KUMC Cost Share and Matching: Allowability and Documentation
This policy describes the circumstances when cost sharing and matching are allowed for inclusion in sponsored projects submitted to external agencies. The policy will set the allowability of cost sharing/matching, the items that are generally allowed or preferred for cost sharing/matching, and the financial reporting requirements and procedures for tracking and reporting cost share/matching for sponsored projects in a manner consistent with the requirements set forth in federal regulations, primarily the Office of Management and Budget Uniform Guidance 2CFR200.
The University of Kansas Medical Center (KUMC), the University of Kansas Medical Center Research Institute, (KUMCRI), and each of their affiliated entities engaged in the conduct or administration of research supported by KUMC and KUMCRI.
External funding for sponsored activities provides essential support for research and scholarly pursuits in all areas. Often it is necessary or important for the institution to share in the costs associated with conducting an externally-funded grant or contract by providing cost-sharing or matching, either as a requirement of the project or as an enhancement to the project. Cost sharing/matching occurs any time that the full costs of a project are not borne by the funding sponsor, including salaries and associated fringe benefits that are not fully paid by the sponsor relative to the effort contributed. It is the policy of the university to minimize cost sharing/matching to the extent possible on sponsored projects as described in this policy statement.
Allowability and Use
The federal government defines cost share/match according to the reporting requirements associated with it: mandatory cost share; voluntary committed cost share; voluntary uncommitted cost share (as defined below). Cost share/match requirements should first be met by a redirection of the state-supported salary contributed to the effort on the project by the PI or other personnel assigned to the project. When in-kind contributions of state-supported salary, fringe benefits and associated facilities and administrative (F&A) costs are insufficient to meet the required cost share/match, other sources, including cash, may be approved. The procedures for managing cost sharing/matching differ slightly on each campus but the policy for allowability is applied consistently across both campuses.
Mandatory cost share/match is that portion of a sponsored project that is required to be contributed to the benefit of the project from non-sponsored funds. Mandatory cost share/match occurs when cost share/match is required by the sponsor as a requisite for proposal submission and it should meet, but not greatly exceed, the required percentages outlined in writing by the sponsoring agency. Mandatory cost share/match must be in the form of allowable costs in accordance with sponsor regulations and must be documented by auditable records.
Voluntary committed cost share/match occurs when cost share/match is not mandated by the sponsor, but the proposal includes auditable support in the budget or narrative, such as a percent of unpaid effort to the project. Voluntary committed cost share/match should always be avoided and requires explicit approval through the appropriate campus research administration office for inclusion in a proposal to an external sponsor. Voluntary committed cost share/match on Federal research proposals is not expected and cannot be used as a factor during the merit review of applications or proposals.
Voluntary uncommitted cost share/match may be included in a proposal when the description describes the contribution in non-auditable terms, such as “The PI will devote additional effort sufficient to accomplish the goals.”
To be acceptable as cost sharing, expenditures must meet the following criteria as set forth in the Uniform Guidance:
- Be verifiable from official University accounting records;
- Not be used as cost sharing for any other sponsored program;
- Be necessary and reasonable for proper and efficient accomplishment of project objectives;
- Be allowable under Subpart E – Cost Principles
- Not paid by federal funds under another award except where the Federal statute authorizing a program specifically provides that Federal funds made available for such program can be applied to matching or cost sharing requirements of other Federal programs;
- Be incurred during the effective dates of the grant or contract.
Examples of expenditures which may be used as cost sharing are:
- Faculty, staff and student salaries and applicable actual fringe benefits;
- Documentable laboratory supplies;
- Unrecovered overhead (F&A).
Documentation and Responsibility for Management
The most efficient and preferable method to provide mandatory cost share is through contributed salary, fringe benefits, and associated facilities and administrative (F&A) costs. These costs are easily tracked through the appointment process and provide an automatic record for documentation through effort certification.
The terms cost-sharing and matching are often used interchangeably, but may also be defined explicitly by various sponsoring agencies. For internal purposes, the university will clarify the reporting requirements through the accounting system by use of specific fund accounts. In this way, the terms “cost share” and “match” may be used interchangeably but the requirements for managing and reporting will be defined by the fund account through which they are associated.
Once cost sharing or matching costs have been committed to a sponsored project, those costs must be documented periodically and included in the financial records for that project. In accordance with federal regulations, the rules for reasonable, allocable, and allowable expenditures apply to the cost shared and matched expenditures the same way they do for sponsored expenditures. In other words, contributions of cost share/match must be allowable costs per sponsor and university policies and guidelines.
Documentation: Cost sharing commitments that are mandated by the sponsor on Federal, State or private awards should be provided from department or school resources. The Research Institute requires that Sponsored Programs Administration review agency guidelines and policy guidelines to determine whether cost sharing is necessary. All cost sharing commitments on sponsored grants must be reviewed and approved by the Department Chair School Dean, Vice Chancellor for Research, and Vice Chancellor for Research Administration.
When the grant is awarded, cost sharing commitments are established in the PeopleSoft system by KUMCRI Post Award Administration and the appropriate department is notified. The quarterly update and maintenance of cost sharing in PeopleSoft is the responsibility of respective departments. On-going periodic reviews of cost sharing commitments are conducted by KUMCRI Post Award Administration. For cost sharing setup and review, contact the Director of Sponsored Programs Administration
Additional cost-sharing issues may arise as a result of changing cost share after a grant has been awarded by the sponsor.
Executive Director, Research Institute: 913-588-5436
Award: The provision of funds based on an approved application and budget, to an organizational entity or an individual to carry out an activity or project. This includes both direct and indirect costs (F&A) unless otherwise indicated.
Cost Sharing or Matching: The value of third party in-kind contributions and the portion of the costs of a federally assisted project or program not borne by the Federal Government.
In-kind Contributions: the value of all non-cash contributions, including services and property, provided by the University and/or third parties.
Key Personnel: The PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salaries or compensation under the grant. Typically these individuals have doctoral or other professional degrees, although individuals at the masters or baccalaureate level may be considered key personnel if their involvement meets this definition. Consultants also may be considered key personnel if they meet this definition. “Zero percent” effort or “as needed” is not an acceptable level of involvement for key personnel."
2015 04 11: Revised to reflect changes in Uniform Guidance.
2008 03 28: Revised