Cost-Sharing Policy

I. Purpose of This Policy

This policy provides guidance on cost sharing so that it is proposed, managed and reported in a manner consistent with the requirements of the Office of Management and Budget (OMB) Uniform Guidance, 2 CFR Part 200-Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, §200.306, cost sharing or matching. When cost sharing is included in a contract or grant, it becomes an obligation of the university, subject to audit.

III. Key Definitions

Cost sharing is that portion of a project's total costs not borne by the sponsor.
Mandatory cost sharing refers to project costs that are not paid by the sponsor and that are required as a condition of the award.
Voluntary committed cost sharing refers to project costs that are voluntarily pledged in a proposal budget and are included in the subsequent award.

Both mandatory cost sharing and voluntary committed cost sharing become university commitments and binding obligations that must be tracked and reported once an award is issued.

Voluntary uncommitted cost sharing refers to costs neither required by the sponsor nor included in the project budget. Voluntary uncommitted cost sharing does not need to be tracked or reported and is not covered by this policy.
Third-party cost sharing refers to cost sharing commitments made by an entity other than Brandeis that are included in Brandeis' proposal budget and subsequent award. Such commitments must also be tracked and reported.

Brandeis University discourages cost sharing unless the sponsor mandates it. Cost-sharing commitments must be documented on the project approval form submitted to the Office of Research Administration prior to proposal submission, with all necessary institutional approvals.

Cost-sharing commitments require the same financial, accounting, legal and regulatory compliance as other sponsored programs expenditures, and must be properly recorded and reported in the university's accounting system.

V. Roles and Responsibilities

Principal investigator: Responsible for identifying all sources of funds for cost sharing of direct costs and for documenting amounts and sources of cost sharing on the Project approval form.
Administrative head: Approves cost-sharing commitments, by signature on the project approval form, for cost sharing of less than $50,000 over the entire project that will be paid from the unit's budget.
Vice provost for research: Approves cost-sharing commitments (with the exception of the Heller School), by signature on the project approval form, for cost sharing of any amount from sources other than the administrative head of the principal investigator's unit, for cost sharing of $50,000 or more from any source, or for any purchase of capital equipment. Approves all requests for reduction or waivers of indirect cost recovery, whether or not the foregone costs are committed as cost sharing or requested from the sponsor.
Senior vice president for institutional advancement: Approves cost-sharing commitments, by signature on the project approval form, for which Brandeis fundraising is required.
Office of Research Administration: Responsible for ensuring that all cost-sharing commitments proposed have the appropriate institutional approvals and for retaining documentation of approvals. Informs sponsored programs accounting of cost-sharing commitments and their sources at the time of award set-up.
Sponsored programs accounting: Creates a separate cost-sharing account (Fund 17), containing the same project number as the funded award, for every project that has mandatory or voluntary committed cost share for expense tracking and reporting purposes. Monitors cost-sharing charges and ensures that they are reported accurately and timely in accordance with the sponsor’s requirements.
Departmental administrators: Work closely with principal investigators and sponsored programs accounting to ensure accurate budgeting, spending and reporting of cost sharing.

VI. Procedures

The source and amount of cost-sharing commitments must be documented on the project approval form submitted to ORA prior to proposal submission. Cost sharing is usually funded by Brandeis, but may, in some cases, be funded by a third party. Brandeis-funded cost sharing may take the form of contributed personnel effort (salary and fringe benefits), direct project costs (travel, materials and supplies), allowable facilities and administrative costs associated with contributed effort or other direct costs or waived facilities and administrative costs (when the university agrees not to recover the full portion of its allowable F&A costs.).

A third party may also contribute cost sharing to a project, in which case we require a letter to Brandeis University committing to share costs, documenting the value of the cost-sharing commitment, and bearing the signature of an authorized official of the organization.

Federal Standards for Acceptable Cost Sharing

Under federal awards, items used as cost sharing must meet all of the following criteria in accordance with OMB Uniform Guidance Subpart D 200.306:

Verifiable from Brandeis' records.
Not included as a contribution to any other federal award.
Necessary and reasonable for accomplishment of project or program objectives.
Allowable under Subpart E Cost Principles (see Uniform Guidance Subpart E 200.400).
Not paid by the federal government under another federal award, except where specifically authorized by statute.
Provided for in the approved budget, when required by the federal awarding agency.
In conformance to other provisions of the Uniform Guidance, as applicable.

The value of property that may be contributed by a third party is to be recorded at the fair market value of the donation. See Uniform Guidance Subpart E 200.434.

To determine cost sharing for third-party-donated equipment, buildings and land for which title passes to the nonfederal entity, see Uniform Guidance Subpart D 200.306 (h)

For third-party in-kind contributions, the fair market value of goods and services must be documented and, to the extent feasible, supported by the same methods used internally by the nonfederal entity.

Sources of Cost Sharing

The following are appropriate sources of funds to meet cost-sharing commitments:

Gifts.
Endowment spending.
Start-up funds.
School, department or center funds.
Third-party contribution (cash or donated goods or services).
Unrecovered indirect costs, with sponsor prior approval.
Other sponsored awards, when permitted.

Funds Not Acceptable for Meeting Cost-Sharing Commitments

Funds pledged as cost sharing for another funded project (except as specifically approved by all parties).
For federal awards, funds included in another federal award, unless authorized by federal statute.
Funds provided by the same funding source as the sponsored project, unless specifically approved in the sponsored agreement.
Funds used for construction or renovation of university buildings, except with express agency approval.
Direct costs incurred and reimbursed through the indirect cost rate (administrative salaries, office supplies, library expenses, and operations and maintenance expenses).
Salary amounts exceeding a regulatory salary cap, e.g., National Institutes of Health.
Costs deemed unallowable according to applicable federal cost principles or award terms and conditions.
Any costs not deemed to be necessary and reasonable for the proper and efficient accomplishment of project or program objectives.

Documenting Third-Party Cost Sharing (Including That of Subrecipient Organizations)

Documentation of the basis for determining the value of personal services, material, equipment and other direct expenses as well as written acknowledgement of the contribution, including:

Name and signature of donor (or subrecipient).
Date and location of contribution.
Detailed description of item/service.
Estimated value of contribution, how value was determined, responsible person making determination.
Source(s) of contribution.
Retention of a copy of receipt on file.

Office of Research Administration