Cost Sharing Policy For Research, Training and Other Activities
Winfred M. Phillips, Vice President for Research, Dean of the Graduate School
The draft policy for cost sharing was previously circulated and we appreciate the input and suggestions received from the colleges. Those suggestions have been incorporated into the attached copy of the final version of the cost sharing policy. Please note that, based on an ongoing dialogue between sponsoring agencies, extramural funding recipients, and the Office of Management and Budget (OMB), further information may be provided specific to cost sharing guidelines (similar to the recent NSF actions on this matter). As such guidelines/best practices are identified, the Division of Sponsored Research will update this cost sharing policy as appropriate. Please contact the Division of Sponsored Research at extension 2-1582 if there are questions regarding this matter. The policy below will also be posted shortly on the Web at http://rgp.ufl.edu/research/proposal.html.
Thank you for your efforts in this regard.
University of Florida Cost Sharing Policy For Sponsored Research, Training and Other Activities
It is the policy of the University that only mandatory cost sharing be submitted to sponsoring agencies. This policy does not preclude exceptions that may be judged appropriate under certain circumstances to leverage a project. Mandatory cost sharing requirements are usually defined by law, statute, agency regulations, or written in the application guidelines for a specific program. When there is mandatory cost sharing a copy of the RFP, regulations or guidelines must be submitted with the proposal along with a written commitment from the individual authorized to commit the resources. All non- mandatory or voluntary cost sharing must be reviewed and committed in writing by the College Dean (without delegation) and forwarded with the proposal for approval in RGP by an authorized institutional representative.
Criteria for Cost Sharing Commitments
(1) Cost sharing and matching funds must be verifiable from the University’s records.
(2) In-kind, third party contributions offered as cost sharing, require a commitment letter on company letterhead signed by an individual who is in a position to commit the in- kind contribution. After the fact reporting to the University will be necessary.
(3) Commitments must not be included as contributions for any other project or program.
(4) Commitments are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
(5) Commitments are allowable and allocable under the applicable cost principles.
(6) Cost sharing commitments may not be from other funds supported by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
(7) Costs are described in the approved budget and/or terms of the sponsored agreement when required by the awarding agency.
(8) Cost sharing provisions of OMB Circular A-110 are met.
2. General Information
Cost sharing is a term that describes circumstances whereby the University is not reimbursed for allowable costs of performing a project because the requested or approved budget does not cover the full costs associated with the specific project. Therefore, cost sharing (also known as matching, or in-kind contributions) represents that portion of the project costs not paid for by the sponsor.
Matching funds may be cash or in-kind contributions. They may include a dollar-for-dollar match to purchase equipment or renovate a facility.
In-kind contributions may be donated time, space, equipment, etc.
Caution: (The value of a third party in-kind contribution must be established and verified at the time of proposal submission and documented at the post award stages. For example when the contribution is in the form of personal services, the contributor must certify that the amount being provided as in- kind is comparable to the individual’s regular rate of compensation. When in-kind contributions are other than personal services, the fair market value of the item must be established, consistent with OMB A-110 procedures).
Cost sharing may be mandatory, voluntary committed or voluntary uncommitted.
Mandatory cost sharing is either required by statute or may be a condition of a specific solicitation. It will normally appear in the award document from the agency. Mandatory cost sharing expenses must be reported back to the sponsoring agency in a Financial Report.
Voluntary committed cost sharing is created if a proposal included cost sharing when none was required. Even if that cost sharing is not in the budget awarded by the agency, the PI and the University are “committed” to providing the project with the indicated support. Voluntary committed cost sharing expenses are not reported back to the sponsoring agency; however, it is still required that the University track and document these costs as they are subject to audit.
Voluntary uncommitted cost sharing is cost sharing that is neither mandatory nor committed. It represents contributions to a sponsored project that do not come from the awarding agency. Voluntary uncommitted cost sharing expenses are not reported back to the sponsoring agency, however they will still be recorded through the Effort Systems or through manual cost sharing entries.
When the University accepts an award with mandatory or voluntary committed cost sharing, the University is making an agreement with the sponsor that is subject to audit. The University is committing to provide the stated cost sharing during the period of performance of the sponsored project.
Caution:(Voluntary committed cost sharing offered in a proposal may be accepted by the sponsoring agency and become a condition of the award, thereby making it mandatory cost sharing.)
Cost sharing must be an allowable cost. This means that grants and contract costs must be allowable under OMB Circular A-21, A-110 and University policies. Any cost that would be unallowable on the grant or contract will be unallowable as cost sharing for that grant or contract. For example, administrative support is not normally allowed as a direct charge to a Federal grant, therefore it is an unallowable cost regardless of the source of support and cannot be used for cost sharing purposes. Sponsoring agencies may have various guidelines with regard to cost sharing. For example, the U.S. Department of Education may allow 8% TDC on a training grant. The difference between 44.5% and 8% cannot be used as cost sharing without prior approval of the Secretary of the U.S. Department of Education.
Cost sharing must be identifiable and verifiable. The college research office (IFAS, Engineering, College of Medicine) or business unit will be responsible for identifying and verifying mandatory and voluntary committed cost sharing by obtaining the required documentation for cost sharing at the time of proposal submission and sending the information with the proposal to the Division of Sponsored Research. The responsibility for entering cost sharing that was met during the project into the University’s effort reporting system is at the department level. The respective Contracts & Grants accounting offices (in IFAS, Engineering or Contracts & Grants-Tigert) are responsible for entering, from data provided by the departments, any cost sharing other than that reported through the effort reporting system, into the University’s cost sharing system.
The Contracts & Grants Accounting Office in Finance and Accounting, located at Tigert Hall, will track all cost sharing in the University’s accounting system and provide official reporting for such cost sharing. It will be the responsibility of the Principal Investigator and the Units to ensure that the cost sharing commitment is met on a grant or contract and to provide the appropriate Contracts & Grants accounting office the documentation necessary to track cost sharing commitments.
3. The Impact of Cost Sharing on the University’s Federal Facilities & Administrative Rate
Cost sharing dollars in aggregate have a negative impact on the University’s Facilities and Administrative cost rate (indirect cost rate). As cost sharing dollars from various units throughout the University accrue in the accounting system, the total amount is incorporated into formula used in the negotiation of the University’s indirect cost rate. As the denominator increases, the percent rate decreases, resulting in a lower Facilities and Administrative rate (indirect cost rate).
4. Cost Sharing Does Not Include:
Items listed in current and pending support, unless specifically identified as cost sharing.
Voluntary uncommitted cost sharing of time and effort is the extra time and effort that an individual might work on a project. For example, Dr. X may chose do work on his grant at a level of 25% of his time rather than the 20% that was in the proposal. The extra 5% of time and effort is voluntary uncommitted cost sharing. It should be accurately reflected in the Activity System but does not need to be accounted for in the University’s cost sharing systems.
– NSF Policy Statement on Cost Sharing (99-92) & NSF Grant Proposal Guideline (page 12)
– Grants Management Advisory Service (February 1995, pages 27- 31)
– OMB A110 (Section 23. Cost Sharing or Matching)
– HHS Transmittal Letter 99.05
– OMB A-21
– OMB Clarification on Voluntary Uncommitted Cost Sharing (January 5, 2001)