Procedure Area: Vice President for Research
Responsible or Contact Office/Role:
Office of Sponsored Programs
- Establishing and communicating policies and procedures related to cost sharing.
- Assisting unit research administrators and faculty in determining if an award requires cost sharing and documenting such commitments.
- Reviewing proposals to ensure that the cost share funding source is identified in the EPRF.
- Incorporating appropriate cost sharing terms and conditions into outgoing sub-contracts.
- Establishing cost share companion accounts (CS Awards) in the financial system (for non-SG sources).
- Ensuring third party cost sharing is properly reviewed, documented and reported.
- Conducting periodic reviews of cost sharing expenses for compliance with sponsor requirements.
- Reviewing and submitting necessary cost sharing reports to sponsors, the Cost Analysis group, and others as requested.
The Office of Financial Planning and Analysis is responsible for:
- Ensuring committed cost shared expenditures are included in UVa's organized research base for F&A rate calculation.
Principal Investigators and Project Directors are responsible for:
- Determining and verifying any cost-share requirements on proposals.
- Ensuring that cost share contributions are documented on the ePRF.
- Ensuring adjustments to salary/effort committed as cost share are made as appropriate.
- Ensuring that cost share commitments are met, by UVA and/or third party.
- Attesting to cost share expenditures on the Statement of Cost Sharing Certification, when required.
Department Chair/Dean and/or Vice Presidents are responsible for:
- Obligating University resources for cost share.
- Ensuring that cost share resources are available.
- Approving the ePRF.
Research Administrators and/or Fiscal Contacts are responsible for:
- Assisting the PI/PD in determining and verifying any cost-share requirements on proposals.
- Assisting with preparing the ePRF to inclue cost sharing committments.
- Ensuring that cost share commitments are adequately documented.
- Ensuring that labor schedules are adjusted when salary/effort is committed as cost share.
- Monitoring cost share throughout the life of the project to ensure compliance with the sponsored agreement.
- Maintaining documentation in support of cost share contributions in accordance with OSP’s document retention procedure.
Approval Date: Approval Date 07/16/2018
This procedure describes the management of sponsored agreements that include cost sharing. UVa is required to track cost shared expenditures in the financial system and submit certified reports of to sponsors. Post Award will work with department administrators to ensure cost shared expenditures are verifiable from UVa’s financial system, monitored for allowibility, allocability, reasonableness and consistency with UVa policy, and sponsor requirements.
Policy or Other Underlying Requirement UVA Policies:
- FIN-017 Consistent Treatment of Sponsored Program Costs
- FIN-027 Time and Effort Certification
- FIN-028 Minimum Effort on Sponsored Program Activities
- FIN-051 Proposing and Managing Cost Sharing on Sponsored Programs
- Uniform Guidance (2 CFR 200.306 Cost Sharing or Matching)
- M-01-06 Memorandum for the Heads of Executive Departments and Establishments
- NIH Grant Policy Statement
- NSF Proposal & Award Policies and Procedures Guide
1. Committed Effort: Any part of ‘University effort’ that is quantified and included in a sponsored program proposal and the subsequent award (e.g., two summer months, 12% time, one half of a year, three person-months, etc.). This quantified effort is associated with a specific dollar amount based on the employee’s Institutional Base Salary (IBS). Committed effort can be paid or unpaid, in the form of one or both of the following:
- Direct Charged Effort: Any portion of ‘committed effort’ toward a sponsored program activity for which the sponsor funds the salary and benefits.
- Cost Shared Effort: Any portion of ‘committed effort’ toward a sponsored program activity for which allowable UVa sources fund the salary and benefits.
2. Cost Sharing: Allowable and allocable costs of a sponsored project that are not borne by the sponsor. Categories of cost sharing include:
- Mandatory Cost Sharing: Cost sharing required by the sponsor as a condition of obtaining an award. Such requirements are generally incorporated in the funding opportunity announcements or solicitations or required by legislation, and will be considered as an award eligibility by the sponsor.
- Voluntary Committed Cost Sharing: Cost sharing specifically pledged on a voluntary basis in the proposal budget or federal award which becomes a binding requirement of the award which must be tracked, documented and reported (when required) to sponsors.
- Voluntary Uncommitted Cost Sharing: Cost sharing over and above proposed and awarded commitments. Such cost sharing does not need to be tracked, documented or reported to sponsors.
For example, for a key person committed to and charged 25% of the Institutional Base Salary to the project, but actually spent 35% effort on the project, the additional 10% effort devoted to the project is considered voluntary uncommitted cost sharing.
- Cost sharing represents real costs associated with University resources.
- Cost sharing requires University redirecting funding for instructions or other activities to support research.
- Committed (mandatory and voluntary) cost shared expenditures are included in the organized research base for F&A calculation, lowering University’s F&A (indirect cost) rate.
3. Third Party Cost Sharing occurs when cost share commitments are borne by cash or in-kind contributions of an entity external to UVa.
4. Electronic Proposal Routing Form (EPRF): The Electronic Proposal Routing Form is an internal UVa document containing critical financial and non-financial data about all proposed extramurally funded activities.
5. Facilities and Administrative Cost (F&A): Costs that are incurred for common or joint objectives benefitting more than one cost objective and therefore cannot be identified readily and specifically with a particular cost objective, sponsored program, an instructional activity, or any other institutional activity.
6. Institutional Base Salary (IBS): The annual amount that the University pays for an individual’s appointment, whether that individual’s time is spent on research, teaching, patient care, or other activities. Base salary excludes any income that an individual may be permitted to earn outside of the duties to the University. IBS includes both compensation for University-related effort and compensation from the University Physicians Group (UPG) for clinical effort.
7. Principal Investigators/Project Directors (PI/PD) and Other Key Personnel: Individuals whose effort is essential to the success of the proposed activity, either because of their critical leadership positions within the proposal (and consequently their intellectual guidance) or because of the uniqueness of the expertise they are contributing relative to the proposed scope of activity. ‘Key personnel’ typically include research scientists, principal scientists and senior scientists, depending on their intellectual contribution to the proposed scope of activity. Typically, replacement of any of these individuals requires approval from the sponsor. Importantly, the status of ‘Principal Investigator/Project Director’ and ‘key personnel’ does not necessarily imply salary support from the sponsor.
8. Sponsored Program Activities: Externally funded programs under which the University is obligated to perform a defined scope of work according to specific terms and conditions and within budgetary limitations. These programs are to be budgeted and accounted for separately from other activities. Sponsored program activities include grants, contracts, cooperative agreements, clinical trial agreements, Intergovernmental Personnel Agreements and other awarding instruments supporting research, instruction, public service, and clinical trials.
Funding sources available for cost share expenditures are typically identified from among department funds, local funds, gift accounts, and endowment income (others are defined in (Attachment A). Federal funds may not be used for cost sharing commitments without advanced approval from the contributing agency.
In preparing proposal packages, the Electronic Proposal Routing Form is completed by the responsible PI/PD with assistance from the cognizant departmental/school research administrators. When cost share commitments have been made in the proposal budget or narrative, the EPRF should reflect the types of the commitments and all of the funding sources that will be used to fulfill the commitment. The ePRF is approved by the cognizant departmental/school official.
Pre-Award will review cost sharing requirements of program solicitations and advise the PI/PD on whether or not cost sharing will be appropriate and if needed, obtain clarification from the sponsoring agency.
Note: The School of Medicine Office of Grants and Contracts has delegated institutional authority in the review and submission of proposals.
Upon award, OSP will identify the cost sharing included in the sponsored agreement and recommend establishment of a cost share companion account and/or other methods of tracking such obligations. The cost share companion account will be funded using the PTAO included on the ePRF.
Pre-Award will add a NOA action in ResearchUVA for a cost sharing account and assign the action to OSP Financial Compliance.
OSP Financial Compliance sets up a cost sharing companion award for tracking and reporting on cost sharing, when appropriate. OSP Financial Compliance distributes Notice of Award (NOA) for the cost share companion award to the PI and department.
Occasionally, non-federal sponsors or donors of restricted gifts allow sharing research costs with federal sponsors. In such cases, OSP Financial Compliance will require the department to use unique cost share Project, linked to the state, non-federal sponsored or restricted gift award for easy identification as cost sharing funding source/s.
Departments set up labor schedules, purchase orders and other commitments on the cost sharing companion account to track and document expenditures from the financial system. The PI/PD is responsible for ensuring that commitments are met.
For third party cost sharing, the Statement of Cost Sharing Certification must be completed and certified by the PI.
The OSP Post Award monitors cost shared expenditures through the life of the sponsored program, reports cost sharing to sponsors in accordance with their specific requirements and closes out cost sharing companion account along with the sponsored award. OSP Post Award recommends adjustments to cost sharing commitment when necessary, and directs department administrators to OSP Pre-Award for contacting sponsors.
OSP Financial Compliance prepares an annual cost shared expenditure report for the Cost Analysis group incorporating cost shared expenditures booked on cost sharing companion accounts, as well as non-federal sponsored, restricted gift or state funded awards.
Allowable and allocable cost overruns can be considered as cost sharing when necessary.
Over the cap salary for NIH and other sponsored awards with salary restrictions cannot be used to meet cost sharing commitments. However, over the cap salaries and associated benefits are considered as research costs by the federal government, and will be included in the research base by Cost Analysis for indirect cost rate calculation.
Some sponsors may require cost sharing for Intergovernmental Personnel Agreements (IPA); a cost sharing companion account is not needed for covering salary gap.
Documentation to be retained by OSP in ResearchUVA:
- Statement of Cost Sharing Certification
List of Allowable Award Prefixes for Cost Sharing
|Award Prefix||Award Type||Award Type Description||Cost Share Allowed?||Owner/Exclusion|
|DI||Gift-Restricted||Gift Sources-Restricted||yes||Financial Planning & Analysis (aka UBO)|
|DI||Gift-Unrestricted||Gift Sources-Unrestricted||yes||Financial Planning & Analysis (aka UBO)|
|DR||Gift-Restricted||Gift Sources-Restricted||yes||Financial Operations|
|DR||Gift-Restricted||UPG DR awards||yes||SOM Comptroller|
|DU||Gift-Unrestricted||Gift Sources-Unrestricted||yes||Financial Operations|
|EF||Endowment Income-Unrestricted||Endowment Income Sources-Unrestricted (Endow Fee)||yes||Financial Operations|
|EH||Endowment Income-Unrestricted||Endowment Income Sources-Unrestricted (Med Ctr/SOM Fund for the Future)||no||Financial Operations|
|EI||Endowment Income-ES Chair||Endowment Income-Eminent Scholars Chair||no||Financial Planning & Analysis (aka UBO)|
|EI||Endowment Income-Restricted||Endowment Income Sources-Restricted||no||Financial Planning & Analysis (aka UBO)|
|EI||Endowment Income-Unrestricted||Endowment Income Sources-Unrestricted||no||Financial Planning & Analysis (aka UBO)|
|EP||Endowment-Principal||Endowment Income from Divested Principal||no||Financial Operations|
|ER||Endowment Income-Chair||Endowment Income-Regular Chair||yes||Financial Operations|
|ER||Endowment Income-ES Chair||Endowment Income-Eminent Scholars Chair||yes||Financial Operations|
|ER||Endowment Income-Restricted||Endowment Income Sources-Restricted||yes||When restrictions allow|
|EU||Endowment Income-Unrestricted||Endowment Income Sources-Unrestricted||yes||Financial Operations|
|FA||F & A Costs||Facilities and Administrative Cost Sources (Grant Overhead)||yes||Financial Planning & Analysis (aka UBO)|
|FI||F&A Costs||Facilities and Administrative Cost Sources (Grant Overhead)||yes||Financial Planning & Analysis (aka UBO)|
|IP||Intellectual Property||Intellectual Property Income Sources||yes||VPR’s Office|
|LA||Local-Auxiliary||Local Auxiliary Sources||yes||Financial Planning & Analysis (aka UBO)|
|LC||Local-Chair Support||Local Chaired Professor Research Support Accounts||yes||Financial Planning & Analysis (aka UBO)|
|LC||Local-General Cornerstone||Local-General Cornerstone||yes||Financial Planning & Analysis (aka UBO)|
|LC||Local-General Infrastructure||Local-General Infrastructure||yes||Financial Planning & Analysis (aka UBO)|
|LC||Local-General Strategic||Local-General Strategic||yes||Financial Planning & Analysis (aka UBO)|
|LG||Local-General||Local General Fund Sources||no||Financial Planning & Analysis (aka UBO)|
|LG||Local-General-PFE||Local General Fund Sources-President's Fund for Excellence||yes||Financial Planning & Analysis (aka UBO)|
|LO||Local-Other||Other Local Sources (exclude student activity fees||yes||Financial Planning & Analysis (aka UBO)|
|LP||Local-Plant Funds||Local Plant Fund Sources||no||Financial Planning & Analysis (aka UBO)|
|LS||Local-Sales and Service||Local Sales and Service Sources||yes||Financial Planning & Analysis (aka UBO)|
|RG||Residual||Residual Sponsored Program Funds||yes||Award Owning Org|
|SA||State-Auxiliary||State Auxiliary Sources||yes||Financial Planning & Analysis (aka UBO)|
|SD||State-Sales and Service||State Sales and Service Sources (Debt Funds)||no||Financial Planning & Analysis (aka UBO)|
|SE||State-ETF||State Equipment Trust Fund||yes||Financial Planning & Analysis (aka UBO)|
|SG||State-E&G||State Educational and General Sources-Tuition, Appropriations, Fees||yes||Financial Planning & Analysis (aka UBO)|
|SP||State-Plant Funds||State Plant Fund Sources||no||Financial Planning & Analysis (aka UBO)|
|SR||State-Financial Aid||State Financial Aid||no||Financial Planning & Analysis (aka UBO)|
|SR||State-Eminent Scholars||Eminent Scholars Matching Program, GF and NGF Sources||no||Financial Planning & Analysis (aka UBO)|
|SR||State-Restricted||Restricted State Sources||maybe (dependent on purpose)||Financial Planning & Analysis (aka UBO)|
|SR||State-Restricted Sponsored||State Restricted Sponsored Funds||no||Financial Planning & Analysis (aka UBO)|
|SR||State-Tech Fee||State Technology Fee||no||Financial Planning & Analysis (aka UBO)|
|SR||State-VGUAP||Virginia Graduate and Undergraduate Assistance Program, GF and NGF||no||Financial Planning & Analysis (aka UBO)|
|SS||State-Sales and Service||State Sales and Service Sources||yes||Financial Planning & Analysis (aka UBO)|
|SS||State-Sales and Svcs Med Ctr||State-Sales and Services of Med Center (0309)||yes||Financial Planning & Analysis (aka UBO)|
|SS||State-SIP Clinical Trials||State-Strategic Investment Pool Clinical Trials||yes||Financial Planning & Analysis (aka UBO)|
|SZ||State-Financial Aid||State-Financial Aid (ARRA Funds)||no||Financial Planning & Analysis (aka UBO)|
|YY||Agency||Agency Sources||yes||Financial Operations|
|YA||Agency-Direct Loans||Federal Direct Loan Program||no||Student Financial Svcs|
- On balance, when committing cost share in a proposal, considerations about sponsor expectations, internal budget impacts and resulting administration should be weighed. Committing to cost sharing is usually only necessary when mandated by the sponsor.
- Cost sharing of un-recovered facilities and administrative (F&A) costs are not always permitted by federal sponsors and may require prior approval before including these costs toward a commitment. The terms of the award and/or the Funding Opportunity Announcement/Request for Proposal may address this specifically. Prior to making such commitments, obtain appropriate approvals.