To comply with the requirements of OMB Uniform Guidance (Section 200.306), the Research Foundation of CUNY has established a procedure to record and track cost share or matching funds on sponsored projects.
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.
Cost sharing is the portion of total costs (direct and indirect) of a sponsored research award that meets the following criteria:
Cost sharing as defined above may be included in either of the following categories:
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.
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 of Research. 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:
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."
To comply with OMB’s Uniform Guidance, cost sharing must meet all of the following criteria:
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’s Office of Research, Director for Research and Sponsored Programs 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.
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.
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 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:
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.
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.
The following costs may not be used as cost sharing:
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.
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:
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.
Grants & Contracts
Cost Accountant/Financial Analyst