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GIM 21

Cost Share on Sponsored Programs

UNIVERSITY OF WASHINGTON

Office of Sponsored Programs/Grant and Contract Accounting

GRANTS INFORMATION MEMORANDUM 21

Effective December 26, 2014

Supersedes: GIM 21 (August 6, 2007)

This GIM is updated to conform to the Federal "Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards" (Uniform Guidance) effective December 26, 2014. This GIM applies to new awards and new funding for existing awards received on or after Dec 26, 2014.

For awards in existence prior to December 26, 2014 that have not received supplemental funding or are not otherwise subject to the Federal Uniform Guidance per sponsoring agency award terms and conditions, please refer to the Archived GIM 21.

Purpose

This GIM describes the University of Washington's policy for cost sharing on sponsored programs.

Background

Cost sharing on a sponsored program represents a commitment of payment of a portion of the costs of that sponsored program that are not paid or otherwise supported by that sponsor. Cost sharing can be from an internal University source or resources from a non-University source ("third party cost share.")

Cost sharing from departmental or school resources may result in the redirect of funds from instruction or other public activities to sponsored agreements. Cost sharing also creates additional administrative burden and compliance exposure.

Persons/Offices Affected

UW Principal Investigators and Departments, Divisions, Schools and Colleges, Grant & Contract Accounting (GCA), Management Accounting & Analysis (MAA), Office of Sponsored Programs (OSP).

University Policy

Cost sharing is discouraged due to the impact to the research base used in calculating Facilities and Administrative (F&A) cost rates, the administrative burden, and the potential redirect of University resources from other University activity.

The University will propose and/or provide cost sharing when required by a sponsor as delineated in a specific program announcement (mandatory cost sharing). Such cost sharing will be limited to the extent and in the manner so required.

The University may propose voluntary committed cost share when:

  1. It is a federally funded project (including when the originating funding is Federal) that uses cost share as a factor in the merit review of the proposal (voluntary committed cost sharing), but only to the extent it is both in accordance with federal awarding agency regulations and the criteria for considering voluntary committed cost sharing during merit review is made explicit in the notice of funding opportunity; or
  2. It is a non-federally funded project and allowed by the sponsor, to the extent permitted and necessary due to the competitive nature of the program (i.e., will be or was considered in the proposal evaluation process.)

Units proposing voluntary committed cost share outside of these two scenarios must ensure that a justification is provided, upon request, so that those approving cost share are adequately apprised of the reasoning for including in the proposal.

No form of cost sharing can be proposed or provided when prohibited by sponsor policies, nor can cost sharing be proposed or provided in violation of applicable law, including the Washington State Public Ethics Law, RCW 42.52.

All cost share, including cash and in-kind, must be approved for use by the entity that controls them, verified in official University records, and cannot represent contributions to other federally-assisted projects. All cost share must be allowable, reasonable and necessary costs to support the project and cannot be costs the sponsor has specifically disallowed. Cost share cannot be used or committed from another federal award, except where the federal statute authorizing a program specifically provides that federal funds made available for the program can be applied to cost sharing requirements of another Federal program.

The PI overseeing the project that contains cost share must institute processes to obtain, track, document, verify and approve cost share commitments throughout the life of the award on a periodic basis. Faculty effort cost share is tracked and verified through the electronic Faculty Effort Reporting System or eFECs every six months. Non-FEC cost share is reported to Grant and Contract Accounting (GCA) quarterly.

Because cost share is a binding requirement of the award, any unmet cost share at the end of the award period may lead to a reduction in the total awarded amount made by the sponsor or may result in the PI providing the commitment from other sources (even if unmet third-party cost share) in order to meet the cost share obligation and in order to close the sponsored program.

Central procedures for tracking cost sharing and related forms and systems shall be established by GCA and Management Accounting and Analysis (MAA).

Procedures and Guidance

Costs permissible as cost-share and limitations

Cost share process

Unmet cost-share

Sponsor salary cap

Concurrent effort

Roles and Responsibilities

Principal Investigator
Chair and Dean level reviewers
Office of Sponsored Programs (OSP)
Grant and Contract Accounting (GCA)
Management Accounting and Analysis (MAA)

Definitions

Concurrent effort (scientific overlap):
Effort funded under a career development award that represents effort that benefits another non-federal program and the goals of the project matches the goals of the career development award.
Cost Share Addendum:
Form used to gather cost-sharing information into categories, for use by GCA when entering the data into the cost share module.
Cost Sharing:
A commitment by an entity other than the sponsor to provide funding or support, regardless of source or form; provided however, de minimis effort is not, in and of itself, cost share to the extent such effort conforms to general University requirements, including effort reporting requirements and applicable law. Conditional commitments or sponsor permitted concurrent effort are not cost sharing.
Faculty Effort Calculator:
Tool used to calculate faculty effort, based on percent effort or dollar amount cost-share commitment. The calculation is then transferred to the faculty effort section of the Cost Share Addendum.
Federal Award/ Project:
An award to the University of any type (grant, contract, cooperative agreement) that is funded in whole or in part from a Federal appropriation, and that retains its character as a federal award in carrying out the activity.
Mandatory Cost Share:
Mandatory cost sharing represents a requirement by the sponsor for University participation in the costs of the supported activity. A cost sharing requirement may specify either a minimum fixed percentage of total project costs or a level of non-federal participation that has been negotiated between the University and the sponsor.
Voluntary Committed Cost Share:
A University contribution of effort or other costs not required by the sponsor as a condition of the award, which have been specifically pledged by quantifying in the proposal budget, budget justification, or narrative of the proposal. A common example of committed cost sharing is a faculty member identifying a percentage of their University effort on the budget page, budget justification, or narrative of their proposal without any corresponding request for funding of that effort.

Related Resources

SubjectDocument/Resource
Form to document detailed cost share information Cost Share Addendum
Cost Share Addendum and Instructions
Tool to calculate faculty effort cost share Faculty Effort Cost Share Calculator
Cost Share Reporting Procedures Grant and Contract Accounting Cost Share webpage
Third Party Cost Third Party Cost Share
Faculty Effort Reporting and Cost Share Management Accounting and Analysis Faculty Cost Share webpage

Contacts

Questions concerning the applicability of cost sharing requirements to a proposal should be directed to Office of Sponsored Programs, extension 3-4043.

Questions concerning post-award administration of cost share commitments should be directed to post award financial compliance at gcafco@uw.edu or extension 6-8678.

Faculty Effort Certification (FEC) questions should be directed to Management Accounting and Analysis at 5-7395.

Content Creator

Review Schedule

This policy is reviewed by the Office of Sponsored Programs and Grant and Contract Accounting as necessary to reflect changes in Federal regulation or University policies.