Cost Sharing Policy

Effective Date:

November 2012

Supersedes:

New Policy

Policy Review Date:

3 Years - From the effective date

Issuing Authority:

Research Foundation President

Responsible Party:

Garrett R. Sanders

Contact Information:

Vice President of Operations

518-434-7130

garrett.sanders@rfsuny.org

Reason for Policy

This document provides a statement of policy to: ensure compliance with the U.S. federal government requirements for Cost Sharing, and to provide The Research Foundation for The State University of New York ("RF") position on the use of Mandatory, Voluntary Committed, and Voluntary Uncommitted Cost Sharing.

The U.S. federal government requirements for cost sharing are primarily in Office of Management and Budget (OMB Circular A-110, "Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations", Section .23 Cost Sharing or Matching, OMB Circular A-21, "Cost Principles for Educational Institutions", Section J, and OMB Memoranda 01-06, "Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs", January 05, 2001.

In addition, sponsoring agencies, including non-federal sponsors, can identify agency and/or program specific cost sharing requirements in their proposal solicitations, program announcements, and award terms and conditions.

Statement of Policy

The RF must ensure that cost sharing requirements of sponsored agreements are proposed, accounted for, and reported in a manner consistent with the requirements of the sponsor and the RF. Federally funded projects must meet the requirements set forth in the OMB Circulars A-110 and A-21.

Special Consideration

Any cost sharing that is offered and documented in the proposal (e.g., budget/narrative) becomes a sponsor requirement in the award (e.g., terms and conditions) and a binding financial obligation of the campus.

For the use of Mandatory, Voluntary Committed, and Voluntary Uncommitted Cost Sharing, the following applies:

Responsibilities

The following table outlines the responsibilities for compliance with this Policy:

Responsible Party and Responsibility

The following responsibilities apply to the principal investigator:

  • Understand and apply the federal government, sponsor-specific, campus, and RF requirements for cost sharing on proposals/awards.Determine the acceptability for including the offer of cost sharing in external proposals to sponsors.
  • Understand that a cost sharing expenditure must meet the same requirements for cost criteria that apply to any direct or indirect cost expenditure made on an award.
  • Determine and provide the appropriate resources in relation to the proposal/award budget and project/scope-of-work.
  • Consider providing cost sharing only when it is mandatory – required by the sponsor in writing.
  • Evaluate providing voluntary cost sharing – based on the needs of the proposal/award, the project/scope-of-work, the critical factors associated with proposal competiveness for successful funding, and the available campus resources.

The following responsibilities apply to various other campus roles (e.g., deans, provosts, department chairs/directors/administrators, institutional officials, operations managers, vice presidents for research) depending on the campus specific structure:

  • Understand and apply the federal government, sponsor-specific, campus, and RF requirements for cost sharing on proposals/awards.
  • Determine the acceptability for including the offer of cost sharing in external proposals to sponsors.
  • Review and approve cost sharing offered in a proposal to ensure reasonableness with the allocation in relation to the budget and project/scope-of-work.
  • Ensure that cost sharing offered does not conflict with any cost sharing offered on other proposals/awards, and/or with the academic and other institutional responsibilities of the principal investigator.
  • Review and submit proposals and accept awards to ensure that cost sharing commitments are in accordance with the federal government requirements for cost criteria.

The following responsibilities apply to campus sponsored program offices (e.g., pre-award, account establishment, post award) depending on the campus specific structure:

  • Understand and apply the federal government, sponsor-specific, campus, and RF requirements for cost sharing on proposals/awards.
  • Develop a separate cost sharing budget for proposal submission.
  • Determine and apply the special considerations/recommendations for voluntary committed and voluntary uncommitted cost sharing, as appropriate.
  • Review and submit proposals and accept awards to ensure that cost sharing commitments are in accordance with the federal government requirements for cost criteria.
  • Document, monitor, and report cost sharing in accordance with the federal government requirements throughout the life of the award – and to ensure the cost sharing is met.

Cost Criteria

All cost sharing expenditures must follow the requirements as identified in OMB Circular A-21 and the other applicable federal government regulations. Cost sharing expenditures must meet the same requirements that apply to any direct or indirect cost expenditure made on an award. To determine if a cost sharing expenditure is appropriate the following cost criteria must be applied.

Allowable – The cost sharing expenditure must be allowable as specified by the federal government regulations and sponsoring agency.

Reasonable – The cost sharing expenditure must be reasonable: the nature of the goods or services acquired or applied, and the amount involved, must reflect the action that a prudent person would take under the circumstances prevailing at the time the decision to incur the cost was made.

Allocable – The cost sharing expenditure must be allocated to the sponsored award or activity based on the benefit derived, cause and effect, or other equitable relationship.

Definitions

Cost Sharing – Is that portion of a sponsored program budget that is contributed by the institution and/or other nonfederal sources – it is not reimbursed by the sponsor. For the purpose of this policy, in accordance with OMB Circular A-110, Cost Sharing also means "matching."

Mandatory Cost Sharing – Is Cost Sharing that is a required condition of an award or agreed to by the institution and sponsor during sponsored agreement negotiation.

Voluntary Committed Cost Sharing – Is Cost Sharing that is not required by the sponsor, but proposed in the budget or narrative with no corresponding sponsor funding requested or awarded.

Voluntary Uncommitted Cost Sharing – Is Cost Sharing that is over and above that which is identified and budgeted for in a proposal and award.

Related Information

OMB Circular A-110: Uniform Administrative Requirements for Grants and Agreements With Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations

OMB Circular A-21: Cost Principles for Educational Institutions

OMB Memoranda 01-06: Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs, January 05, 2001

Research Foundation: Cost Sharing: Guide for Administrators

State University of New York: Faculty Salary Recovery from Sponsored Programs (Document Number 1002)

Forms

None

Change History

Date

Summary of Change

November 7, 2012

New Policy

 

 

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