- GAP 200.140, Cost Sharing on Sponsored Projects
GAP 200.140, Cost Sharing on Sponsored Projects
GAP 200.140, Cost Sharing on Sponsored Projects
Federal awards issued prior to December 26, 2014 should be managed in accordance with OMB Circulars A-21, A-110, and A-133. Federal awards issued on or after December 26, 2014 should be managed in accordance with 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance). It is important to verify the appropriate regulations applicable to your award. Documentation of appropriate regulations may be found in the Award Notice issued by the funding agency.
These guidelines pertain to Federally sponsored projects and should be used as guidance for all sponsors unless specifically addressed in a non-Federal sponsor’s policies and/or procedures.
This GAP supersedes previous GAP versions, Duke Policies, Guidelines, etc. Unless otherwise noted, this GAP applies to all sponsored projects, unless superseded by guidelines from Non-Federal sponsors.
The purpose of this GAP is to define cost sharing and outline how cost sharing will be captured within the Duke General Ledger. The process for cost sharing on sponsored projects reflects guidance outlined in OMB Circular A-110, section c.23 as well as in the Uniform Guidance, 2CFR§200.306. Each Federal sponsor may have additional cost sharing requirements or restrictions, which must be followed.
This procedure has been developed to ensure that “cost sharing” on sponsored projects is proposed, accounted for and reported in a manner consistent with requirements set forth by Duke University, federal regulations (Office of Management and Budget (OMB) Circulars A-110, A-21, and 2 CFR Part 200: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (The Uniform Guidance)), and sponsoring agencies. Regardless of source of funding, Federal guidelines are used for cost sharing. (Any example using the Federal Government as a sponsor applies also to non-federal sponsors.)
Note that federal sponsors recognize cost sharing commitments when quantifiable financial commitments are included in any part of the proposal, not solely the budget and justification. Please note, if at any time quantifiable commitment (i.e., measureable commitment that can be tracked) is included in any document submitted to a Federal agency in the proposal package – Scope of Work, Budget, Budget Justification/Narrative, Letters of Support, etc. – this commitment becomes voluntary committed cost sharing and must be documented in university systems and the financial commitment must be met. Departments should be careful to not inadvertently commit to voluntary committed cost sharing. Principal Investigators (PI's) certify expenditure statements for cost sharing activities/accounts in the same manner as for direct project expenditures. PI's are responsible for ensuring that cost-sharing commitments are met.
For both mandatory and voluntary committed cost sharing, when an award is received in which cost sharing was proposed and is noted in the award document, the cost sharing becomes a binding commitment that the University must provide as part of the performance of the sponsored project.
Cost sharing has a significant financial impact on the department providing the funds and on the University as a whole. Therefore, Duke University and the Federal Government do not support voluntary committed cost-sharing unless required by the Federal sponsor. On all grant and contract proposals, no cost sharing commitments may be submitted unless specifically approved as outlined in Section IV of this procedure.
All allowable costs, as set forth in the applicable Federal cost principles, incurred by a recipient and the value of the contributions made by third parties in accomplishing the objectives of the award during the project period.
The recipient's cash outlay, including the outlay of money contributed to the recipient by non-Federal third parties.
In-Kind Contributions are the value of non-cash contributions provided in support of the project by third-parties. These contributions may be in the form of real property, equipment, supplies and other expendable property, and the value of goods and services directly benefiting and specifically identifiable to the project or program. Values for non-Federal entity contributions of services and property must be established in accordance with the cost principles in OMB Circular A-21 and/or the Uniform Guidance Cost Principles Subpart E.
Cost sharing or matching means the portion of a project costs not paid by Federal funds (unless otherwise authorized by Federal statute). Only allowable costs can be cost shared. Unallowable expenses cannot, by definition, be cost shared.
The following are types of cost sharing:
Committed Cost Sharing
- Mandatory Committed Cost Sharing:
The portion of the University's contribution to a sponsored project which is required by the terms of the project. It must be included or a proposal will receive no consideration by the sponsor.
- Voluntary Committed Cost Sharing:
Under Federal research proposals, voluntary committed cost sharing cannot be used as a factor during the merit review of applications or proposals, but may be considered if it is both in accordance with Federal awarding agency regulations and clearly specified in a notice of funding opportunity. Criteria for considering voluntary committed cost sharing and any other program policy factors that may be used to determine who may receive a Federal award must be explicitly described in the notice of funding opportunity.
- Voluntary committed cost sharing should not occur. It refers to cost sharing specifically pledged on a voluntary basis in the proposal’s budget or the Federal award on the part of the non-Federal entity and that becomes a binding requirement of Federal award. For all Federal awards, mandatory cost sharing and voluntary committed cost sharing or matching funds and all contributions, including cash and third party in-kind contributions, must be accounted for as part of the non-Federal entity's cost sharing or matching reporting when such contributions meet all of the following criteria:
- Are verifiable from the non-Federal entity's records;
- Are not included as contributions for any other Federal award;
- Are necessary and reasonable for accomplishment of project or program objectives;
- Are allowable;
- Are not paid by the Federal Government under another Federal award, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs; and
- Are provided for in the approved budget when required by the Federal awarding agency.
Unrecovered indirect costs, including indirect costs on cost sharing or matching may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency. Unrecovered indirect cost means the difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the non-Federal entity's approved negotiated indirect cost rate.
Uncommitted Cost Sharing
- Voluntary Uncommitted Cost Sharing (VUCS):
Uncommitted cost sharing can only be voluntary. VUCS occurs when faculty and/or senior researchers donate effort to sponsored agreements above and beyond that which is committed and budgeted for in a sponsored agreement as either sponsor paid or cost shared. Voluntary uncommitted cost sharing should be treated differently from committed effort and should not be included in the organized research base for computing the F&A rate or reflected in any allocation of F&A costs. It is not required to be tracked in effort reporting. Additional guidance on VUCS is provided by Memoranda 01-06 (M-01-06) issued by the Office of Management and Budget.
Duke’s policy is that cost sharing will not be committed on federal projects unless required in writing by the federal sponsor. Should the sponsor ask for cost sharing, contact your pre-award office as the Uniform Guidance states that federal agencies may not require cost sharing as a factor in merit considerations during proposal review.
Exceptions to inclusion of cost sharing on a sponsored program application must be approved by either:
- SOM/SON Management Center for proposals submitted by the School of Medicine (SOM) and School of Nursing (SON),
- Office of Research Support and/or Vice Provost for Research and/or designee for proposals by University/Campus departments
All expenses to be cost shared are originally charged to the sponsored project's code. The sponsored project's code is then credited for the cost shared amount. On cost sharing of salaries, equipment, and other direct costs, the cost shared amount is charged to a non-federal cost object of the department.
The following expenses cannot be offered as cost sharing commitments in sponsored project proposals:
- Administrative salaries, services and supplies that are not appropriate as direct costs, as stated in OMB Circular A-21section F.6.(b) or 2CFR §200.420. For guidance see GAP 200.320, Direct Costing on Sponsored Projects.
- Unallowable costs, for guidance see GAP 200.320, Direct Costing on Sponsored Projects.
- University facilities such as laboratory space. PI's should take care in preparing proposals for sponsored projects not to commit use of facilities as cost sharing, but rather to characterize the facilities as "available for the performance of the sponsored agreement at no direct cost to the project."
- Depreciation on equipment.
- Cost sharing over the salary cap.
The Principal Investigator is responsible for accumulating the data necessary to provide proof of any cost sharing which is received in-kind.
- Complete a Duke University In-Kind Cost Sharing Report
The report should include the value of in-kind contributions. These reports should be prepared each month and sent to the Office of Sponsored Programs for inclusion in the financial reports and billings.
Note: This guidance is administrative in nature and is not a cost reimbursement policy. Failure to comply may or may not result in adjustments of charges to the award. Noncompliance with this policy does not mean this cost is unallowable from an external perspective. Any adjustments of charges will be as required under applicable federal cost reimbursement principles. If a cost is removed from an award for any reason, whether or not related to this guidance, the cost will generally be charged to departmental funds.