Cost Share

Cost Share jbarber32

Cost Sharing Policy

Cost Sharing Policy
Type of Policy
Administrative
kcross8
Effective Date
Review Date
Policy Owner
Grants & Contracts Accounting
Contact Name
Joshua Rosenberg
Contact Title
Executive Director
Contact Email
josh.rosenberg@business@gatech.edu
Reason for Policy

Georgia Tech may provide cost share for projects funded by U.S. state, local or federal government agencies or non-profit organizations. This policy provides guidance for assessing, managing, and obtaining required approvals for such commitments in order to protect the Institute and the researchers engaging in the work, and to allow for consistent reporting to external sponsors.

Policy Statement

All researchers who engage in sponsored or externally funded research will comply with Institute and sponsoring agency policies as well as any applicable regulations regarding cost sharing requirements on all proposals and awards.

All Cost Sharing
The commitment of funds for cost sharing is subject to the availability of funds for that purpose.

Cost share commitments must be approved prior to proposal submission by units that are contributing the funds. In addition, the Office of the EVPR must review all proposed voluntary committed cost share.

Mandatory and Voluntary Committed Cost Sharing Contributions are auditable and are allowable only when they meet all the following criteria:

  • Are verifiable from the recipient's records.
  • Would be allowable as a direct cost on the grant.
  • Are not included as contributions for any other federally assisted project or program.
  • Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
  • Are allowable under the applicable cost principles.
  • Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
  • Are provided for in the approved budget when required by the Federal awarding agency.
  • Conform to provisions of 2 CFR 200 or other sponsor requirements, as applicable.

Voluntary Uncommitted Cost Sharing
Any funding or other resources needed for voluntary uncommitted cost sharing should be approved prior to proposal submission to the funding entity.

Third-Party Cost Sharing
Funds to be provided by entities outside of Georgia Tech must be supported at the proposal stage by written documentation from an authorized official at the outside entity indicating its commitment to provide cost sharing.

If the third-party entity fails to fulfill its cost sharing obligation, the lead PI’s unit is responsible for covering the commitment.

Scope

This policy applies to all Georgia Tech faculty and staff engaged in, administering, or overseeing research.

Policy Terms

Approver
Individual authorized by the unit to oversee respective unit budgets.

Cost Sharing
The part of project or program costs not borne by the funding agency but supported by contributions from the recipient and/or third parties. Cost share items may include but are not limited to matching funds, faculty effort, financial support for project activities, and other contributions of university resources and services. Cost share may be mandatory or voluntary.

Mandatory Cost Sharing
Contribution required by the sponsor as a condition of receiving an award. Principal Page 3 of 5 investigators must include the total amount of the cost share commitment in the proposal budget.

Principal Investigator (PI)
Lead researcher on a sponsored project. Learn more about PI/PD eligibility here.

Third-party Cost Sharing
Contribution provided by entities outside of Georgia Tech.

Voluntary Committed Cost Sharing
Contribution that is not required by the sponsor but included in the proposal budget, creating a binding commitment equal to that of mandatory cost share. Voluntary Committed Cost Share is often prohibited by sponsors and is rarely appropriate. An example of permitted voluntary committed cost share is where it is allowed by the sponsor and listed as a review criterion.

Voluntary Uncommitted Cost Sharing and Other Support
Faculty or senior researcher effort that is over and above that which is committed and budgeted for in a sponsored agreement and unquantified descriptions of cost sharing in sections of the proposal other than the budget or budget justification, such as Facilities, Equipment and Other Resources or Other Support.

Procedures

All Cost Sharing
Documentation
Approvals for cost sharing of any kind are documented in Institute-level systems such as GT-TRACS and eRouting to ensure clarity and accessibility for all stakeholders.

Responsibilities

Principal Investigator
Obtains approval prior to proposal submission from units that are contributing the funds. Learn more about PI/PD eligibility here.

Office of the Executive Vice President for Research Approves all cost share at the institute level and voluntary committed cost share from any unit.

Office of Sponsored Programs
Confirms that all necessary cost share documentation is in place at the proposal stage.

Associate Deans for Research
Facilitate cost share conversations and processes at the college level.

Units
Appoint an appropriate approver with financial oversight for all cost share requests.

Approver
Ensures that adequate funding exists to support the cost share request and is authorized by the unit to commit the funds. This person is identified within GT-TRACS.

Enforcement

If a PI submits a proposal without obtaining approval for committed cost share, the Institute may be forced to decline the award. After a project is awarded, consequences for non-compliance with cost share commitments are typically determined by the sponsor but may include Georgia Tech or sponsor termination or freeze on the account and may result in disciplinary action by the Institute where appropriate.

Cost Share Expenses

Cost Share Expenses
Type of Policy
Administrative
jbarber32
Policy No
3.9
Effective Date
Last Revised
Review Date
Policy Owner
Office of Grants and Contracts Accounting
Contact Name
Josh Rosenberg
Contact Title
Senior Director, Grants and Contracts Accounting
Contact Email
josh.rosenberg@business.gatech.edu
Reason for Policy

Cost share (Matching) funds are those funds contractually obligated by the Institute to meet the financial requirements specified in a sponsored award. These expenses represent the Institute’s contribution to an externally funded sponsored project. When a cost share obligation is identified in the sponsored agreement, it must be accounted for in the Institute’s accounting records and reported to the sponsor. Cost share expenses should generally be incurred at the same rate as the sponsor’s portion of award expenses.

Policy Statement

The Federal Government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200 – 200.306 “Cost sharing or matching”) indicates that all contributions, including cash and third party in-kind contributions, must be accepted as part of the recipient's cost sharing or matching when such contributions meet all of the following criteria:

  1. Are verifiable from the recipient's records.
  2. Are not included as contributions for any other Federal award.
  3. Are necessary and reasonable for accomplishment of project or program objectives.
  4. Are allowable under Subpart E – Cost Principles.
  5. Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
  6. Are provided for in the approved budget when required by the Federal awarding agency.
  7. Conform to other provisions of this Part, as applicable.

If any expense cannot meet the above criteria, it is not eligible to be recorded and reported as cost share. In addition to expenses incurred by Georgia Tech, the following types of expenses may be counted as cost sharing if properly approved, documented, and supported:

  • Unrecovered F&A (indirect) costs, including indirect costs on cost sharing or matching, with the prior approval of the Federal awarding agency based on approved rates.
  • Unrecovered tuition remission costs with the prior approval of the Federal awarding agency based on approved rates.
  • Donated supplies, equipment, or property based on current fair-market values and period-of-use requirements [reference 200.434 “Contributions and donations”].
  • Third party contributions of personal services, supplies, equipment, property based on current fair-market value and period-of-use requirements [reference 200.434 “Contributions and donations”].

Generally speaking, only expenses that would be allowable to the sponsored project are allowable as cost sharing expenses. Any exceptions to this rule must be approved and documented (i.e., salaries in excess of the NIH salary cap or waived Tuition Remission expenses).

Scope

All employees engaging in sponsored research activity.

Policy Terms

Unrecovered F&A
The difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the recipient’s approved negotiated indirect cost rate.

Internal Institutional support
Internal institutional funding provided to the unit upon successful receipt of a research award, which is not contractually obligated by the sponsored program.

Procedures

The GM System obtains contract information directly from the OSP database. Since all projects with Cost Sharing requirements must be managed by OSP, the GM System receives all authorized Cost Share/Matching information at the time of the award or any subsequent amendment. Upon completion of an agreement by OSP, Project Numbers are assigned. If there is a contractual Cost Sharing requirement a Cost Sharing Project number will be assigned.

The amount of the Cost Sharing requirement is entered into the Project Demographic section of the GM Project files. Cost Share budgets are entered by the departments via the Institute budgeting process into the Institute’s General Ledger System. These budget amounts are subsequently added to the GM project files systematically. The budgets in the GL System will only reflect the amount of funds budgeted by the departments.

The Grants Management (GM) System allows for all companion cost share projects to be linked, summarized, and reported in accordance with applicable requirements. For this reason, all cost share projects should be associated with the appropriate sponsored award/fund within the GM system.

The GM System reports Cost Share Obligation on the "Fund" Demographics Panel. The amount of the budget to be reflected in the cost share project(s) is to represent the funded amount available to spend (plus amounts already expended). A comparison of the total amount budgeted (including State funded cost sharing and GTRC funded projects) to the obligation will indicate the amount of additional funding required.

All related cost share projects are linked to the sponsored project for reporting purposes. Additional companion Cost Share projects may be established by appropriate personnel throughout the life of a sponsored project to properly account for all applicable cost sharing expenditures. When this occurs, the Office of Grants and Contracts Accounting should be notified immediately in order to ensure proper set-up in the GM System.

Projects should not be set up or allocated in the accounting records as cost share projects unless they are contractually required by the sponsor. Internal institutional support that is necessary but not contractually required should be set up by the Budget Office as other State funds outside of the matching fund group of sponsored projects.

Cost Share Documentation Requiring Special Certification and Approval Authorization
On an exception basis, cost share expenses posted to non-companion discretionary projects may be recorded as cost sharing for the applicable sponsored award. In these cases, the Principal Investigator and appropriate unit financial officer are required to complete the cost share certification form, which certifies the project can be used as matching contribution. Source accounting system support and pertinent summary schedules must accompany this certification page.

Documentation and certification of prior fiscal year cost share expenses posted to “non-companion” projects must be approved by the Director of Project Accounting or Senior Director of Grants and Contracts Accounting prior to processing. Requests that exceed 120 days of the initial posting date will follow the Late Cost Transfer process for review and approval.

Federal Salary Limitations (NIH Salary Cap)
The Cost Sharing accounting mechanism referenced above should be used to account for salary limitations applicable to NIH grant and cooperative agreement awards and extramural research and development contract awards. In so doing, the appropriate amount of effort devoted to the NIH award is visible in the accounting records of the Institute.

Refer to the G&C website for Frequently Asked Questions related to cost sharing.
http://grants.gatech.edu/main/wp-content/uploads/2014/03/FINAL_Cost-share-FAQ_1.pdf

Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for additional guidance related to sponsored cost transfer requests.

Responsibilities

Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored projects during the performance and close-out periods.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
11-05-2014 Office of Grants & Contracts Accounting Align with requirements of 2 CFR 200
04-01-2014 Office of Grants & Contracts Accounting Administrative review