Cost Sharing Policy

I. Scope

This policy applies to all employees who propose to engage in or are engaged in Sponsored Programs, and to all Sponsored Programs (both federal and non-federal).

II. Policy Statement

III. Reason for the Policy

1. Maintain good stewardship of the university's limited resources for purposes that maximize mission impact.
2. Ensure that the university’s Sponsored Programs comply with the sponsor’s requirements
3. Provide clear direction to employees who propose to include Cost Sharing in Sponsored Program proposals

IV. Procedures 

1. Once a funding opportunity is identified that requires a cost share, the Project Investigator (PI) should ensure prior approvals from the Dean and the sponsor of the cost share, if not the host department.   The Sponsored Programs Office should review the opportunity to ensure that the cost share is required and that prior approvals are established.  If the cost share is secured from an entity outside of the institution, Business Affairs should review the cost share and ensure the proper documentation is established to formalize this sponsorship.
2. While all proposals are reviewed before submission, budgets containing cost shares must be carefully considered.  The review committee must verify that the cost share meets sponsor requirements, the funds are available for the proposed project (and not otherwise encumbered), and that the budget meets cost accounting principles. 
3. When the award is received, the cost share accounts must be set up according to cost accounting principles for eae of continuous monitoring.  Cost share funds must be designated and spent on the project only and used consistently and uniformly like the sponsor funds. The PI and Sponsored Programs Office will monitor the expenses regularly.  The Sponsored Programs Office will provide monthly and quarterly reports to the PI and coordinate with the PI, Dean, and Business Affairs to ensure the proper use of all project funds.  Business Affairs will oversee the balanced application of expenses to the sponsored funds and cost share funds and ensure that all transactions meet institutional policies and federal laws

V. Definitions

1. Sponsored Programs- Sponsored Programs include grants, cooperative agreements, and contracts.  These programs are temporary in nature.  Their scope of work, budget, and timeline are contractually agreed upon and the project is funded by a public or private sponsoring agency or foundation. 
2. Cost Sharing- costs of a project that are not covered by the sponsor and therefore must be provided by the institution.  These costs must be verifiable, allowable, allocable, incurred during the project period and subject to additional sponsor requirements.  Common forms of Cost Sharing include: 
   1. Institutional
      1. Payroll costs.
      2. Non-payroll costs such as equipment, supplies, travel, tuition, and unrecovered indirect costs.
   2. Third party
      1. Third party cash.
      2.  Third party in-kind services such as volunteers, employee time, donated/loaned facilities, equipment or supplies.  These costs can be difficult to document and verify.
3. Mandatory committed cost sharing- is required by the sponsor and must be documented throughout the life cycle of the award. 
4. Voluntary committed cost sharing- this type of cost share is not required by the sponsor, but committed by the university as part of a proposal.  During the award, the cost share must be documented and reported alongside the sponsored funds.
5. Voluntary uncommitted cost sharing- this type of cost share is provided by the university.  It is not required by the sponsor or committed within the proposal or award agreement.  These funds do not need to be documented or reported

VI. Sanctions

Mismanagement of Cost Sharing commitments or any aspect of a Sponsored Program could result in negative publicity for the university, audit findings, fines and penalties, return of funds to the sponsor, award termination, suspension, or debarment. Employees who engage in such mismanagement (intentional or not) face disciplinary action which may include termination of employment. Additionally, intentional mismanagement may result in criminal prosecution.

VII. Related Information

For federally sponsored programs, the Office of Management and Budget (OMB) provides cost management principles through the Uniform Guidance.  2 CFR 200.306 directs how cost sharing is to be managed on federally sponsored programs.