COST SHARING/IN-KIND CONTRIBUTIONS
The purpose of these guidelines is
to provide direction in proposing and budgeting cost sharing
for grants and contracts.
Cost Sharing Defined
When
federal statute or agency regulations require that the
University share in the cost of sponsored research projects,
the University’s contribution is referred to as “cost
sharing.” In general, cost sharing and matching represent
that portion of project or program costs not borne by the
sponsor (generally the federal government). Cost sharing can
be voluntary or mandatory (that is, required by means of a
statute or law), and can take the form of either cash
contributions or in-kind contributions.
Cash
Contributions represent the recipient’s (that is, Cal
State LA or UAS) cash outlay, including the money contributed
to the recipient by non-federal third parties.
In-kind
Contributions represent the value of all non-cash
contributions, including services and property, provided by
the recipient and/or non-federal third parties.
ORSP policy
is to dissuade Principal Investigators (PIs) from proposing
cost sharing to a sponsoring agency if it is not mandatory.
There are several reasons for this. First, when PIs offer
cost sharing to a sponsor that does not require it, they
reduce the funds available for other projects that do require
cost sharing. Second, by committing cost-sharing funds, the
University, UAS and the PI become responsible for securing,
tracking and documenting all cost-sharing commitments.
Accurate accounting of these commitments is necessary to meet
annual audit requirements, and these commitments may become
audit concerns if not addressed properly. It is
time-consuming and expensive to document these cost-sharing
commitments. Finally, certain faculty members who have many
awards that include salary cost sharing may become
over-committed, resulting in an inability to substantiate the
promised levels of support.
Mandatory
cost sharing is usually specified in a sponsor’s program
guidelines. PIs are responsible for securing and negotiating
all mandatory cost sharing. ORSP will assist PIs in the
interpretation of cost-sharing requirements and ensure that
program guidelines are satisfied. ORSP will also instruct the
PI regarding the documentation needed to support all on-campus
and off-campus cost-sharing proposals.
1. Items
that may be Cost Shared:
Cost sharing or matching may
consist of the following cost elements used to further project
objectives:
1.
Salaries of faculty or staff who are paid by the
University, and who devote a percentage of their compensated
time to a sponsored project, without receiving reimbursement
from the sponsor. Cost sharing a faculty member’s personal
time is not allowed.
2.
Facilities and Administrative costs (F&A) that the
University has not recovered. In the event that the sponsoring
agency has a maximum F&A rate that is lower than our federally
negotiated F&A rate, the University is entitled to cost share
the unrecovered indirect costs if the funding agency allows
it.
3.
Space not included in the calculation of the F&A rate
that is usually rented space. For auditing purposes, it is
best to cost share space when there is less than full recovery
of F&A costs.
4. Other direct costs, such as
supplies, equipment, or travel that are paid from
non-federal funding
sources.
5.
Third party or external contributions to a project
(e.g., non-federal public agencies and institutions, private
organizations, and individuals). All third-party or external
contributions should be secured prior to the submission of a
proposal or the execution of a contract. If third-party cost
sharing is proposed but not yet secured, then the PI must
submit to ORSP a legally-binding statement from the
third-party contributor, committing the contributor to the
cost-sharing amount if the proposal is funded. In this case,
the PI must also ensure that the third-party contributor’s
budget estimates are presented in a line-item budget that is
reasonable and justified.
All cost sharing contributions,
both cash and in-kind, must adhere to the following criteria,
as required by OMB Circular A-110. Cost sharing contributions
must be:
1.
Verifiable from the recipients’ records.
2.
Not included as contributions for any other federally
assisted project or programs.
3.
Necessary and reasonable for proper and efficient
completion of the project or program objectives.
4.
Allowable under the applicable cost principles (OMB
Circular A-21, or other sponsor regulations if the sponsor is
non-federal.)
5.
Not paid by the federal government under another award,
except where authorized by federal statute to be used for cost
sharing or matching.
6.
Provided for in the approved budget when required by
the sponsoring agency.
7.
Consistent with other provisions of Subpart C, Section
.23 of OMB Circular A-110.
2. Items that may not be Cost
Shared:
1.
Third-party cost sharing that is presented in aggregate
and not presented in a detailed, line-item budget.
2.
Third-party cost sharing that has not been presented
and signed by an authorized representative of the third-party.
3.
Space that has been used in the calculation of Cal
State L.A.’s F&A rate.
4.
Contributions from projects funded by the federal
government.
5.
Cost sharing that cannot be documented.
6. Cost sharing that is not
relevant to the project. |