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Policy No.: 6104
Effective Date: 06/27/02
Revised Date: 04/26/06
Reviewed Date: 01/17/13

Sponsored Project Cost Share Policy

Purpose

To establish policy for the funding, accounting and reporting of cost share requirements on sponsored projects.

Policy

The University of Nebraska Medical Center (UNMC) policy does not allow for voluntary committed cost sharing without prior approval of the Vice Chancellor of Research or designee.

Cost share committed on sponsored projects is to be limited to the minimum amount necessary to meet sponsors' requirements for the following reasons:

• Exceeding the sponsor’s mandated level for cost sharing rarely improves the likelihood of an award.
• Identifying, tracking and reporting of cost sharing increases administrative duties.
• Cost sharing salary reduces the amount of salary eligible to be recovered from external sponsors.
• Cost share commitments negatively impact negotiation of UNMC’s F&A rate.

The principal investigator is responsible for maintaining records of all project related costs, including cost share through the use of a cost share companion account.

Per federal regulations (OMB Circular A-110, Subpart C. 23) cost sharing must be accounted for through university financial records. To identify, track and report cost share commitment on sponsored projects, UNMC uses three mechanisms:

• UNMC Internal Budget: UNMC policy requires that the amount, category (e.g., salary, equipment) and type of cost share (i.e., mandatory or voluntary committed) and its funding source (i.e., cost center) be documented on UNMC’s internal budget.
• Cost Share Companion Account: UNMC policy requires that UNMC Procedures for Cost Sharing and Companion Accounts be established to document that:

• cost share commitments to the sponsored project were met
• funds used to meet matching requirements were used only once

Criteria for Determining Allowable Cost Share Expenses

In general, cost shared expenses must meet the same standards as expenses made using the sponsor's funds. In addition, cost-shared expenses must be:

• Determined allowable by sponsor policy and program guidelines
• Allowable under UNMC policy, per UNMC Policy 6100, Direct Costs.
• Verifiable in the UNMC’s accounting record
• Necessary and reasonable to efficiently achieve the objectives of the program
• Incurred during the effective period of the award

See also UNMC Policy 6100, Direct Costs.

Criteria for Determining Unallowable Cost Share Expenses

The following are examples of expenses which are not allowable as cost sharing:

• Costs associated with use of UNMC facilities
• Cost of using any item of equipment purchased with federal funds
• Expenses that are not directly connected with performance of the project
• Expenses that can not be verified in the project accounting records
• Resources committed as cost share for other projects
• Expenses recovered through the Facilities and Administrative Costs (F&A) paid by the sponsor
• UNMC IBS Salary in excess of NIH salary limitation level (NIH Salary Cap)

See UNMC Policy 6102, Institutional Base Salary Policy.

• Federal funds unless approved by sponsor

Other unallowable expenses are detailed in UNMC Policy 6103, Unallowable Expenses.

Definitions

Cost Sharing (also called matching) refers to the specific portion of the project or program costs not funded by the sponsor. Cost sharing occurs when a cost specifically benefits a sponsored project, but is not charged to the sponsor. Typically, cost sharing is a direct cost such as salary or equipment. If a sponsor limits F&A (indirect costs) eligible to be charged to a project, unrecovered F&A may be allowed as cost share if sponsor has approved. There are 3 types of cost sharing:

• Mandatory: Costs required by the terms of the award or by federal statute that the University must contribute toward the project as a component of the award. The two major categories include:

• Cash: Actual expenditure of funds (e.g. salaries, equipment, travel)
• Non-Cash (In-kind): Contributions to the project other than cash (e.g. effort of non-employee volunteers)

• Voluntary Committed: Cost associated with a project, identified in the proposal, yet not requested from the sponsor. Common examples include:

• Effort: A percentage effort (e.g., for faculty or senior researchers) included in a proposal budget or stated in the text of the proposal for which compensation is not requested; and
• Equipment: The purchase of equipment for the project that was identified in the proposal; however, funds were not requested of the sponsor.

• Voluntary Uncommitted: Cost associated with a project, not funded by the sponsor, and not identified in the proposal, or in any other communication to the sponsor as a commitment of the University. Includes:

• Effort of faculty or senior researchers that is beyond the effort committed and budgeted for in a sponsored agreement.

Effort: See also UNMC Policy 6105, Effort Reporting. To comply with OMB Circular A-21, J.10, principal investigators must commit some effort on each individual sponsored programs whether federal or non-federal, whether paid or not paid by the sponsor. Exceptions to this requirement include training grants, dissertation support, limited purpose awards (e.g., travel grants, conference support), or salary support provided by another funding source, such as career awards.

Additional Information

• Any questions about this policy should be referred to Financial Compliance and Cost Analysis.<
• OMB Circular A-21, “Cost Principles for Higher Education”
• OMB Circular A-110, “Uniform Administrative Requirements for Grant and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations"
• UNMC Procedures for Cost Sharing and Companion Accounts
• In-Kind (Third Party) Contribution Record Form
  

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