Cost-sharing or matching refers to the share of sponsored project costs not covered by the sponsoring agency. Cost-sharing can be mandatory or voluntary.
Mandatory cost-sharing is when a sponsor requires it as a condition for making an award, while voluntary cost-sharing refers to an institution-initiated contribution to a sponsored project.
Under federal research proposals, there is no expectation of voluntarily committed cost-sharing, which cannot be considered a factor during the merit review. The National Science Foundation (NSF) prohibits the inclusion of voluntarily committed cost-sharing in proposals.
In-kind contributions to a sponsored project are considered cost-shared expenditures, given that the sponsor receiving the contributions was to pay for them.
The purpose of this policy is to highlight critical requirements for cost sharing. These requirements ensure that cost-shared expenditures comply with the University and Research Foundation (RF) policies, the sponsor’s guidelines, and the U.S. Office of Management and Budget Uniform guidance.
Required Approvals for Cost-Sharing
At CUNY SPH, all proposed mandatory cost-sharing arrangements must be approved by the Associate Dean for Research before the proposal is submitted. The Principal Investigator (PI) should confer with the Associate Dean for Research regarding a cost-share strategy to meet the sponsor’s requirements.
The Grants Officer (GO) will maintain mandatory cost-share approvals.
Voluntary Cost Sharing
Voluntarily committed cost-share requires approval by the CUNY Office for Research Administration, Director of Sponsored Research and Compliance given compelling circumstances. The SPaR office will request approval using the PI’s justification.
The PI should discuss their intent to cost share with a GO ahead of the grant application submission deadline, as the approval process may be lengthy.
Cost Share Expenses
The most common cost-share expenses are salaries, fringes, supplies, and associated facilities and administrative costs.
Faculty Effort or Research Staff Salary
PIs can commit to expending faculty or research staff effort on a sponsored program without charging a commensurate salary to the sponsored fund. Such a commitment to effort binds the University to contribute research staff or faculty time to the project and to record salary expenditures, including fringe benefits, in a manner that verifies the expenditure from University records.
Like all committed efforts, faculty must report cost-shared faculty effort on a PAR Form.
Other Direct Costs
Most other costs that could be charged (allowable, allocable, reasonable, and consistently treated) to a sponsored project can be cost-shared. The following are examples of other direct costs that may be cost-shared:
- Laboratory supplies
- Equipment items that do not meet capitalization thresholds
There are three ways to cost-share indirect costs.
Unrecovered Overhead on Sponsored Expenditures
Unrecovered overhead is the amount of F&A not collected from the sponsor that could have been allocated to the direct costs paid by the sponsor of an award. The unrecovered overhead typically results from awards made by sponsors that do not pay the full negotiated F&A rate. For federal sponsors, Uniform Guidance section 200.306(c) indicates that “Unrecovered indirect costs may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency.”
Overhead on Cost-Shared University Resources
Overhead on cost-shared university resources is the amount of F&A, calculated at the full negotiated F&A rate that would typically have been allocated to cost-shared direct costs funded by University resources.
Items Normally Considered Indirect
Some items usually considered indirect include depreciation, administrative support, and rent. For cost-sharing on federal awards, costs typically deemed indirect represent a cost accounting standards (CAS) inconsistency and are therefore not allowed. For non-federal awards, however, the sponsor may allow items typically considered indirect to be offered as cost-sharing.
The following costs may not be used as cost sharing:
- Costs pledged as cost-sharing for another sponsored program or funded by another sponsored program, except where authorized by the sponsor;
- Costs that are included and reimbursed through the F&A rate; and
- Costs representing salaries over regulatory caps, such as the NIH salary cap, cannot be used to meet a cost-sharing commitment.
All cost-shared expenditures must be verifiable to the University’s or RF’s records. When cost-sharing direct cost expenses, the RF’s Grants & Contracts department requires the PI to complete a Cost-Share Form and provide the account number (CUNY First Department or RF PRSY), if applicable, where cost-share commitments will be met.
The GO will assist the PI with completing the cost-share form. The cost share form will summarize the details of cost sharing on the award, including:
- Dollar value requirement;
- Source of the cost-sharing funds (including CUNY tax levy department number); and
- Cost sharing expense detail.