Sponsored Funds Financial Management
Sponsored Funds |Policies & Procedures | Cost Sharing
Cost Sharing is defined as a sponsored program cost that is not reimbursed by the sponsor. Any cost sharing (voluntary or mandatory) contained in the proposal and subsequently accepted as a term or condition of a sponsored award is considered to be required for purposes of documentation and reporting. Therefore, it is critical to take care in considering any cost sharing that is offered in a proposal. It is the Principal Investigator’s responsibility to provide adequate documentation of those costs. Failure to do so may result in a disallowance on the prime budget to counterbalance the shorted cost share.
Cost sharing is considered allowable only if it is verifiable; not included as contributions for any other federally-assisted project; necessary and reasonable for proper and efficient accomplishment of the project; allowable under the cost principles of OMB Circular A-21; not paid by the federal government under another award, except where authorized; provided for in the approved budget; and conforms to other applicable provisions of OMB Circular A-110.
Examples of Allowable Cost Share
- Unpaid personal service (effort not compensated directly with award funds, e.g. SUNY faculty effort) Regulatory caps do exist with some funding sources
- Other than personal service - OTPS (contributions by SUNY, or the UAlbany Foundation, e.g., supplies, equipment, tuition)
- Third party in-kind contributions (non-cash contributions by a non-federal third party directly benefiting and specifically identifiable to the project, e.g. volunteer services, supplies, equipment, tuition)
- Matching funds (usually RF non-sponsored funds)
- Program income (the use of program income as cost sharing must be determined based on sponsor regulations)
- Facilities and Administrative costs (F&A related to cost shared expenses)
- Unrecovered Facilities and Administrative costs (F&A not collected on a direct cost to the sponsored award which typically yield F&A)
Examples of Unallowable Cost Share
- Salaries of certain administrative positions (e.g. deans and other non-teaching and non-research employees)
- Salary dollars above a regulatory cap (e.g., DHHS salary cap)
- Unallowable costs as specified in OMB Circular A-21, Section J (alcoholic beverages, entertainment, fund raising,
- Costs associated with RF and SUNY building rental, purchase and maintenance when collecting the On-Campus F&A rate
- Costs included on another federal project
- Costs included on a non-federal project unless specifically authorized by that sponsor
The documentation requirements for cost sharing depend on the type and source of the cost. At proposal stage, any cost share offered in the proposal should be documented and approved by the Principal Investigator, Department Chair, Dean, and Vice President as appropriate. Any proposed third party cost share should be documented in a letter of commitment from the third party.
Once the award has been made, it is the Principal Investigator’s responsibility to provide adequate documentation of the actual cost sharing to the Grant Administrator. Adequate documentation would be as follows:
RF Non-federal sponsored award – while it is typically not allowable to offer costs from another sponsored award, there may be unique circumstances where this is permitted. In these cases, a letter from the non-federal sponsor acknowledging and accepting that costs will be reported on another sponsored award would be required. The RF account number and the specific costs from that account should be identified.
- SUNY effort – at account set up, SFFM is notified of the level of effort being cost shared for an award and initiates the collection of this information. Each semester, effort reports are generated and mailed to the Principal Investigator for certification of that effort. It is critical that those effort reports are reviewed for accuracy, signed and returned promptly.
- If students are offered as cost sharing, the PI must provide SFFM with a list of student names and salary amounts at the beginning of each semester.
- SUNY or UAlbany Foundation OTPS costs – copies of the invoice and payment documentation must be provided.
- Third party – a letter from the third party certifying to the actual expense provided in support of the project and a valuation of those costs.
- RF Non-sponsored award – the RF account number and the specific costs on that award should be identified.
All OTPS cost share documentation must be sent to your Grant Administrator in Sponsored Funds Financial Management prior to the term of the award to ensure proper and timely reporting to the sponsor. In the event that a portion of an expense is being offered, a memo must be included with the invoice and payment documentation to support how that portion of the expense is appropriate to be cost shared. SFFM is not responsible for any disallowances by the sponsor due to inadequate documentation.