applicable;
- In compliance with the criteria outlined in the applicable federal regulations; and
- Determined by the sponsor’s specific award terms and conditions.
- Cost Sharing must be:
- Effort Cost Sharing
- Principal Investigators and other senior/key personnel must demonstrate effort on their proposals and awards. This effort may be reflected as direct salary or Cost Sharing on an award. Certain awards which require very little or no dedicated personnel time (e.g. equipment, dissertation or training support, fellowship, travel, conferences, or other limited purposes) may be exempt from this requirement.
- Effort may be committed and met at any time within a project year (summer months, academic year, or both). Committed effort, whether mandatory or voluntary, must be met and reported during the periods in which it was accomplished. Any effort provided in excess of the level committed to a sponsor is referred to as voluntary-uncommitted Cost Sharing and is not required to be reported to the sponsor.
- Equipment Cost Sharing
- Equipment committed as Cost Sharing in a proposal, whether mandatory or voluntary, must be purchased, tracked, and reported during the periods in which it was utilized. Any equipment Cost Sharing provided in excess of the level committed to a sponsor is referred to as voluntary-uncommitted Cost Sharing and is not required to be reported as Cost Sharing.
- University equipment Cost Sharing dollars may be available when a sponsor requires mandatory equipment Cost Sharing or the project budget exceeds the available funding for equipment. Equipment specifics (e.g., cost limits and life expectancies) are consistent with UD Policy 5-01.
- The PI may submit requests of up to $50,000 from the Research Office with one-to-one match assistance from the PI’s college or unit. For example, $50,000 from the Research Office requires an equal $50,000 from the college or unit. These funds must be used on equipment and cannot be used for any other purpose unless prior written approval is granted by the Vice President for Research, Scholarship & Innovation (or their designee).
- In the case of major center proposals that involve multiple academic units and multiple years of funding, the PI may submit requests to the Research Office of up to $50,000 for each year of funding. The requested amount must be matched one-to-one by the college or unit for each of the years that the Research Office provides funding.
- The University has an annual equipment Cost Sharing budget. Any overrun amounts to the equipment budget are proportionately divided among those colleges and units benefiting from the Cost Sharing during that fiscal year.
- Non-Equipment Expenses
Non-equipment expenses, such as travel and supplies, may be used as Cost Sharing when they are deemed necessary to meet mandatory Cost Sharing requirements or for project performance. These expenses must comply with federal regulations.
- Third-Party Cost Sharing
Third-Party Cost Sharing contributions are those given to a specific grant or contract by an individual or group from outside both the University and the sponsoring agency. PIs are responsible for obtaining and monitoring supportive financial documentation to verify that Cost Sharing requirements have been met. A letter of Cost Sharing commitment must be provided by the third party. Third-party Cost Sharing must be verified and documented.
- Waived Facilities & Administrative Rate (F&A) Cost Sharing
Unrecovered F&A costs on Federal projects may be included as Cost Sharing only with the prior approval of the Federal awarding agency. These amounts shall be documented in the University’s financial system and shall be reflected in the closeout analysis. These amounts shall be tracked in the University’s financial accounting system as analysis type values of WFA (Waived Facilities and Administrative) and CFA (Cost Sharing Facilities and Administrative). As F&A Costs are reimbursements for expenses already incurred, the University does not generally support F&A Cost waivers and will only consider them when a compelling rationale is provided.
During the proposal process, if a potential subaward recipient proposes Cost Sharing, the Cost Sharing shall be documented in the letter of intent. When awarded, committed Cost Sharing shall be documented in the subaward agreement and must be tracked by the prime awardee throughout the life of the award. The prime awardee is responsible for ensuring the entire Cost Sharing commitment is met.
- Unallowable Cost Sharing
The following types of Cost Sharing are not allowed:
- Federal to Federal – Federal appropriations or contracts and grants funded by Federal agencies, either directly or indirectly as flow-through funding, are not allowable as Cost Sharing for other Federal projects. Federal contracts and grants may generally be used as Cost Sharing on any non-Federal contract or grant unless restricted by the non-Federal sponsor.
- Expenditures Included in the F&A Rate – Costs that are included as part of the facilities and administrative cost rate calculation, such as space used for instruction and research, equipment depreciation, utilities, department administration, etc., cannot be cited as Cost Sharing expenditures.
- Double Counting – Cost Sharing can only be committed and reported as Cost Sharing once. If Cost Sharing relates to two or more projects, it shall be pro-rated among the projects so that, in total, it is only reported once.
- Costs Incurred Outside the Project Period – Costs that have already been incurred and are documented in the University accounting system prior to the project award start date are generally ineligible for Cost Sharing unless allowed as pre-award costs.
- Lack of Technical Relationship – Costs that are not specifically related to the performance of the project cannot be used as Cost Sharing. Therefore, if another University-sponsored project or gift is identified as a Cost Sharing contribution, the technical relationship between the two (or more) projects must be established and documented.
- Costs Specifically Not Allowable under Federal Regulations – These costs include alcohol, entertainment, advertising, memberships, etc. In addition, any costs associated with a Principal Investigator’s sabbatical leave are generally not allowable unless specifically approved by the sponsoring agency.
- Expenses prohibited by the award terms and conditions.