Purpose

To comply with the requirements of OMB Uniform Guidance (Section 200.306), the Research Foundation, CUNY has established a procedure to record and track cost share or matching funds on sponsored projects.

Applicability

This procedure applies to all sponsored programs administered by the Research Foundation, CUNY on behalf of the Colleges of The City University of New York.

Guidelines

Cost sharing is the portion of total costs (direct and indirect) of a sponsored research award that meets the following criteria:

  • It is not provided by the sponsor (i.e., the CUNY College has agreed to fund it).
  • It is included in the itemized costs of the project or program's budget that has been approved by the sponsor.

Cost sharing as defined above may be included in either of the following categories:

  • Mandatory Cost Sharing: Cost contribution required of the grantee by the sponsor as a condition of the award, such as the matching requirements of challenge awards.
  • Voluntary Committed Cost Sharing: Cost contribution voluntarily offered by the principal investigator and included in the program budget. Once accepted by the sponsor voluntary cost share becomes a binding commitment. According to Uniform Guidance (Section 200.306) “… voluntary committed cost sharing is not expected. It cannot be used as a factor during the merit review of applications or proposals…”

Costs may be disallowed and future funding jeopardized, if a CUNY college is called upon to demonstrate cost sharing to an agency and does not have the documentation to do so. 

Basic Considerations

Proposals for sponsored projects should not contain formal cost sharing commitments unless cost sharing is required (mandatory) by the sponsoring agency and stated as an eligibility criterion for the project for which funding is sought. Voluntary committed cost share is not allowed unless approved by CUNY’s Office for Research Administration. Voluntary committed cost share (a) causes an undue administrative burden; (b) requires the PI to maintain supporting documentation; (c) may be subject to audit and disallowance; and (d) may restrict the availability of faculty and use of College resources. Expenses incurred to meet cost sharing commitments bring the same accounting, financial, legal, and regulatory burdens as costs on sponsored programs.

Cost shared expenses must be in compliance with the following:

  • RFCUNY and University sponsored programs expenditure policies
  • Any additional terms specified by the sponsor
  • U.S. Federal agency guidelines or non-federal program guidelines, as appropriate
  • U.S. Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards

Effective January 1, 2011, the National Science Foundation has prohibited the inclusion of Voluntary Committed Cost sharing in proposals. Proposals which include voluntary committed cost sharing in the budget, justification or narrative "run the risk of the proposal being returned without review or declined."

Regulatory Requirements for Cost Sharing

To comply with OMB’s Uniform Guidance, cost sharing must meet all of the following criteria:

  • The cost sharing must be verifiable and auditable within the Research Foundation, CUNY or College’s records;
  • Cost share is not paid by the federal government under another award, except where authorized by federal statute to be used for cost sharing or matching;
  • The cost sharing is necessary and reasonable to accomplish program objectives; and
  • The cost must be incurred during the term of the agreement.

Required Approvals for Cost Sharing

The University limits cost sharing to that which is mandated by the sponsor. All proposed mandatory cost sharing arrangements must be approved by the responsible chair and/or dean before the proposal is submitted. Note: The PI should confer with the chair and/or dean regarding a cost share strategy to meet the sponsor’s requirements. When cost sharing appears on a proposal budget, the source, type and amount of funds should be identified.

The grants officer will maintain mandatory cost share approvals made by dean and department chairs. Committed cost sharing creates an obligation to the University and must be treated like any other contractual agreement. Cost sharing of direct expenditures represents a commitment of departmental, program, or University resources from teaching or some other University activity to support a sponsored project or program. Consequently, voluntary committed cost share is not allowed unless approved by the CUNY Office for Research Administration, Director of Sponsored Research and Compliance.

If a sponsor significantly reduces the award budget presented in the original proposal, it may be appropriate to request a reduction in the cost-sharing commitment as well.

Recording of Cost Share Transactions

All cost-shared expenditures must be verifiable to either the University’s or RFCUNY’s records. Costs financed by departmental budgets or any other non-federal fund source(s) may be claimed as a cost sharing contribution for a federal sponsored research award if they are directly identifiable with the applicable federal research award and are contributed during the performance period of the sponsored research award. Again, this depends upon how the cost sharing was proposed. Costs which duplicate the types of costs included in the Facilities and Administration Cost rate and costs which are charged to another federal sponsored research award cannot be used as cost sharing.

The most common cost share expenses are salaries, fringes, supplies, equipment and associated facilities and administrative costs. When cost sharing direct cost expenses the RFCUNY’s Grants & Contracts department will need the PI to complete a Cost Share Form and provide the account number (CUNY First Department or RFCUNY PRSY), if applicable, where cost share commitments will be met.

Sources of Cost Sharing

  • College tax levy funds
  • Unrecovered Facilities and Administration (F&A) costs, if approved by the sponsor
  • Third party contributions
  • Other sponsored projects (non-federal)

Cost Sharing Direct Costs

Faculty Effort or Research Staff Salary

PIs can commit to expend faculty or research staff effort on a sponsored program without charging commensurate salary to the sponsored fund. Such a commitment of effort binds the University to contribute research staff or faculty time to the project and to record salary expenditures, including fringe benefits, in a manner that makes the expenditure verifiable from University records. Like all committed effort, cost-shared faculty effort must be reported on a PAR.

Equipment

Equipment purchased with College resources cannot ordinarily be offered as cost sharing, if the depreciation of College-owned equipment is included in the University's indirect cost rates and the equipment was not purchased for use on the project. Rather than committing the use of College-owned equipment as cost sharing, proposals should characterize the equipment as "available for the performance of the sponsored agreement at no direct cost to the project." If, however, the purchase of equipment is necessary for the project or the sponsor mandates the purchase of equipment, then the acquisition cost of specific equipment may be offered as cost sharing. Purchase and acquisition must occur during the period of performance of the project, and procedures must be in place to ensure that the depreciation on such equipment is not included in the indirect cost rate calculation.

Other Direct Costs

Most other costs that could be charged (allowable, allocable, reasonable, and consistently treated) to a sponsored project can be cost-shared. The following are examples of other direct costs that may be cost-shared:

  • Laboratory supplies
  • Equipment items that do not meet capitalization thresholds

Indirect Costs (Facilities & Administrative Costs)

Indirect costs may be offered in a proposal to meet cost sharing requirements imposed by the sponsor, but they are not considered to be cost sharing in any other situations. There are three ways to cost-share indirect costs. Note that none of these cost-shared indirect costs are recorded in the University or RFCUNY’s General Ledgers - they will be calculated and reported manually by Grants & Contracts.

Unrecovered Overhead on Sponsored Expenditures

The amount of F&A not collected from the sponsor that could have been allocated to the direct costs paid by the sponsor of an award. Unrecovered overhead typically results from awards made by sponsors that do not pay the full negotiated F&A rate. For federal sponsors, Uniform Guidance section 200.306(c) indicates that "Unrecovered indirect costs may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency."

Overhead on Cost-Shared University Resources

The amount of F&A, calculated at the full negotiated F&A rate that would normally have been allocated to cost-shared direct costs funded by University resources.

Items Normally Considered Indirect

Some items normally considered indirect include depreciation, administrative support, and rent. For cost sharing on federal awards, costs typically deemed indirect represent a cost accounting standards (CAS) inconsistency and are therefore not allowed. For non- federal awards, however, the sponsor may allow items typically considered indirect to be offered as cost sharing.

Costs Not Acceptable as Cost Sharing

The following costs may not be used as cost sharing:

  • Costs pledged as cost sharing for another sponsored program or funded by other sponsored program, except where authorized by the sponsor;
  • Costs that are included and reimbursed through the F&A rate (administrative salaries, library expenses and operation and maintenance expenses); and
  • Costs representing salaries over regulatory caps, such as the NIH salary cap cannot be used to meet a cost sharing commitment.

Documentation of Cost Sharing

Proposal Stage

At the proposal stage, where there is a formal cost sharing commitment (mandatory or voluntary committed), the source(s) and amount of the cost sharing will be identified in the proposal budget and budget justification by the project investigator and/or grants officer.

Award Period

The project administrator will be responsible for coding the sponsored award in the Front End system with the Cost Share attribute Mandatory or Voluntary Committed when the approved award documentation from the sponsor received.

At a minimum, mandatory or voluntary committed cost share must be documented before fiscal year end and again at award closing. A cost share form must be prepared and certified by the principal investigator and authorized college official (dean/department chair) for each award with a cost sharing requirement. Email certification to the PA from the aforementioned authorized officials along with the completed cost share form is acceptable.

The cost share form will summarize the details of cost sharing on the award, including:

  • Dollar value requirement
  • Source of the cost sharing funds (including CUNY tax levy department number)
  • Cost sharing expense detail

Note: When a PI is going to cost share an employee's time on a sponsored research proposal, the PI will need to provide the name(s) of the employee(s) and dollar amount of their salary and fringes to be cost shared in the proposal and enter the amount of cost sharing on the Cost Share Form.

The project administrator will review the form for completeness and upload into the Front End system.

Post Award Stage

For awards that include committed cost sharing, the College is required to maintain documentation of the cost sharing. When reporting to sponsors is required, the terms of the award indicate the frequency of reports (generally, quarterly, semi-annually, annually and/or at end of the project). Grants officers will work with principal investigators to make sure that the necessary cost sharing documentation has been maintained. When required by sponsors, formal cost sharing reports are certified by the PI and authorized college official (dean/department chair) and submitted by the project administrator.

Roles and Responsibilities

Principal Investigator

  • Ensure compliance with the cost sharing procedure
  • Identify cost sharing commitments in proposals
  • Obtain approval for cost sharing commitments from the Provost
  • Obtain certified and documented third-party contributions
  • Ensure that committed cost sharing effort is provided and documented on the Cost Share Form
  • Ensure that cost share match at the college is documented and readily available in the event of an audit

Grants Officer

  • Advise principal investigators and divisional administrators of the cost sharing requirements associated with particular grant or cooperative agreement programs
  • Review proposals prior to submission to ensure that formal cost sharing commitments are fully documented and that all necessary approvals have been obtained
  • As part of the award initiation process, inform principal investigators, divisional personnel and central administrative departments of the details of the cost sharing requirements associated with particular awards. Verify that cost share documentation is maintained at the College
  • As necessary, negotiate revisions to cost sharing requirements with sponsoring agencies

Grants & Contracts

  • Monitor award, in conjunction with the grants officer, to ensure that cost sharing requirements are met
  • Review Cost Share Form for mandatory and committed cost share components
  • Report cost sharing to sponsoring agencies as required
  • Inform principal investigators, appropriate college officials and sponsor if cost sharing requirements are not being met.

Cost Accountant/Financial Analyst

  • Ensure that cost sharing is correctly reflected in the College's indirect cost rate calculations