Research Policy Analysis and Coordination
5-300 Types of Cost Sharing/Matching
5-310 Mandatory Cost SharingMandatory cost sharing/matching refers to that portion of the University contribution to a sponsored project which is required by the terms of the project’s Request for Proposal or Application (RFP/RFA). By accepting an award with mandatory cost sharing, the University incurs an obligation to document its financial contributions to the sponsored project. Reporting also may be required. Campus Contracts and Grants Officers should carefully review all proposals and awards to make sure that any cost sharing requirements are consistent with agency and University policies and appropriate for the value of the project to the University.
Unless there is specific statutory requirements for cost sharing, federal sponsoring agencies should not require cost participation by educational institutions engaged in federal research projects if:
- The particular research objective or scope of the effort for the project is specified by the federal government rather than proposed by the institution. This would apply to solicited proposals, but not unsolicited proposals; or
- The research effort has only minor relevance to the non-federal activities of the performing institution and the institution is proposing to undertake the research primarily as a service to the government.
Awards from for-profit sponsors should not require mandatory cost sharing. However, in cases where this is appropriate, campus Contract and Grant Officers should refer to sections 8-637 and 11-341 of this Manual for a summary of sponsor patent rights applicable to agreements with for-profit sponsors with regard to whether the for-profit sponsor has paid the full cost of an extramurally funded project.
5-320 Voluntary Cost Sharing
Voluntary cost sharing refers to University-initiated contributions to a sponsored project. Voluntary cost sharing is discouraged under the University’s policy requiring full cost recovery for work conducted under extramural awards as it commits University resources and creates additional award administration documentation requirements. However, if a campus anticipates voluntary cost sharing at the time of proposal submission, it is appropriate to so inform the sponsor. If the proposed cost sharing amount is included in the award budget or the project narrative, the fulfillment of the cost sharing must be documented and reported as if it were mandatory cost sharing. The extent of voluntary cost sharing should be reasonable and prudent, considering the Principal Investigator's other commitments of time and University policy regarding full recovery of costs. As with mandatory cost sharing, voluntary cost sharing must be approved by individuals who have authority over the stated source of the cost sharing.
All proposals for federally supported research projects should be responsive to the applicable federal guidelines. However, any attempt by sponsoring federal agencies to impose arbitrary or unreasonably high cost contributions should be resisted.
5-330 Committed Cost Sharing/Matching
Committed cost sharing includes mandatory and voluntary cost sharing identified in the project proposal (in the proposed budget or in the project narrative). It represents a commitment by the University that must be fulfilled if the proposal is accepted as offered by the University and awarded by the sponsorBy accepting an award with committed cost sharing, the University also incurs an obligation to document the financial contribution provided to the sponsored project. Reporting may also be required by the sponsor. (See 5-500, Cost Sharing Records and Reports.) In addition, information on commitments must be identified for proper effort reporting and for F&A rate proposal development. (See 5-520.)
Should the awarded amount be reduced from the proposed amount, the committed cost sharing may need to be adjusted accordingly, particularly if the awarded budget reduction requires a change in the Scope of Work. Any reduced cost sharing should be correctly stated in the award.
5-340 Voluntary Uncommitted Cost Sharing
Voluntary uncommitted cost sharing refers to any effort of University faculty (and possibly senior researchers) beyond that which is committed and budgeted for in a sponsored agreement. Such voluntary uncommitted cost sharing is not included in either the proposal budget or the narrative. Unlike committed cost sharing, voluntary uncommitted cost sharing does not require documentation or reporting, and will not be included in the organized research base for computing the facilities and administrative (F&A) rate or reflected in allocation of F&A costs. Furthermore, such faculty and senior researchers’ effort is excluded from the effort reporting requirement in 2 CFR 220,
Cost Principles for Educational Institutions, (OMB Circular A-21) section J.10. (Also see: OMB Memorandum M-01-06, Clarification of OMB A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs.)