Policy Overview:
It is the policy of Rice University to comply with sponsor requirements for
cost sharing commitments, tracking and reporting agreed to by the University as
part of accepting sponsored project funds. Accordingly, cost sharing commitments
to be undertaken by the University are proposed, reviewed and approved during
the proposal review and submission process. The decision by the University to
commit its resources toward cost sharing is based on institutional priorities
and a determination that funds are available. Cost sharing has programmatic,
administrative, and financial consequences for the University and should be
considered thoughtfully as these commitments may require significant or
long-term obligations. Voluntary committed cost sharing from Rice University
funds, above the level mandated/required by the sponsor for funding a project,
is discouraged and will be approved only in the most exceptional
circumstances.
Proposal procedures, available on the Office of Sponsored
Research (OSR) website, require that committed cost sharing (as defined below)
be identified by type of expense and approved by those with authority to commit
the funds within the University before the proposal is submitted to the sponsor.
Cost sharing commitment requests made to the Vice Provost for Research for
central University funding should clearly state the cost sharing commitments
provided by the principal investigator(s), chair(s) and dean(s). Each unit that
contributes to a cost sharing commitment is responsible for ensuring that
resources remain available to meet that commitment until the project is
completed or the proposal is rejected. Requests for cost sharing should be
initiated early in the proposal-preparation cycle, as soon as the intention to
propose and the need for funds become known.
Once a sponsor awards a proposal that includes any form of quantifiable cost
sharing, such commitments must be satisfied and are subject to audit. All cost
sharing expenditures must comply with University and sponsor requirements
regarding allowability, allocability and
reasonableness, be reflected properly in the accounting
records and meet the cost sharing expenditure criteria listed below.
Additionally, committed cost sharing expenditures are tracked and reported in
the facilities and administrative (F&A) cost proposal.
Definitions:
Cost Sharing is that portion of total project costs
(including direct costs and related F&A) not provided by the sponsoring
agency. Such costs are sometimes referred to as matching
funds in the program announcement.
There are three types of cost sharing: mandatory, voluntary committed and
voluntary uncommitted.
- Mandatory Cost Sharing is required by the sponsor
as a condition of funding. It is described in the sponsor’s program announcement
and noted in the award document or the approved budget. It must be included in
the proposal as a condition of submission and receipt of award. This type of
cost sharing is also referred to as Required Cost Sharing.
- Voluntary Committed Cost Sharing is not required
by the sponsor but has been included in the proposal in a quantifiable
manner. See the OSR proposal procedures for examples of
quantified voluntary committed cost sharing included in proposals. Some sponsors
do not allow proposals to include voluntary committed cost sharing.
- Voluntary Uncommitted Cost Sharing is cost sharing
that has been recorded in the accounting system but is neither mandatory nor
voluntary committed cost sharing. If a faculty member chooses to report
voluntary uncommitted cost sharing on a project, the cost sharing is recorded in
the accounting system but is not required to be reported to the sponsor. See the
post-award cost sharing procedures section of
the Research and Cost Accounting (RCA) website for additional information.
Committed Cost Sharing includes both mandatory cost sharing and
voluntary committed cost sharing and excludes voluntary uncommitted cost
sharing. When an award is made which includes committed cost sharing, the
University has agreed to ensure that the cost sharing is funded and
expended. Committed cost sharing expenditures must be identified, administered,
recorded and accounted for consistently throughout the University and reported
as required by the sponsor.
Responsible organization is the
department identified on the proposal Review and Approval
form as the organization responsible for overall administration of the
project. Administration includes: proposal preparation; inter-departmental
coordination for multi-departmental projects; technical reporting; budget and
financial management, including cost sharing; and award closeout.
Allowable, allocable and reasonable costs are defined
in the glossary section of the Research and Cost Accounting
website.
Cost Sharing Expenditures:
To qualify as cost sharing, expenditures must be:
- necessary and reasonable for the accomplishment of the project;
- derived from non-federal sources;
- approved by the non-federal sponsor, if funded from non-federal sponsored
projects;
- treated as cost sharing for only one designated project;
- allowable and allocable costs; and
- verifiable through the University’s accounting system and records.
Cost sharing expenditures consist of allowable direct and indirect costs
that meet the above criteria. See the post-award cost
sharing procedures on the RCA website for
information on coding of cost shared expenditures.
See the Appendix to this Policy for Cost Sharing Roles and
Responsibilities.
Additional Information
The following Office of Management and Budget (OMB) Circulars contain
additional information on the federal requirements for cost sharing:
- OMB
Circular A-110 for administrative requirements, including section C23, Cost
sharing or matching
- OMB Circular A-21 for cost principles on allowable costs
and determination of F&A rates
- OMB Circular
A-21 Clarification Memo for treatment of voluntary committed cost sharing in
computation of F&A rates
- OMB
Circular A-133 for single annual audits of federal expenditures on grants
and contracts
Contact Offices
Information about requirements, reporting and procedures is
available from the Office of Sponsored Research and
Research and Cost Accounting websites.
Pre-Award: The Office of Sponsored Research should be contacted for
assistance on cost sharing proposal procedures and commitments.
Post-Award: Research and Cost Accounting should be contacted for assistance
on post-award procedures for cost sharing funding and expenditures.
Policy No. 306
Issued: December 18, 2009
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Related Rice University Policies
• Rice Policy No. 304,
Effort Reporting
APPENDIX TO POLICY NO. 306
Cost Sharing Roles and Responsibilities
Roles
|
Responsibilities
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Principal Investigators (PIs)and co-PIs
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· Initiate discussions
with providers regarding planned cost sharing commitments early in the
proposal development process.
· Indicate plans
to contribute cost sharing (voluntary or mandatory) from funds available to the
PI.
· Finalize cost sharing
commitments by provider and type of expenditure and prepare the cost sharing
form.
· Submit the signed
(department, school, Vice Provost) cost sharing formwith the proposal.
· Honor cost sharing
commitments.
· When cost sharing is
based on contributed effort, ensure that certified Effort Reports accurately
reflect the commitment for faculty, staff and students.
· Monitor the status of
all committed cost sharing funding and expenditure commitments.
· For multi-PI awards,
the main/contact PI has primary responsibility to monitor and coordinate the
funding and recording of cost sharing expenditures.
· Request assistance
from the Chair and Dean as needed to resolve variances from agreed-upon
commitments of cost sharing funding and/or expenditures.
· Certify that
non-subcontract third party cost sharing commitments have been
met.
|
Department Administrators (DAs)
|
· Assist PIs and co-PIs
with cost sharing responsibilities.
· Process needed payroll
forms to record cost sharing effort.
· Monitor and
properly code cost sharing expenditures.
Note: The DA of the responsible organization is responsible
for processing needed budget transfers to fund the cost sharing
commitments. Such budget transfers should be processed within 90 days of the
start of each project year.
|
Chairs
|
· Review and recommend
to the Dean any proposed departmental cost sharing commitments.
· Honor cost sharing
commitments.
· Assist the PI and Dean
in resolving variances from agreed-upon commitments of cost sharing funding
and/or expenditures.
|
Deans
|
· Review and approve
proposed cost sharing commitments from the department and the school to ensure
they meet school goals.
· Make recommendations
to the Vice Provost for Research for cost sharing commitments in those cases
where central funds are sought.
· Honor cost sharing
commitments.
· Negotiate any revision
to cost sharing commitments resulting from the departure of a PI or
co-PI.
· Assist PIs and Chairs
in resolving variances from agreed-upon commitments of cost sharing funding
and/or expenditures.
|
Vice Provost for Research
|
· Review and approve
requests from Deans for central administration cost sharing commitments in
consultation with Provost as necessary.
· Honor cost sharing
commitments.
|
Provost
|
· Assist the Deans,
Chairs and PIs, as needed, in resolving variances from agreed-upon commitments
of cost sharing funding and/or expenditures.
|
Office of Sponsored Research (OSR)
|
· Review cost sharing
proposal commitments for compliance with both Rice and sponsor policies,
including allowability of costs.
· Ensure that all cost
sharing commitments have been signed by providers.
· Review documentation
of third party cost sharing for compliance with Office of Management and Budget
(OMB) Circular A-110 requirements.
· Ensure subcontract
awards include committed cost sharing as
needed.
|
Research and Cost Accounting (RCA)
|
· Assist PIs and DAs
with tracking cost sharing expenditures.
· Request assistance
from PIs, DAs, Chairs, Deans, and VPR as needed to ensure compliance with
committed cost sharing expenditures.
· Certify cost sharing
expenditures on periodic reports to sponsors.
· Provide cost sharing
schedule on federal awards during the annual OMB Circular A-133
audit.
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