Subject Area: Sponsored Awards
Responsible Office: Financial Services
Sponsor: Chief Financial Officer
Originally Issued: October 1994
Revised: February 2010, December 2014, May 2015
Refer Questions To: Christine Sorensen, 773-702-2398
Purpose: To ensure compliance with federal regulations and other regulatory policies regarding cost sharing (matching) requirements for sponsored awards.
Per federal regulations, cost sharing or matching is defined as the portion of project costs not paid by Federal funds (unless otherwise authorized by Federal statute). For purposes of this policy, cost sharing and matching are synonymous. This policy further makes the distinction by type of cost sharing:
- Mandatory cost sharing are costs the University must contribute as a condition of the award as described in the funding opportunity and/or in the award document.
- Voluntary committed cost sharing are costs that are not a condition of the award, but those that the University voluntarily commits to by describing and quantifying specific costs in a proposal budget and/or budget justification. This includes any unfunded effort above a salary cap.
- Voluntary uncommitted cost sharing are costs the University incurs as part of completing the project but were not disclosed nor committed to in the proposal budget and/or budget justification.
The following policy covers both mandatory and voluntary committed cost sharing. Voluntary uncommitted cost sharing is intentionally excluded from this policy.
The terms "cost sharing", "matching", and "in-kind" refer to that portion of the total project costs not borne by the sponsor. These terms are often used interchangeably and special attention should be given to sponsor definitions and requirements.
Mandatory and voluntary committed cost sharing for both federal and non-federal sponsored awards is funded by the University unit making the commitment and needs to be documented in the financial records of the University.
Cost sharing and matching funds are both considered forms of cost sharing and must meet all of the following criteria:
- Are verifiable from University financial records;
- Are not included as contributions for any other Federal award;
- Are necessary and reasonable for accomplishment of project or program objectives;
- Are allowable under federal regulations or sponsor-specific agency policy;
- Are not paid by the Federal Government under another Federal 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; and
- Are provided for in the approved budget when required by the Federal awarding agency.
Federal awarding agency approval is required, and nonfederal awarding agency may be required, to include unrecovered indirect costs associated with the cost shared direct costs as part of cost sharing or matching. Unrecovered indirect cost is the difference between the amount charged to the award and the amount which could have been charged to the award under the University's approved federally-negotiated indirect cost rate.
- Mandatory and voluntary committed cost sharing expenses—other than cost sharing required by the National Institutes of Health salary caps to Health and Human Services' awards—must be charged to a "cost sharing" associate account of the sponsored award. The principal investigator or his/her designee must identify the funding source for the associate account at the time the account is created.