Section: Research Policy Number: 6-19 Policy Name: Cost Sharing Date: November 3, 2009 Revisions:
Cost sharing or matching is the portion of award costs not borne by
the sponsoring agency. The purpose of this policy is to set forth the
circumstances and to establish the procedure for proposing, approving,
administering, and documenting cost sharing on sponsored projects. It
includes all contributions, including cash and in-kind, that a recipient
makes to an award.
Cost sharing is auditable and must be allowable under cost principles
and verifiable to records. The University must ensure that cost sharing
requirements of sponsored agreements are proposed, accounted for and reported
in a manner consistent with the requirements set forth in federal regulations,
primarily Office of Management and Budget (OMB) Circulars A-110 and A-21.
Any cost share committed on a proposal, if awarded, is an assumed committed
budget amount that must be properly accounted for and tracked in the award.
Approval for cost share should occur at the time of the proposal submission
through inclusion in the grant budget. Cost share represents a commitment
of resources by the University of Delaware that can be made through contributions
of labor (time on a project), tuition scholarships, equipment funds, or
third party (sub award or collaborator) contributions. Once cost sharing
is specified and quantified in the proposal budget, budget justification,
or budget narrative by the University, the institution is committed even
when not required by the sponsor. Cost incurred by the University to fulfill
cost sharing commitments must coincide with the budget period of the sponsor
The Principal Investigator’s responsibility for maintaining records
of all project related costs is the same for both the award and cost share
The University reserves the right proportionately to reduce the cost
sharing commitment if funds awarded are less than proposed.
Regardless of the resource committed, cost share falls into one of
three categories below: mandatory, voluntary committed or voluntary uncommitted.
Mandatory Cost Share:
Whenever possible, cost sharing should be limited only to those situations
where it is mandated by a sponsor. If cost share is mandated by a
sponsor it should be limited to the minimum amount necessary to meet
a sponsor’s requirement.
Voluntary Committed Cost Share:
Voluntary cost share is committed when the University has determined
that a contribution of additional resources is necessary to ensure
the success of a competitive award or proposal. The University strongly
discourages voluntary cost share by its Principal Investigators.
Voluntary Uncommitted Cost Share:
A commitment of university resources beyond the budgeted commitments
is considered voluntary uncommitted cost share. Examples include effort
provided by a faculty member beyond that which is budgeted. In these
circumstances, it is not necessary to track or account for these commitments.
These are considered additional cost related to the total research
ALLOWABLE COST SHARE
There are several factors that determine the allowability of specific
costs as cost sharing. Cost shared expenses must meet the same standards
that apply to costs that are directly charged to a project.
The costs must be:
Allowable and allocable under federal cost principles as specified
in OMB Circular A-21.
Verifiable from University records when applicable.
Necessary and reasonable for proper and efficient accomplishment of
Identified in the approved award budget set up by the Research Office
In compliance with the criteria outlined in OMB Circular A-110.
Determined by the sponsor’s specific award terms and conditions.
EFFORT COST SHARE
Because of the additional administrative requirements and responsibilities
that may be inherent in the cost sharing commitment, PIs are strongly encouraged
to limit voluntary cost sharing commitments. However, according to federal
policy, most Federally-funded research programs must have some level of
committed faculty (or senior researchers) effort, paid or unpaid from the
sponsored award. The University has established a minimum of 1% effort to
all federal awards. This does not apply to major research instrumentation,
awards solely for travel and infrequent other special circumstances.
If no salary is charged directly to the sponsor, an appropriate amount
of cost-shared effort should be provided. It is not acceptable for a PI
to submit a research proposal without some level of commitment by the PI
to the proposed project. This requirement is not applicable to equipment
awards, dissertation or training support, fellowship, or other limited purpose
awards (e.g., travel grants, conference grants) that require little or no
additional time from the PI.
Effort may be committed and met at any time within the fiscal year (summer
months, academic year, or both). Committed effort, whether mandatory or
voluntary, must be met and reported during the periods in which it was accomplished.
Any effort provide above the level committed to a sponsor is referred to
as voluntary uncommitted cost-share, and is not required to be reported
EQUIPMENT COST SHARE
Equipment committed as cost share in a proposal, whether mandatory
or voluntary, must be purchased, tracked, and reported during the periods
in which it was accomplished. Any equipment cost share provided above
the level committed to a sponsor is referred to as voluntary uncommitted
cost-share, and is not required to be reported as cost-share.
University equipment cost share dollars are available when a sponsor
requires mandatory equipment cost share or the project budget exceeds
the available funding in the area of equipment. UD Policy defines equipment
as any single item valued at $5,000 or greater and having a useful life
of two or more years.
The PI is allowed to submit requests of up to $50,000 with one to one
match assistance from the PI’s college or unit. For example, $50,000 from
the Research Office requires an equal $50,000 from the college or unit.
These funds must be used on equipment and cannot be used for any other
In the case of major center proposals such as COBRE or MRSEC that involve
multiple academic units and multiple years of potential funding, the PI
can submit requests of up to $50,000 for each of the years of funding.
This sum must also be matched by the college or unit for each of the years
that the Research Office provides funding.
The University has an annual equipment cost share budget. Any overrun
amounts are proportionately divided among those colleges benefiting from
the cost share during that fiscal year. In the case of cost share for
center grants, only the units involved in benefiting from the match for
the center proposals will be assessed the cost of the overrun amount.
Other expenses, such as travel and supplies, may be cost shared when
they are deemed necessary to meet mandatory cost share or for the completion
of the project. These expenses must meet the Cost Principles stated in
OMB Circular A-21.
THIRD PARTY COST SHARE
Third Party cost share are contributions given to a specific grant or contract
by an individual or group from outside both the University and the sponsoring
agency. PIs are responsible for tracking and obtaining backup financial
documentation to ensure that cost share has been met. A letter of commitment
must be provided by the third party organization in which the cost share
amount is documented. Once the award is executed, the third party cost share
must be documented to verify expenses.
WAIVED F & A COST SHARE
Unrecovered F&A costs on Federal projects may be included as cost
sharing only with the prior approval of the federal awarding agency per
OMB Circular A-110, Subpart C 23b.These amounts are documented in the
financials system and will be reflected in close out analysis. These amounts
are tracked in the UD Financial accounting system as analysis type values
of WFA and CFA and will be reflected in closeout analysis.
During the proposal process if a subaward recipient proposes cost share,
this should be documented in their letter of intent. When awarded committed
cost share should be documented in the subaward agreement and must be tracked
by the prime awardee throughout the life of the award. The prime awardee
is responsible for making sure that the entire cost share commitment is
UNALLOWABLE COST SHARE
The following types of cost sharing are not allowed:
Federal to Federal - Federal appropriations or contracts and grants funded
by Federal agencies, either directly or indirectly as flow-through funding,
are not allowable as cost sharing for another Federal project. Federal contracts
and grants may generally be used as cost sharing on any non-Federal contract
or grant unless restricted by the non-Federal sponsor.
Expenditures Included in the Facilities and Administrative Rate - Costs
that are included as part of the indirect cost rate, such as space used
for instruction and research, equipment depreciation, utilities, department
administration, etc., cannot be cited as cost sharing expenditures.
Double Counting - Cost sharing can only be committed and reported as
cost sharing once. If cost sharing relates to two or more projects, it should
be pro-rated among the projects so that, in total, it is only reported once.
Costs Incurred Outside the Project Period - Costs that have already been
incurred and were documented in the University accounting system prior to
the project award start date are generally ineligible for cost sharing,
unless allowed as pre-award costs.
Lack of Technical Relationship - Costs that are not specifically related
to the performance of the project cannot be used as cost share. Therefore,
if another University sponsored project or gift is identified as a cost
sharing contribution, the technical relationship between the two (or more)
projects must be established and documented
Costs Specifically Not Allowable under OMB Circular A-21 (CFR 220) -
These costs include alcohol, entertainment, advertising, memberships, etc.
In addition, any costs associated with a PIs sabbatical leave are generally
not allowable unless specifically approved by the sponsoring agency.
Expenses not allowed by the award terms and conditions.