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ACCOUNTING
FOR COST SHARING
The following document comprises the
University’s policy on cost sharing and the procedures for monitoring
project-by-project cost sharing and reporting such cost sharing to
sponsoring agencies. The policy was developed for the following
purposes:
-
To provide guidance regarding the
circumstances in which committed cost sharing is permitted by the
University, including what kind of services, expenditures, or assets
may be cost shared.
- To provide information to the
University community regarding the contractual, financial, and
administrative implications that result from the commitment to cost
share.
- To establish procedures by which the
University can identify the cost sharing commitments it makes as a
condition of obtaining external sponsorship and demonstrate that it
has fulfilled such commitments.
- To establish procedures for
recording cost-shared expenditures in the University’s accounting
system in order to identify cost sharing as required by OMB Circular
A-21, "Cost Principles for Higher Education" (A-21).
Cost Sharing: Rationale
and Description
For many years both the Federal
Government and most charitable foundations have considered it the role
of universities to conduct research, training and other activities.
These sponsors will "assist" universities by supporting these
activities, but many awards do not equal 100% of the cost of the
projects. The difference is "cost sharing", and is sometimes a required condition
of receiving awards. The magnitude of cost sharing can range from 1% to
over 50% of the total project cost. Cost sharing is sometimes called
"matching."
Technically, cost sharing
from the University’s resources is "cash" cost sharing,
because a precise dollar amount can be shown in the University’s
accounts. Cost sharing from third party sources may be "in
kind," because the goods or services can be identified, but may not
be subject to a precise monetary evaluation. However,
"in-kind" is sometimes used by some sponsors to mean any cost
sharing.
Summary of
Four Types of Cost Sharing:
Mandatory Cost
Sharing is
cost sharing required by a sponsor as a condition of making an award. If
Mandatory Cost Sharing is required, the requirement is always specified
in the published description of federal programs. The requirement is
usually expressed in terms of a percentage of the total project cost or
a percentage of the sponsor share of the total project cost although
occasionally it is expressed as a fixed dollar amount. Mandatory cost
sharing expenses must be identified for cost accounting purposes and
must be reported to the sponsor in the financial report of the project.
Failure to document the agreed upon cost sharing during the conduct of
the project will generally result in reduction of funds available from
the sponsor.
Voluntary
Committed Cost Sharing is cost sharing the University
may offer in a proposal to reflect accurately the total resources
necessary to complete a project, or to make a proposal competitive. This
offer is included in the award directly or by reference. Voluntary
Committed cost sharing expenses must be properly identified for cost
accounting purposes, but are not generally included on financial reports
to sponsors.
Salary Cap
Cost Sharing is Cost Sharing which occurs when the University
proposes (or later assigns), effort by individuals whose salary exceeds
a sponsor-imposed limit for individual salaries. It may not be offered
for Mandatory Committed Cost Sharing. Salary Cap Cost Sharing must be
identified for cost accounting purposes. Under OMB definition, Salary
Cap Cost Sharing is classified as voluntary committed cost sharing, but
for ease of understanding, it is defined separately in University
documentation.
Voluntary
Uncommitted Cost Sharing is cost sharing that is not
committed or budgeted for in a sponsored agreement. It need not be
tracked for cost accounting purposes or reported to the sponsor, and if
it arises from faculty or other personnel effort, it is excluded from
separate identification in effort reporting. Voluntary Uncommitted Cost
Sharing most commonly results from a cost overrun on a project, or from
researchers’ effort which is over and above that committed and
budgeted for in a sponsored agreement.
Charging a Cost Sharing Account
The cost sharing index will include
the direct allowable expenditures that correspond to the sponsored
program index. Allowability of costs on mandatory cost sharing
accounts is identical to allowability on associated sponsored program
indexs.
Criteria
- Must be verifiable from records;
- Are not included as contributions
for other federally assisted programs;
- Are reasonable and necessary to
project;
- Are allowable charges;
- Are not paid by federal government
under another assistance agreement;
- Are provided for in the approved
budget when required
Accounting For Cost
Sharing
The cost sharing index is a
supplemental index to an existing primary index in another ledger,
and in special circumstances it may be a 5-ledger index. The budget
and expenses in the cost sharing index may "roll-up" with
the primary index and count as one index for University reporting.
For federal reporting purposes, the cost sharing index is a part of
the research activity of the University. Organized Research includes
cost sharing in the base for the University Research Facilities and
Administrative Costs (F&A costs) Rate Proposal.
1. Creating a Cost Sharing Account
A cost sharing
index created in any ledger has its own budget and expenses
associated with a specific sponsored agreement.
The Department will identify the
budget source at the time of the proposal submission. It will
forward to the Office of Sponsored Programs Administration any
changed information prior to inception of the project.
Office of Sponsored Programs
Administration will transmit to Grants and Contracts Accounting the
cost sharing source index provided by the department when it
forwards information on the new award.
Grants and Contracts Accounting will
request or create the index with a cost sharing attribute and
title.
Grants and Contracts Accounting will
inform the department of the new grant or contract index and
corresponding cost sharing index.
The Department will submit the
budget reallocation document to the appropriate Finance and
Administration Department (depending upon the ledger) to enter the
budget for the cost sharing index.
2. Charging a Cost Sharing
Account
The
cost sharing index will include the direct allowable expenditures that
correspond to the sponsored program index. Allowability of costs on mandatory
cost sharing is identical to allowability on the associated sponsored
program index.
The
PAF will show the cost sharing index number and the associated
sponsored program index.
The Effort Certification report will
show the related cost-shared salary charged and the Principal
Investigator (PI) will certify accordingly.
Grants and Contracts Accounting will
report mandatory cost sharing to the sponsor. Where mandatory and
committed voluntary cost sharing are
co-mingled, the cost sharing reported to the
sponsor will be up to the amount
authorized in the agreement.
Grants and Contracts Accounting will
freeze the cost sharing index at the same end date as the associated
sponsored program index unless there is a
continuation year of the sponsored program.
Budget
transfers from designated or gift funds (ledger 6) to the cost sharing
supplemental index may be on a project period basis, but budget
transfers of E&G funds may only be on a fiscal year basis. It is
preferable that transfers from gift funds also be handled on a fiscal
year basis. It is also preferable that cost sharing for a given fiscal
year be identified at the beginning of the year when possible. The PI
should identify the budget source on the Cost Sharing Authorization form
and secure approval by an authorized signator.
One sponsored
index may have multiple accounts set up to monitor cost sharing when
the related cost sharing is coming from different schools and /or
departments. Also if there are multiple salaries to closely monitor, the
department should request additional cost sharing accounts. The same
school and/or department channel should be used to open multiple
accounts.
Each sponsored
program with mandatory cost sharing will have at least one
associated cost sharing index. The department should monitor the
index monthly and update the budget as needed. Cost sharing accounts
may not be in a deficit at the end of the University’s fiscal year.
Departments should make a budget transfer rather than an expense
transfer to resolve the deficit in the cost sharing index.
Departments may
use the voluntary uncommitted cost sharing practice to handle cost
overruns. Cost overruns occur when accumulated costs for specific cost
objectives are greater than the accumulated award amount after applying
any appropriate expense transfers, refunds, etc. For cost transfers,
follow the Cost Transfer procedures in the Financial and Budget Policies
and Procedures Manual. The costing practice (i.e., setting up a
separate index) is not used for a cost overrun, since the overrun will
not be tracked. Cost overrun is considered uncommitted cost sharing.
3. Salary Cap as Voluntary
Committed Cost Share
If a sponsor
imposes a specific salary cap, the University will not charge the
sponsor above that rate but will treat that salary portion as voluntary
committed cost sharing. The University will not report voluntary
committed cost sharing to the sponsor but will capture it for the
F&A costs rate, therefore, charging the salary to a separate voluntary
cost sharing index.
4. Subawardee Cost Sharing
Commitment
The subawardee
will provide the PI a certified statement of the cost-shared
expenditures at the final billing of the subaward. The PI must approve
the expenditures' statement to verify that the subawardee provided the
committed services or assets in the performance of the sponsored
agreement.
The PI will
supply the cost-shared confirmation statement to Grants and Contracts
Accounting. Grants and Contracts Accounting will document the file and
report the mandatory cost sharing to the sponsor.
5. Inkind Cost Sharing Commitment
The PI will
obtain a written confirmation of the value of cost-shared goods and
services. The PI must approve the cost sharing statement to verify that
the third party provided the committed services or assets in the
performance of the sponsored agreement.
The PI will
supply the cost-sharing confirmation statement to Grants and Contracts
Accounting. Grants and Contracts Accounting will document the file and
report the mandatory cost sharing to the sponsor.
EXAMPLES OF SALARY
COST SHARING
Assume an NIH
grant with faculty members paid over the salary cap ($166,700 as of
January 2002). The department may charge cost sharing to one, or
multiple 1-, 2-, 4-, or 6- ledger cost sharing to index(s). Charge
mandatory cost sharing and voluntary committed cost sharing to
same accounts; however, they may be charged cost sharing to
different ledgers. In practice, an NIH grant is very unlikely to have
mandatory cost sharing.
1. None of proposed effort is
volunteered as cost sharing.
John Doe’s
annual salary is $250,000. He will commit 20% effort with no salary cost
sharing requested on his NIH grant. Charge the salary as follows:
| Fund
Source |
Account |
Object
Code |
Amount |
|
| Grant
Budget Account |
5-ledger |
1126 |
$33,340 |
Not
cost shared ($166,700 @ 20%) |
| Cost
Sharing Account |
1-ledger |
1126 |
$16,660 |
Salary
Cap (Voluntary committed) ($83,300 @20%) |
2. All of
proposed effort is volunteered as cost sharing.
Note that
salary cap is only a limit on the amount the sponsor will reimburse.
Sally Roe’s
annual salary is $250,000. She will commit 20% effort with no salary
requested on her NIH grant. Charge the salary as follows:
| Fund
Source |
Account |
Object
Code |
Amount |
|
| Cost
Sharing Account |
1-ledger |
1126 |
$50,000 |
Voluntary
committed ($250,000 @20%) |
3. Part of proposed effort is
volunteered as cost sharing, and faculty member’s salary exceeds cap.
Mary James’
annual salary is $200,000. She will commit 20% effort with only 10%
salary requested on her NIH grant. Calculate the salary as follows:
| Fund
Source |
Account |
Object
Code |
Amount |
|
| Grant
Budget Account |
5-ledger |
1126 |
$16,670 |
Not
cost shared ($166,700 @ 10%) |
| Cost
Sharing Account |
2-ledger |
1126 |
$23,330 |
Voluntary
committed |
(Computation)
$200,000 salary
x 20% total committed effort =
$ 40,000
$166,700 cap salary x 10% capped payment by grant =
$(16,670)
$Balance is voluntary committed including salary cap =
$ 23,330
Cost
Sharing Policy
Salary
Cap Administration
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