Q. What is Cost Sharing?
A. A portion of total sponsored project/program costs not funded by the sponsor. For additional guidance on Federal regulations please see the link to the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
Q. Why is Cost Sharing at Brown University discouraged when not required by the sponsor?
A. Cost Sharing reduces the University’s ability to maximize its reimbursement from external sponsors. In addition, there are negative F&A calculation and administrative impacts when committing cost sharing. Click HERE to view the Cost Sharing on Sponsored Projects Policy for detail information on the impact of cost sharing to the University.
Q. How do I know whether cost sharing is required?
A. Cost sharing requirements are explicitly stated in the Request for Proposals (RFP), the program guidelines, program announcement (PA), etc. This information is also frequently found in a “Special Instructions” section, or in the budget guidelines of the proposal-preparation section.
Q. Why does the University need to track cost sharing?
A. Federal regulations require full accountability for costs committed in the fulfillment of sponsored projects. Cost Accounting Standards require that costs proposed on a sponsored projects application be accumulated and reported on completely and accurately.
Q. Which expenditures are allowable for cost sharing?
A. Cost sharing expenditures must satisfy all of the following criteria:
Are necessary and reasonable for proper and efficient accomplishment of project objectives.
Are allowable, allocable, reasonable, and consistently treated under applicable federal costs principles.
Are incurred during the effective dates of the grant or during the pre-award phase when authorized by the sponsor.
Are verifiable from the official University records.
Are not included as contributions for any other federally assisted project.
Are not paid by the Federal Government under another award, except where authorized by federal statute to be used for cost sharing.
Unrecovered indirect costs may be included as part of cost sharing with the prior approval of the Federal awarding agency.
Q. Which costs are not acceptable as cost sharing?
A. The following costs may not be proposed as Cost Sharing:
Costs not deemed to be necessary and reasonable for the proper and efficient accomplishment of project objectives.
Costs that are included and reimbursed through the F&A rate (administrative salaries, office supplies, library expenses, and operations and maintenance expenses).
Costs pledged as Cost Sharing for another funded project.
Costs funded by other sponsored programs.
Costs considered unallowable by the University, the Sponsor, or under Uniform Guidance.
Q. What is the difference between “mandatory” and “voluntary” cost sharing?
A. Mandatory cost sharing is required by the sponsor as a condition of the award. Ordinarily this requirement will be indicated in the program announcement. Voluntary cost sharing is not required by the sponsor but is nevertheless offered in the proposal by the investigator; ordinarily in the form of contributed effort. Cost sharing that is included in the proposal voluntarily by the investigator becomes mandatory (or also known as 'voluntary committed' cost sharing) once the award is made. All committed cost sharing, whether mandatory or voluntary committed, must be accounted for and tracked.
Q. Why does proposed mandatory cost sharing require approval by the responsible official before the proposal is submitted?
A. The responsible official’s signature is required to ensure cost sharing commitment is secured prior to submission of the proposal.
Q. What is “Third Party in-kind” contribution/cost sharing?
A. A non-cash contribution to a sponsored project or program provided by a party other than either Brown University or the primary sponsoring agency. Third-party in-kind contributions may be in the form of goods, services, real property, equipment, supplies or other expendable property directly benefiting and specifically designated for the project or program.
Q. Can salary which exceeds a sponsor’s salary cap be used to meet cost sharing requirement?
A. No, unless prior approval is obtained from the sponsor.
Q. Can salaries and fringe benefits be cost shared?
A. Yes, but it depends on several two factors. First, a time commitment to the project for the individual has to be estimated. Second the salaries and fringe benefits have to be calculated for that individual based upon the FTE committed.
Q. How do I cost share salaries and fringe benefits in Workday?
A. Please refer to the Cost Sharing Reference Guide maintained by the Controller's Office.
Q. Can other federal grant funds be used as a source of cost sharing on a federal grant?
A. No, federal dollars cannot be used to cost share on a federal grant proposal, except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs. Also note that federal funds that “pass-through” another state agency are still considered federal funds and cannot be used for cost share.
Q. What happens if I cannot meet my cost sharing commitment as originally expected/proposed?
A. If the project includes a requirement for cost sharing, it is important that the account is monitored closely to ensure that the PI meets those requirements. If there is a concern that the PI will be unable to meet the committed amount, it is essential that the sponsor is contacted as soon as possible to request approval for a budget modification or an amendment to the award. Your OSP pre-award contact should be involved in this communication. If you have not met the cost sharing requirements, and the sponsor is unwilling to renegotiate the amount, it is likely that the funds provided by the sponsor will be reduced by the percentage the shortfall represents. Not meeting the cost-sharing requirement puts the project at risk of being deemed non-compliant by the sponsor and may require the University to have to return the funding. Every effort should be made to meet the obligated amount using start up/discretionary funds, unrestricted monies, and/or any appropriate non-federal grants.
Q. Is prior approval required from a federal sponsor before using a federal award as cost-share on a non-federal proposal?
A. Uniform Guidance specifically states-“All contributions, including cash and third party in-kind, shall be accepted as part of the recipient’s cost sharing or matching when such contributions meet all of the following criteria.
Are verifiable from the recipient’s records.
Are not included as contributions for any other federally-assisted project or program.
Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
Are allowable under the applicable cost principles.
Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
Are provided for in the approved budget when required by the Federal awarding agency.
Conform to other provisions of this part, as applicable.