Sponsored Project Cost Sharing

Policy number: 10.14

Policy section: Research

Revised Date: December 16, 2019

1. Definitions

Definitions of capitalized terms are set forth in Appendix A.

2. Policy Statement

It is the policy of the University that only the minimum amount of Cost Sharing necessary to meet a Sponsor’s requirements will be provided by the University.

3. Purpose

As a condition of accepting Funding from a Sponsor, the University may be held responsible for a portion of the cost of the Sponsored Project. The purpose of this policy is to establish requirements for the identification, funding, accounting, and reporting of Mandatory Cost Sharing, Voluntary Committed Cost Sharing, and In-Kind or Matching associated with Sponsored Projects.

4. Cost Sharing

Voluntary Committed Cost Sharing is discouraged and in some cases unallowable unless specifically required by the Sponsor.
Mandatory Cost Sharing, Voluntary Committed Cost Sharing, In-kind or Matching must be identified, administered, and accounted for consistently for Sponsored Projects regardless of the source of Funding. Mandatory Cost Sharing, Voluntary Committed Cost Sharing, In-kind or Matching must conform to University and federal policies regarding allowability, allocability, and reasonableness and must be verifiable through documentation. Direct Cost Sharing approval and source must be obtained in writing from the appropriate Dean of the school or college, department Chair, or Director of a center, institute, or division following procedures specified in the Research Handbook and providing the resources prior to submission of the Proposal.
The Associate Vice President for Research or designee must approve the proposed waiver of any portion of F&A Cost recovery and provide a detailed report of the approved waivers annually or more frequently, as requested, to the Vice President for Business and Finance or designee.

5. Roles and Responsibilities: Principal Investigator/Project Director

It is the responsibility of the Principal Investigator/Project Director to:

ensure that Cost Sharing is only committed when required by Sponsor guidelines;
identify resources for Cost Sharing prior to Proposal submission;
associate Cost Sharing expenses with only one Sponsored Project and ensure that commitments are met;
document third party contributions properly;
ensure that allowable, allocable, necessary, and reasonable costs are incurred during the effective dates of the Award and are timely and accurately charged to the appropriate accounts and Sponsored Projects;
ensure that Cost Sharing is not paid from federal funds except as authorized by law; and
complete the Waiver of IDC Form.

6. Roles and Responsibilities: Deans, Associate Deans, Assistant Deans, and Department Chairs

It is the responsibility of the Deans and department Chairs to:

provide direction, resources, and oversight to help ensure that all Cost Sharing obligations and expenditures are met in accordance with law, University Policies, and Sponsor policies and procedures;
document in a timely manner the allocation of department Voluntary Committed Cost Sharing;
provide all sources of Cost Sharing and Matching obligated by the school, college, department, division, center, or institute; and
sign the Waiver of IDC Form.

7. Roles and Responsibilities: Office of Research Administration and Graduate Studies

It is the responsibility of the Office of Research Administration and Graduate Studies to:

ensure that Cost Sharing commitments are appropriately included (or not included) in Proposals in accordance with federal regulations, University Policies, and Sponsor policies and procedures;
ensure that funding for Cost Sharing is documented in writing prior to Proposal submission;
identify situations where an Award is significantly less than requested and work with the Principal Investigator/Project Director and Sponsor to determine whether any related Cost Sharing should be appropriately reduced; and
advise the Principal Investigator/Project Director and applicable administrative offices such as the Office of Grant and Contract Accounting and the appropriate department Chair, Dean, and Financial Business Manager of the existence and form of Cost Sharing associated with an accepted Award.

8. Roles and Responsibilities: Office of Grant and Contract Accounting

It is the responsibility of the Office of Grant and Contract Accounting to:

provide financial system set-up to accommodate Cost Sharing as evidenced in the budget and written, internal Cost Sharing agreement. This may be accomplished by a combination of establishing allocations for system-generated Cost Sharing entries, manual entries, and companion projects, in the case of extensive Cost Sharing;
maintain copies of signed invoices and other expenditure documentation in the Sponsored Project's accounting file;
screen Sponsored Project costs to ensure that costs are allowable and are categorized by the proper account code;
review recorded Cost Sharing for compliance with commitments; and
report Cost Sharing to Sponsors according to Sponsor requirements and the terms and conditions of Awards.

9. Related Policies, Procedures, and Guidelines

University Policy 10.1 Sponsored Research and Activities
University Policy 10.15 Sponsored Project Effort Reporting
Research Handbook

Appendix A: Definitions

“Award” means a Grant, subgrant, Contract, subcontract, or Cooperative Agreement that provides for Funding.

“Committed Cost Sharing” means a binding commitment of the University to provide resources for a Sponsored Project which the University must provide as part of the performance of the Award. Committed Cost Sharing may be Mandatory Cost Sharing or Voluntary Committed Cost Sharing. These costs must be documented and reported.

“Companion Project” means a separate project used to isolate costs that are not borne by the Sponsor. They may be funded by the University or a third party. A Companion Project may be used when Cost Sharing is extensive and/or related to specific items within a broader category.

"Contract" means a legally enforceable agreement between the University and a Sponsor that provides Funding when a primary purpose is delivery to the Sponsor of property or services for the benefit of the Sponsor, in addition to the research, educational, or service benefit to the University.

"Cooperative Agreement" means a legally enforceable agreement between the University and a Sponsor that provides Funding when substantial interaction between the Sponsor and the University is anticipated during the performance of the Sponsored Project.

“Cost Sharing” means that portion of the costs of a Sponsored Project not borne by the Sponsor. Cost Sharing may be in the form of direct costs (personnel or non-personnel) or F&A costs subject to a Sponsor’s restrictions. Cost Sharing may be In-Kind, Matching, Mandatory Cost Sharing, Voluntary Committed Cost Sharing, Committed Cost Sharing, or Voluntary Uncommitted Cost Sharing. These costs are borne by the University or other third parties (including non-federal third parties in the case of a federal Award), rather than by the Sponsor. Since faculty salaries at the University are usually paid for by a faculty member’s or staff member’s department, Cost Sharing of Effort represents a redirection of departmental resources from teaching or other departmental activities to support a Sponsored Project.

“Effort” means the time spent on Sponsored Projects and all other activities for which an individual is compensated by the University. Effort on a Sponsored Project is expressed as a percentage of the individual’s Total University Effort and includes the time spent working on the Sponsored Project to which salary is directly charged or contributed as Cost Sharing.

“F&A Costs” means facilities and administrative costs. F&A costs are also referred to as “indirect costs”.

“Funding” means financial support for a Sponsored Project, including money, property, services, or anything of value in lieu of money.

“IDC” means indirect costs. See F&A Costs.

“In-kind” means the value of non-cash, third-party contributions (i.e., property or services) that directly benefit and are specifically identifiable to a Sponsored Project.

“Mandatory Cost Sharing” means Cost Sharing that a Sponsor requires the University to provide as a condition of obtaining an Award. It must be included or a Proposal will receive no consideration for Funding by the Sponsor.

“Matching” is synonymous with “Cost Sharing”.

"Principal Investigator/Project Director” means the individual solely responsible for technical conduct of a Sponsored Project, technical contact with the Sponsor, expenditure of Sponsored Project Funding, and fulfillment of technical performance and reporting obligations under an Award. "Principal Investigator” (PI) includes an individual designated in an Award as "Project Director" (PD), when performing the functions of a Principal Investigator, or other individuals performing the functions of a Principal Investigator. For the period of the Award, the Principal Investigator/Project Director must be a full-time employee (staff, tenured or, tenure track faculty, Research Professor, Research Associate Professor, Research Assistant Professor, or, if approved by the Provost or his or her designee, a non-tenure track, non-tenure eligible faculty member) appointed pursuant to University Policy 2.3, Faculty Ranks, Academic Titles, and Voting Rights.

“Proposal” means the document submitted to a Sponsor requesting Funding for a Sponsored Project which includes, without limitation, (i) Financial Obligations, Regulatory Obligations, Reporting Obligations or Accounting Obligations, as described under “Sponsored Projects”, (ii) a Statement of Work and (iii) a budget.

“Research Handbook” is a document maintained by the Office of Research and Graduate Studies specifying current procedures and requirements for the proposal, acceptance, execution, and oversight of Sponsored Projects.

"Sponsor” means any external entity that provides Funding to the University. Sponsors may be (i) governmental agencies (for example, federal, state or local governments, or their administrative organizations); (ii) nonprofit organizations (for example, universities, nonprofit corporations, foundations, or associations); (iii) for profit organizations (for example, corporations, partnerships, sole proprietorships, and other business entities); or (iv) individuals.

"Sponsored Projects” means all projects, programs, research, training, public service and other activities that receive external Funding through Grants to the University or through Contracts or Cooperative Agreements between the University and a Sponsor, where one or more of the following obligations applies:

Financial Obligation. The University is required to comply with conditions imposed when a Sponsor awards Funding for the performance of services or delivery of products described in a Statement of Work;
Regulatory Obligation. The University is required to comply with Sponsor regulations.
Reporting Obligation. The University is required to provide to the Sponsor technical performance reports or regulatory or administrative reports; or
Accounting Obligation. The University is required to establish a separate accounting record of Sponsored Project expenditures to demonstrate allowability of costs, to maintain financial accountability, to make financial reports to the Sponsor, and to preserve appropriate records for audit.

“Statement of Work” means the component of a Proposal or an Award that describes the specific work to be undertaken and the products that will be produced by the Sponsored Project.

“Total University Effort” is defined as all activity for which the University compensates an individual, whether on a full-time or part-time basis, including students who are working as teaching or Research Assistants.

“University Policies” means, for the purposes of this policy, all University Policies included in the University Policy Manual and all other procedures, guidelines, and requirements of the Office of Research and Graduate Studies and the Office of Grant and Contract Accounting included in the Research Handbook, and the procedures, guidelines, and requirements of all University colleges, schools, departments, centers, institutes, and divisions.

“Voluntary Committed Cost Sharing” represents quantified University resources offered in the Proposal by the University when the Sponsor does not require a specific contribution.

“Voluntary Uncommitted Cost Sharing” is defined as Effort by University faculty (including senior researchers) that is over and above that which is committed and budgeted for in an Award.

“Waiver of IDC Form” means the form providing for the waiver of indirect costs.

Revised: December 16, 2019

Adopted: January 15, 2015

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