Cost Sharing Policy

Purpose:

To establish the conditions in which the university will commit to Cost Sharing; the process for including Cost Sharing in a sponsored project; and the core compliance principles that Cost Sharing must meet.

Reason for Policy:

Cost sharing requires departmental and university resources to support the project for which cost share is provided. The cost benefit of these commitments must be carefully considered for each project and a clear plan must be in place to ensure commitments can be met. Proper handling of these costs is required to comply with Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 2 CFR 200.309  (”Uniform Guidance”) and to provide non-federal sponsors with similar assurance that the university is meeting the terms and conditions of their awards.

Failure to meet Cost Sharing commitments and properly document them can result in loss of funding (including returning previously awarded funds), audit findings, and risk to NIU’s reputation with the sponsor.

Intended Audience:

• Principal Investigators
• Directors, department chairs, deans, division heads
• Departmental/divisional business administrators
• Sponsored programs administration personnel

Policy:

The university will normally commit to cost sharing only:

1. when Mandatory Committed Cost Sharing is required by the sponsor;
2. to the extent necessary to meet the specific requirements of the solicitation;
3. if all Cost Share commitments are included in the proposed and agency approved budget;
4. if the department/unit/third party responsible for the committed funds provides documented approval prior to proposal submission;
5. where permitted by university and sponsor policies; and
6. where the proposed Cost Sharing is allocable to and directly benefiting the sponsored project and reasonable and necessary for the performance of the sponsored project.

The university is required to track Mandatory Cost Sharing and Voluntary Committed Cost Sharing and make available documentation to auditors or sponsors upon request in order to verify the Cost Sharing amounts claimed.

All Cost Sharing must meet the following core principles.

• Cost Sharing cannot include contributions from any other sponsored award, including federal awards, unless each sponsor specifically authorizes the Cost Sharing in writing.
• An expense cannot be used as Cost Sharing on more than one sponsored project. For example, a cost on a gift fund designated as a match on one sponsored project cannot also be used as a match on a second sponsored project.
• Costs used to satisfy Cost Sharing commitments are subject to the same agreed upon terms and conditions under the sponsor approved project budget. Costs deemed unallowable by the sponsor cannot be used to meet cost sharing commitments.
• For a federally funded sponsored project, Unrecovered Facilities and Administrative (F&A) Costs may be included as part of cost sharing only with the prior approval of the federal awarding agency.
  
  

Special Considerations

Salary “effort” above the regulatory cap – For example, the National Institutes of Health (NIH) has a salary cap that limits the salary amount that may be awarded and charged to NIH grants and contracts. The university may pay an individual’s salary amount in excess of the salary cap with departmental or discretionary funds. However, this differential cannot be used for Cost Sharing.

Using fringe benefits – Fringe benefits commensurate with salary are an actual cost to NIU. Fringe benefit costs associated with requested salary cannot be cost shared unless the department/unit submitting the proposal is willing to cover the cost.

Use of NIU-owned equipment – Cost sharing of equipment in NIU’s current inventory is not allowed. The reason for this is twofold: (1) the sponsor is already paying for a portion of it through the F&A rate calculation; and (2) the equipment was not specifically purchased for use on the project.

University facilities such as laboratory space – The use of NIU facilities is recovered from sponsors through the application of the F&A rate assessed on each project. Therefore, offering university space or facilities as Cost Sharing is not permitted as these costs are F&A, not direct costs.

Using donated supplies, materials, and volunteer services - Third parties may contribute Cost Sharing to an award. Because this is not an expenditure made by NIU, documentation that includes the value of the donated supplies, materials, and/or volunteer services from the Third Party should be provided. The SPA Cost Share MOU may be used to document these commitments.

Graduate Research Assistant (GRA) Tuition remission – Tuition remission is pro-rated based on a student’s actual appointment/effort on the project. As such, the full proposed cost of a tuition waiver can be difficult to capture as Cost Share during the project. 

Encouraged but Not Required – Some funding solicitations include language noting cost share is encouraged but not required, and/or indicate that committing cost share will make proposals more competitive. This is not Mandatory Cost Sharing.

Roles and Responsibilities:

Principal Investigator

Secures Cost Sharing approvals for their projects and works with SPA to document the commitments via the Cost Share Commitment Form.

Ensures all Cost Sharing commitments are met. This may include hiring personnel, graduate students, or initiating purchases.

Certifies that all Cost Sharing commitments are allowable and directly benefit the project. 

Notifies SPA of any project or budget changes that may affect Cost Sharing commitments and work with SPA to manage any agency notifications or approvals that may be necessary. 

Department Chair, Dean, Other Contributing Unit (s)

Approves and assumes financial responsibility for unit commitments.

Aligns Cost Shared grant effort with overall workload.

Sponsored Programs Administration

Reviews all sponsor Cost Sharing requirements and conveys them to the Principal Investigator.

Includes approved Cost Sharing commitments on the proposal and/or awarded budgets per the Cost Share Commitment Form.

Confirms commitments are allowable per applicable regulations. SPA reserves the right to reject any cost share commitments that do not meet the requirements of this policy. 

Periodically updates Principal Investigators of project Cost Sharing commitments.

Distributes Cost Sharing reports to the Principal Investigator for certification.

Completes and submits reports of financial activity, including cost share, to sponsors.

Vice President for Research and Innovation Partnerships

Approves all Voluntary Committed Cost Sharing.  This includes Cost Sharing above the sponsor mandated amount and any commitments offered in response to funding solicitations that include Encouraged but Not Required language.

Definitions:

Cost Sharing

The portion of the total project costs not borne by the sponsor.

Mandatory Committed Cost Sharing

Cost Sharing that the sponsor requires as a condition of obtaining an award. The sponsor requirement must be noted in its published program regulations or funding solicitation.

Voluntary Committed Cost Sharing

Cost Sharing that the sponsor does not require as a condition of obtaining an award, but is quantified in the proposal budget or narrative.  This includes Cost Sharing commitments for solicitations that include Encouraged but Not Required language. Uniform Guidance prohibits the use of Voluntary Committed Cost Sharing as a factor during the merit review of proposals unless it is a part of the agency regulations or funding solicitation.

Third Party (In-kind) Cost Sharing Contribution

The value of non-cash contributions that third parties provide to the project. Third parties must provide documentation to support the use of the funds as university cost sharing and a certification of the fair market value of the non-cash contribution provided.

Unrecovered Facilities and Administrative (F&A) Costs

The difference between the federally negotiated F&A rate applicable to the award and the actual F&A rate approved by the sponsor and used in assessing indirect costs.