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University Research Administration
Research Administration Hot Topic
Cost Sharing – Overview of the NEW policy and
procedures
Lynda Wolter & Mary Beth Rudofski
May 18, 2015
BSLC - 001
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Uniform Guidance on Cost Sharing
• 200.99 – Voluntary Committed Defined
– Cost sharing pledged on a voluntary basis in the proposal’s
budget or the Federal award
– Becomes a binding requirement of the award
• 200.306 – New Text in Post-Award Procedures
– Voluntary committed cost sharing is not expected and
cannot be used as a factor during merit review of the
application/proposal
– If voluntary committed cost sharing is used to determine
who may receive a Federal award, the criteria must be
explicitly described in the notice of funding opportunity
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Cost Sharing/Matching Contributions
• Financial Policy 2110 –
http://finserv.uchicago.edu/support/policies/2100/2110_costsharing.shtml
• Definition: Per federal regulations, cost
sharing or matching is defined as the portion
of project costs not paid by sponsor funds. For
purposes of this policy, cost sharing and
matching are synonymous.
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Types of Cost Sharing
• Mandatory cost sharing are costs the University must contribute as
a condition of the award as described in the funding opportunity
and/or in the award document.
• Voluntary committed cost sharing are costs that are not a
condition of the award, but those that the University voluntarily
commits to by describing and quantifying specific costs in a
proposal budget and/or budget justification. This includes any
unfunded effort above a salary cap.
• Voluntary uncommitted cost sharing are costs the University incurs
as part of completing the project but were not disclosed nor
committed to in the proposal budget and/or budget justification.
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Policy Synopsis
•
Cost sharing and matching funds are both considered forms of cost
sharing and must meet all of the following criteria:
– Are verifiable from University financial records;
– Are not included as contributions for any other Federal award;
– Are necessary and reasonable for accomplishment of project or program
objectives;
– Are allowable under federal regulations or sponsor-specific agency policy;
– Are not paid by the Federal Government under another Federal award, 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; and
– Are provided for in the approved budget when required by the Federal
awarding agency.
– Unrecovered Indirect Costs require agency prior approval to include these
costs as part of cost sharing or matching. Salary Caps, other than cost sharing
caused by the NIH salary caps to HHS awards, must be charged to a “cost
sharing” associate account of the sponsored award.
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Pre-Award Procedures
At Proposal Routing, the cost sharing commitment must be
made in the agency proposal budget per the requirements of
the sponsor and recorded in the AURA cost share budget.
– Proposal budgets should include the cost shared expense in a
way that is clearly identifiable.
– Proposal budget justifications/narratives should include
language that if the awarded budget is cut, the cost sharing
commitment will also be reduced in proportion to the cut and
with agency approval.
– If external entities are providing cost sharing or in-kind
contributions, then documentation to the source of the
contribution must be included in the proposal/application and
be signed by a representative who can legally bind the external
entity.
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Pre-Award Procedures
•
Internal Cost Share Memo: The unit on campus providing the cost sharing
must provide in writing the amount and source of the cost share funding.
– The cost sharing memo must be signed by the Department Chair, Dean or
other University official who can make the commitment of funding.
– Cost Share commitments cannot be contingent on the availability of funding.
– Once the commitment is made, it cannot be withdrawn unless the sponsor is
notified and approves the change in budget.
– NIH Cap Exceptions: no cost share memo is needed unless the over the cap
salaries are for ANL employees. Then a memo is needed as the grant
department covers any cost share costs for ANL employees rather than ANL.
•
All cost sharing/matching commitments must be documented in writing
and the PDF saved in 18.3 Other Internal Documents.
•
Budget Grid: on View 1 indicate the type of cost sharing and the costs
documented in the AURA Cost Share Budget
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Pre-Award Reminder – PI effort
REMINDER: All Research projects must include PI effort for at least
one named Principal Investigator/Program Director in accordance with
University policy:
http://researchadmin.uchicago.edu/policies_compliance/policies/facul
ty_effort_projects.shtml.
• If that effort is not funded by the sponsor, then the effort is
considered voluntary committed cost sharing and should be
documented as such.
• Equipment, instrumentation, student support, dissertation awards
and other research-related projects are exempt from the
requirement of PI effort unless there is a specific agency
requirement for PI effort or the effort commitment of the PI is more
than de minimus time.
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At Time of AWARD
The URA Award Manager will review the
documentation and confirm all cost share
commitments, except Over the NIH Cap Cost
Share.
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Post Award Procedures
• Mandatory or voluntary-committed cost
sharing commitments need to be accounted
for in FAS
• An associate account(s) is created under the
main FAS award account to capture these
commitments
• SAA will work with the Unit to determine what
account(s) are needed and the account(s) that
will ultimately fund the cost sharing expenses
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Post Award Procedures
Type of Cost
Commitment
FAS Accounting
Salary (and
associated fringe
benefits)
Effort from faculty or • Work w/SAA to create associate account
staff that the
• Update Workday Costing Allocation to
sponsor will not pay
charge the associate account
Salary (and
associated fringe
benefits)
Effort from faculty or HHS Awards / NIH Salary Cap
staff that the
• Update Workday Costing Allocation to
sponsor pays only
charge a non-sponsored account for the
up to a salary cap; a
over-the-cap salary
cap that limits the
rate of pay
Non-HHS Awards
• Work w/SAA to create associate account
• Update Workday Costing Allocation to
charge the main account with the salary up
to the cap and the associate account for
the salary that is over-the-cap
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Cost Allocation Example – HHS Award
Monthly
Salary
NIH Salary Cap
(1/11/15)
Base Salary
@
$240,000 /
12 months
NIH Cap @
$183,300 /
12 months
$20,000.00
$15,275.00
Expected Salary Distribution
Effort
to HHS Award
Account
20%
Salary Distribution to
Non-Sponsored
Account
20% of Salary Cap @
$3,055.00 /
Monthly Salary at
$20,000
Expected Effort @
20% less
HHS Award @
15.275%
15.275%
4.725%
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Cost Allocation Example – Non-HHS Award
Monthly
Salary
SponsorSpecific Salary
Cap
Base Salary
@
$240,000 /
12 months
Sponsor Cap @
$200,000 /
12 months
$20,000.00
$16,666.67
Expected Salary Distribution
Effort
to Main Award
Account
20%
Salary Distribution to
Associate Account
20% of Salary Cap @
$3,333.33 /
Monthly Salary at
$20,000
Expected Effort @
20% less
Award @ 16.667%
16.667%
3.333%
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Post Award Procedures
Type of Cost
Commitment
FAS Accounting
Other direct
expenses (not
salary/fringe)
Supplies,
equipment, travel,
etc.
• Work w/SAA to create associate account
(can be same as account for personnel
expenses)
• Charge associate account for purchases
and reimbursements
Indirect costs
Indirect cost on
• No accounting actions are necessary
direct cost sharing
• SAA to calculate indirect for reporting
expenses or
purposes
unrecovered indirect
costs
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No Cost Extensions
• PI effort is required; other researchers effort
may be needed
• If a commitment is made when requesting an
extension that will not funded by the sponsor,
the voluntary committed cost sharing will
need to be charged to a cost sharing associate
account
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References
•
UG §200.306 Cost sharing or matching: http://www.ecfr.gov/cgi-bin/text-
idx?SID=704835d27377ef5213a51c149de40cab&node=2:1.1.2.2.1&rgn=div5#se2.1.200_130
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•
Memoranda 01-06 -- Clarification of OMB A-21 Treatment of Voluntary
Uncommitted Cost Sharing and Tuition Remission Costs:
http://www.whitehouse.gov/omb/memoranda_m01-06
•
UChicago Financial Policy:
http://finserv.uchicago.edu/support/policies/2100/2110_costsharing.shtml
•
URA links: Cost share (to be revised):
http://researchadmin.uchicago.edu/preparing/budget_development/cost_sharing.shtml
•
Faculty Effort on Research Projects-
http://researchadmin.uchicago.edu/policies_compliance/policies/faculty_effort_projects.sht
ml
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