Federal Grant Cost Sharing Policy

Responsible Office or Person: Business Office
Related Law & Policy: CFR 200.306

All Principal Investigators (PIs) and administrators at Carroll who are involved with the administration and conduct of sponsored awards must comply with this policy.

Carroll University has established the following policy for the management of cost sharing to comply with the requirements of the Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and federal agency policies and procedures. Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the federal sponsored award. Cost sharing, also known as matching, is funded by Carroll or a non-federal third-party.

Carroll encourages analysis and evaluation before a cost sharing commitment is made. All committed cost sharing must be tracked and may require reporting.

Types of Cost Sharing

Mandatory Committed Cost Sharing: Costs required as a condition of the award which must be tracked and may require reporting. This type of cost sharing is required by the Sponsor and must be included in the proposal.

Voluntary Committed Cost Sharing: Cost sharing specifically pledged by Carroll on a voluntary basis which is quantified in either the proposal budget and/or narrative and becomes a binding requirement of the award, must be tracked, and may require reporting.

Voluntary Uncommitted Cost Sharing: Costs and effort that are not included as part of the submitted proposal or upon acceptance of the award. This does not need to be tracked or reported.

In-Kind Cost Sharing: In-kind cost sharing are contributions wherein the value can be readily determined, verified, documented, and justified but where no actual cash is transacted in securing the good or service comprising the contribution. When applicable, an estimated value of the in-kind cost sharing should be determined and documented based on the fair market value at the time of the accepting award. In-kind cost sharing must be tracked manually by the department managing the award and follow the University in-kind contribution procedures.

Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Sections 2 CFR 200.306 (“Uniform Guidance”) states “Under Federal research proposals, voluntary committed cost sharing is not expected. It cannot be used as a factor during the merit review of applications or proposals, but may be considered if it is both in accordance with Federal awarding agency regulations and specified in a notice of funding opportunity.”

Cost sharing expenditures must adhere to the same requirements as direct cost expenditures and must comply with the following:

• Federal sponsored award terms and conditions
• University sponsored policies and guidelines

Uniform Guidance Section 200.306 requires that “cost sharing funds are a) verifiable from the University's records b) not included as contributions for any other federal award c) necessary and reasonable for the accomplishment of the project or program objectives d) are allowable under Subpart E Cost Principles e) not paid from another federal award and f) included in the approved budget when required by the Federal awarding agency.”

Failure to appropriately document cost sharing commitments from verifiable official University records could result in audit findings and require the return of funds to the sponsor.