M. Cost Sharing on Externally Sponsored Programs

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1.   Preamble

This University of New Hampshire (UNH) policy was created in order to provide guidance to faculty and staff concerning cost sharing commitments in externally funded programs, including:

1.1   Requirements for including cost sharing in proposals;

1.2   The management of cost sharing according to Federal requirements; and

1.3   The procedures to record cost-shared expenditures in UNH's financial system.

UNH is committed to supporting the sponsored activities of its faculty and staff but, in order to ensure that its cost sharing commitments do not overburden its resources, cost sharing should be limited to those situations where it is an eligibility requirement for a proposal submission or when the program description identifies it as a review criterion.

This policy addresses federal requirements for cost sharing. However, all cost sharing is subject to this policy, regardless of the project sponsor.

2.   Definitions

2.1   Cost sharing or matching means the portion of project costs not paid by a sponsor

2.1.1   Mandated cost sharing means cost sharing which is explicitly required, as reflected in the sponsor's notice of funding opportunity.

2.1.2   Voluntary cost sharing means cost sharing pledged on a voluntary basis in the proposal's budget that becomes a binding requirement of award.

2.1.3 Voluntary uncommitted cost sharing means faculty/senior researcher effort that is over and above that which is committed and budgeted for in a sponsored agreement.

2.2   Companion cost sharing funds are UNH account funds established for the purpose of budgeting, accumulating, and tracking the cost shared expenses associated with a particular sponsored program.

3.   Policy

3.1   Cost sharing must be proposed, managed, and accounted for in a correct and consistent manner. This includes understanding when cost sharing is appropriate, and accurately charging and reporting cost shared expenses.

3.2   Prior to submitting a proposal to a prospective sponsor, UNH formally reviews each potential offer of cost sharing and determines whether or not to approve the offer for inclusion in the proposal to the sponsor. To be proposed as cost sharing, costs generally must be

(1) be verifiable within UNH's accounting system and dated;

(2) be necessary and reasonable for proper and efficient accomplishment of program objectives;

(3) be allowable under a sponsor's terms and conditions, and cost principles, if applicable;

(4) be provided for in the sponsor approved budget;

(5) not be included as a contribution under another federal award; and

(6) not be paid using federal funds (except where the federal statue authorizing a program specificially provides that federal funds made available for such program can be applied to matching or cost sharing requirements of other federal programs).

3.3   Non-cash donations and contributions (i.e., services, materials, and equipments) must be valued according to federal requirements.

3.4   Companion UNH account funds for budgeting, accumulating, and tracking expenses cost shared on UNH awards, must be established contemporaneously with the award and funded promptly and regularly through the award project period.

4.   Cost Sharing Sources. Cost sharing sources may include:

4.1   Expenses funded from UNH accounts (e.g., educational and general funds);

4.2   Expenses funded from non-federal sponsored program accounts;

4.3   Program income related to the particular sponsored program when approved in advance by the sponsor;

4.4   Unrecovered F&A costs for the particular sponsored program, with UNH and sponsor prior approval;

4.5   Federally sponsored awards where authorized by Federal statute (very rare)

4.6   Cash and in-kind contributions from sources external to UNH, including volunteer services by professional and technical personnel, consultants, and other skilled and unskilled labor; and donated supplies and equipment.

5. Cost Sharing vs Institutional Support

The terms "cost sharing" and institutional support" are commonly used interchangeably even though their meanings are very different. Cost sharing as applied in a grant application is generally a documented, auditable commitment of funds to a specific project. Institutional support, on the other hand, is a description of the multiple ways in which the institution provides resources and infrastructure which make the proposed work feasible. Institutional support can be a very powerful tool in providing the desired “commitment” of the University to an investigator’s research plans without a formal cost sharing obligation. Institutional support may include the description of items such as

a) specialized core facilities (e.g., microscopy, imaging, research, computing,

b)  laboratory speace,

c) clinical resources, and

d) library resources

 


References:
For awards made prior to 12/26/14:
 

OMB Circular A-21:            

C.2.     Factors affecting allowability of cost.

 

C.3.     Reasonable costs.

 

C.4.     Allocable costs.

 

 J.        General Provisions for Selected Items of Cost

 

 

 

OMB Circular A-110: Subpart C,  .23.  Cost sharing or matching.
OMB Memoranda 01-06
UNH Policy on Program Income on Externally Sponsored Programs

 

For awards made or amended after 12/26/14
2 CFR 200
OMB Memoranda 01-06
 

Administrative Responsibility:    UNH Senior Vice Provost for Research
Effective Date: 7/1/95; revised 5/30/07 and 12/26/14

 

This page last updated Friday, March 16, 2012. For information on the adoption and effective dates of policies please see explanation on the OLPM Main Menu.