POLICY
STATEMENT #120
COST SHARING IN SPONSORED PROGRAMS
I.
INTRODUCTION
When
the University bears a portion of the costs of a
sponsored program or project (for example, by purchasing
equipment or supplies for the project from University
resources, or by committing faculty or staff effort
to the project at no cost to the sponsor) it is
considered “cost sharing.”
Cost
sharing may be either mandatory (when a sponsor
requires a certain portion of the costs to be paid
by University funds) or voluntary (when no such
requirement exists). Voluntary cost sharing may
be either committed (when a measurable resource
is offered, i.e., a specific percentage of an investigator’s
effort) or uncommitted (when the resource offered
can not be measured and, thus, not audited). When
the University receives a sponsored project award
in which either mandatory or voluntary committed
cost sharing is proposed, and the cost sharing becomes
part of a contractual commitment to the sponsor
of the project, then the cost sharing is a binding
commitment that the University must provide as part
of its performance of the obligations under the
sponsored agreement. The University must also provide
full documentation and an audit trail to demonstrate
that such resources were committed to the award.
Cost
sharing has programmatic, administrative, and financial
consequences for the University and, as a general
rule, is strongly discouraged unless specifically
required by the sponsor in the program announcement.
Voluntary committed cost sharing reduces the flexibility
principal investigators (PIs) have to conduct other
research because of possible conflicts of commitment;
increase the requirements for auditable recordkeeping;
and have an adverse effect on the University's recovery
of facilities and administrative (F&A) (indirect)
costs. The value of any voluntary committed cost
sharing by the University is added to the "research
base" in calculating the University's federal
F&A rate, so voluntary committed cost sharing
in most cases decreases the University’s F&A
recovery.
II.
POLICY
Explicit
commitments to cost share should not be included
in proposals unless specifically required by the
sponsor in the program announcement. This does not
mean that PIs should not spend time on research
projects for which they receive no salary from the
sponsor, nor does it mean that the University should
not contribute resources toward the performance
of projects funded externally. Rather, PIs should
describe their participation in research projects
in terms that do not commit them to specific percentages
of effort (salary) or to non-salary expenses.
III.
IMPLEMENTATION
The
Vice Chancellor for Research and Federal Relations
is responsible for this Policy. The Vice Chancellor
will work with deans and the Office of Sponsored
Programs in the Policy’s implementation and
daily management, and can provide assistance to
faculty in strengthening proposals while avoiding
unnecessary voluntary committed cost sharing. The
Vice Chancellor will also work with deans to define
acceptable levels of cost sharing in cases where
funding agency guidelines are ambiguous. All cost
sharing must be approved in advance by the appropriate
college dean and reported to the Vice Chancellor
via the proposal Internal Processing Forms.