OFFICE OF RESEARCH AND PROJECTS
Effective:December 18, 2002
SIUE Policy on Cost Sharing
Regulations require the University to substantiate, through adequate records, cost sharing expenditures for
both direct and indirect (facilities and administrative) cost associated with all external grants and contracts.
The records must reflect that direct cost sharing expenditures are appropriate, necessary and incurred within
the related project period. Records must also provide evidence that the cost sharing expenditures incurred
in a particular fiscal year are included in the development of the University’s facilities and administrative
cost rate for the same fiscal year.
The SIUE Policy on Cost Sharing has been developed to ensure that the University remains in compliance
with State and Federal regulations governing cost sharing arrangements. This policy will enable the
University to recover the full amount of program or project costs that it expects to receive from Federal or
State sponsoring agencies.
Definition of Cost Sharing
The federal government through the Office of Management and Budget (OMB Circular A-110) “Uniform
Administrative Requirements for Grants and Contracts with Institutions of Higher Education and Other
Non-Profit Organizations has defined cost sharing as “that portion of project or program costs not borne by
the federal government.” Most State of Illinois agencies define cost sharing similarly and define cost
sharing in grants and contract agreements as project or program costs not borne by the state agency.
The Office of Management and Budget (OMB Circular A-21) “Cost Principals for Institutions of Higher
Education” defines specific categories of cost sharing as follows:
1.
Mandatory Cost Share
a) Mandated by law or regulation
b) Stated in program or project announcement
2.
Voluntary Committed Cost Share
a) Solicited or suggested in the program or project announcement
b) Cost sharing specifically pledged in the proposal’s budget or award by the institution
3.
Voluntary Uncommitted Cost Share
a) Faculty/senior researcher effort that is over and above that which is committed and
budgeted for in a sponsored agreement.
Cost sharing may be in the form of in-kind, cash or both.
In-kind may include the following cost elements:
a.
b.
c.
d.
e.
Salary and Wages
Employee Benefits
Other Expenses
Indirect Costs associated with direct costs listed above
Unrecovered indirect costs
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Cost sharing must be:
a.
b.
c.
d.
Directly identifiable with the project
Incurred during the period of performance of the award
Financed from non-federal funds
Meet OMB A-21 Cost Principal guidelines
Cash cost sharing contributions include:
1.
2.
Cash contributions from unrestricted accounts and/or third-party sources
Matching Funds – Cash contributions from unrestricted accounts and/or third party sources.
(Matching funds typically require a dollar-for-dollar ratio to qualify for funding)
OMB A-21 (Cost Principals for Institutions of Higher Education) requires that mandatory and voluntary
committed cost share be properly documented for cost accounting purposes. OMB A-21 also states that
faculty must properly document compensated effort for projects funded by the federal government and
private agencies/corporations in order for those costs to be properly allocated by salary and associated
Facilities and Administrative costs.
OMB A-21 states that voluntary uncommitted cost sharing should be treated differently from committed
effort and should not be included in the organized research base for computing the F&A rate or reflected in
any allocation of F&A costs. It also states that voluntary uncommitted cost sharing is excluded from the
effort reporting requirement in section J.8 of A-21 (General Provisions for Selected Items of
Costs/Compensation for Personnel Services) “ This treatment is consistent with the guidance in section
J.8.b (1). c, "Payroll Distribution," that a precise documentation of faculty effort is not always feasible, nor
is it expected, because of the inextricably intermingled functions performed by the faculty in an academic
setting (i.e., teaching, research, service and administration.)”
Policy
University policy requires that the Office of Research and Projects review agency program guidelines and
policy requirements to determine whether cost sharing is necessary. In instances where program guidelines
require a level of mandatory cost share and a commitment is made to cost share funds to a project, the
Dean, Department Chair and/or Director of the school or department must verify the availability of such
funds before submitting the proposal.
When a sponsor does not provide rules or guidelines that require cost sharing, but encourages it in writing,
the Dean and/or Director shall consult with the Dean or the Assistant Dean of Graduate Studies and
Research to determine if cost sharing is appropriate and, if so, at what level.
The principal investigator/project director’s academic unit should demonstrate its support of a proposed
project by providing resources either partially or in total of the cost share requirement. Other units’ central
to the university may provide some of the cost sharing requirements. An example would be that the Office
of Graduate Studies and Research might provide Graduate Student Tuition Waivers, State Matching Grant
Funds Program for Research Projects and Travel Awards. The Office of Graduate Studies and Research
and the Office of the Provost and Vice Chancellor for Academic Affairs will not provide additional cost
sharing funds for commitments in excess of the sponsor’s stated requirements.
The University permits faculty members to devote a reasonable portion of their time and effort, paid by the
University, to accomplish their extramural sponsored projects. The most appropriate cost sharing
contributions, for instance, are University funded salaries and wages, any applicable fringe benefits and
associated indirect costs for faculty and staff directly engaged in the sponsored project. Percentage of
effort devoted to a sponsored program must be reasonable. Total effort devoted to sponsored programs and
University-related duties may not exceed 100%.
When cost sharing is required and/or proposed on an award, the program or project budget will specifically
identify the source of University funds (budget purpose account numbers and name) that will be used to
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satisfy the cost sharing commitment on the Grant Proposal and Grant Acceptance Routing Form. Grant
accounts will not be activated and/or spending will not be permitted on an award until all cost sharing
resources are identified.
In order to identify and document cost sharing expenditures required under State and Federal grants, each
school or unit will establish a State (2) ledger cost share account which will clearly be identified as such in
the university’s financial accounting system and where cost sharing expenditures for each sponsored
program within that school or unit will be recorded. The school or department will be responsible for
maintaining separate records and supporting documentation of cost sharing expenditures posted in this
account for each sponsored program. Post award certification reports on cost share expended on each
sponsored program must be submitted to Research and Projects Fiscal Management on a quarterly basis
and/or at the conclusion of the sponsored project.
The University will not waive or reduce facilities and administrative costs (indirect costs) in order to meet
sponsor cost share requirements.
All cost sharing commitments are subject to audit and will require the appropriate documentation of cost
sharing commitments and expenditures in support of those commitments.
Responsibilities and Authority:
Principal Investigator/Project Director is responsible for securing all necessary cost sharing and
matching funds commitment from their academic units and the Office of Graduate Studies and Research in
accordance with federal and state requirements and funding agency program requirements. The Principal
Investigator/Project Director is also responsible for completing Faculty/Professional Staff Activity Reports
and identifying the sponsored program by account name and account number in the appropriate
“Professional Activity” area of the report and recording the appropriate level of effort devoted to the
sponsored program. He/she is also responsible for insuring that other faculty and project staff that are
compensated through the sponsored program record their level of effort devoted to the project on their
individual “Activity Reports” as described above. The Principal Investigator/Project Director is also
responsible for insuring that the Cost Share Certification is completed and signed by his/her unit head and
School Dean and submitted to Research and Projects Fiscal Management quarterly and/or prior to
conclusion of the sponsored project.
Department Chairs/Department Directors are responsible for verifying and insuring that all cost share
commitments will be met. Department Chairs/Department Directors are responsible for determining the
percentage of faculty and/or staff time committed as cost share or in-kind contribution is reasonable and
that the total level of effort expended on sponsored programs and University-related duties does not exceed
100%. The signature of the Department Chairs/Department Director on Cost Share Certifications and
Grant/Contract Routing forms will serve as evidence of review and approval of the commitment.
School Dean is responsible for verifying and insuring that academic unit cost sharing commitments will be
met and will not interfere with other approved instructional and research activities. The School Dean will
verify and insure all cost sharing commitments are met by approval and signature of Cost Share
Certification and Grant/Contract Routing Forms.
Dean and/or Assistant Dean of Graduate Studies and Research is responsible for verifying and insuring
that all cost sharing commitments made by the Office of Research and Projects are met. He/she is
responsible for reviewing and approving cost share requests and securing cost sharing resources above the
resources committed by the academic unit. The Dean and/or Assistant Dean of Graduate Studies and
Research is responsible for determining the necessity and appropriate level of cost sharing in the absence of
a sponsors written requirements and negotiating appropriate cost sharing levels with the funding agency.
Research and Projects Fiscal Management is responsible for reviewing program specific guidelines and
agency requirements for the recording and reporting of cost share to sponsor. RPFM is responsible for
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verifying the approval of all cost share commitments and for preparing reports to sponsor with regard to
cost share expenditures.
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