Research Policies

GRADUATE SCHOOL POLICY: COST SHARING ON SPONSORED PROJECTS

Introduction
Definition of Cost Sharing
Policy
Responsibilities and Authority
Procedures

Introduction

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. 

Definition of Cost Sharing

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:

1. Salary and Wages
2. Employee Benefits
3. Other Expenses
4. Indirect Costs associated with direct costs listed above
5. Unrecovered indirect costs

Cost sharing must be:

1. Directly identifiable with the project
2. Incurred during the period of performance of the award
3. Financed from non-federal funds
4. Meet OMB A-21 Cost Principal guidelines

Cash cost sharing contributions include:

1. Cash contributions from unrestricted accounts and/or  third-party sources
2. 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)

Policy

University policy requires that (a) the Office of Research and Projects review agency program guidelines and policy requirements to determine whether cost sharing is mandatory, and (b) the Associate Provost for Research review and approve all cost sharing commitments. 

When cost sharing is required and/or proposed, the program or project budget will specifically identify the source of University funds that will be used to satisfy the cost sharing commitment on the Grant and Contract 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. Voluntary cost sharing commitments require additional written justification.

Responsibilities and Authority:

Associate Provost for Research and Dean of the Graduate School is responsible for reviewing and approving all cost sharing and matching funds commitments from academic units.

The Office of Research and Projects in the Graduate School is responsible for preparing reports to sponsor with regard to cost share expenditures.

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 for review to the Office of Research and Projects.

When a sponsor does not provide rules or guidelines that require cost sharing, but encourages it in writing, the Principle Investigator shall consult with the Dean or the Associate Dean for Research to determine if cost sharing is appropriate and, if so, at what level.

Principal Investigator/Project Director is 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.

Procedures

1. In accordance with policy 5B2 concerning “University Guidelines Regarding Review and Approval of Externally Financed Projects” all proposals for external funding must be submitted for review and approval to the Office of Research and Projects at least five working days before the external deadline.
2. If such proposals include cost sharing commitments, additional approvals and justification are required. In such cases signed cost sharing approvals must be included with the “Grant and Contract” approval routing form.
3. 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. 
4. 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.
5. 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.

Approved by Provost, 02-17-2011

Approved by Chancellor, 03-01-2011