EMU Research
Cost Sharing
PURPOSE: The purpose of these guidelines is to ensure that all cost share proposed in grant applications complies with the requirements set forth in federal cost sharing regulations (OMB Circulars A-110 and A-21). Following is guidance pertaining to the circumstances in which cost sharing is permitted by EMU and the types of expenditures and assets that can be proposed. In addition, it provides information about the implications that arise when committing cost sharing to a project. In this guidance, "grant" applies to both grants and cooperative agreements received to support sponsored activity. Cost sharing is not generally appropriate for contracted research, particularly with private industry.
DEFINITION: Cost sharing occurs when an item of cost specifically benefits the sponsored project, but is not charged against the grant budget. At times the University will direct resources, either in-kind or committed cash, towards the objectives of a grant-funded project. Cost share, just like grant funds, are subject to audit.
Cost share for all grants must be:
- Verifiable by EMU's financial records
- Necessary and reasonable for proper and efficient accomplishment of project or program objectives
- Allowable under the terms and conditions of the Sponsor
In cases of federal grants, cost share:
- Cannot be paid with federal funds under another award, except where specifically authorized by federal statute
- Cannot be included as cost sharing for any other federally-funded project or program
- Must be included in the approved budget when cost sharing is required by the federal sponsor
- Must conform with cost sharing provisions of OMB Circulars A-110 and A-21
Types of Cost Share
Cost sharing includes three types:
- Mandatory Cost Sharing/Matching
- Voluntary Committed Cost Sharing
- Voluntary Uncommitted Cost Sharing
Mandatory Cost Sharing:
- Is required by the sponsor as a matter of statute, regulation, or policy
- Is required by the individual solicitation/program guidelines
Voluntary Committed Cost Sharing:
Is not required by the sponsor, but proposed by the applicant to demonstrate institutional commitment. An example of voluntary committed cost sharing is when the University commits academic year faculty effort reflecting a commensurate portion of faculty salary and corresponding fringe benefits in the budget that is submitted to the sponsor.
Voluntary Uncommitted Cost Sharing:
Is effort above and beyond the effort committed and budgeted for a sponsored project. It is not required by the sponsor, nor offered in a proposed budget by the University. It is not monitored by the University and often is the result of executing a project, as actual effort to carry out the project is greater than what was proposed.
PRACTICE: The University has a long-standing practice of meeting published mandatory cost sharing requirements. Meeting mandatory cost sharing requirements often comes from a mix of in-kind and cash contributions and includes faculty time, graduate assistant tuition remission, and ORDA cash matching funds. Voluntary committed cost sharing, however, limits the University's ability to maximize its reimbursement of grant related costs, restricting its ability to support continued growth of faculty research and scholarly activity.
Both mandatory and voluntary committed cost sharing is included in the denominator base of the Facilities & Administrative cost rate calculation. By increasing this base with cost share, the overall F&A rate is essentially driven down, again, limiting the University's ability to make continued investment in the research enterprise. Voluntary committed cost share should, therefore, be offered only when competitive forces and the institutional benefit of receiving an award warrant the commitment.
Cash and In-kind Contributions
Cost share includes both in-kind contributions, as well as cash contributions. In-kind contributions are costs that provide real value to a sponsored project, but do not require a cash outlay by the University. Items of cost the University would incur regardless of receiving an award that are directed to the benefit of a grant project are considered in-kind contributions. It may include:
Personnel Costs:
- Salaries and related fringe benefits for existing personnel, either faculty or other project personnel who hold existing positions with the University
- Laboratory Supplies
- Travel Expenses
- Equipment
- Tuition Remission
- Third party contributions
- Unrecovered F&A costs when prior approval from the awarding federal agency is provided
Cash contributions may come from the following sources:
- gifts
- endowments income
- unrestricted departmental/college funds
- ORDA cash match funds: cash match funds are generally not used to support academic year salary support.
Items that are not appropriate to use as cost share are:
- items of cost pledged as cost share for another funded project
- costs funded by other federal grants
- overages on grants (unallowable under OMB A-21)
- unfunded salary for effort that extends beyond the contractual appointment period, (i.e., unfunded summer months for faculty)
- costs that are not necessary, or reasonable for the efficient accomplishment of the project
- all costs that are not allowed under the terms of the grant
DOCUMENTING COST SHARE:
It is essential that the proposal clearly describe how cost shared items are necessary and reasonable for the proper and efficient accomplishment of the project. All cost sharing must be verifiable within the University's financial system and thoroughly documented. Records pertaining to cost sharing must be retained the same period as the financial records for the grant. This generally is three (3) years following the submission of the final financial report, or completion of an audit, but may be longer.
All committed cost share, both, mandatory or voluntary, becomes an official part of the award package. It is essential that it be documented in the budget justification of the proposal, as well as included in the internal budget detail.
COST SHARE COMMITMENT APPROVALS:
Cost share commitments by the University are documented and approved through the ORDA Transmittal process. Prior to submitting a proposal, a Transmittal is prepared and circulated for review and approval by the Principal Investigator's department, college, and others at the University who are committing resources to the project.
Departmental Approval:
A faculty member's Department Head approves any cost sharing of faculty or departmental salary, as well as any in-kind contributions such as supplies and materials, or assigning a departmental Graduate Assistant to a grant at the time of proposal.
College Approval:
The College approves any commitment of its resources to a project, such as space, new faculty lines, or funds for equipment from its budget at the time of proposal.
Office of Research Development:
ORDA approves any commitment of University matching funds from its cash match fund at the time of proposal.
Third-Party Contributions:
Prior to submitting a proposal that includes third-party contributions, a letter of commitment that identifies the items to be cost shared, assigns a value to those costs, and is signed by an authorized representative of the collaborating institution must be received by the University.
JUSTIFYING THE NEED FOR COST SHARING:
