All faculty, staff, and student employees engaged in Syracuse University-administered sponsored projects.
General Policy Statement
As a recipient of federal funds, Syracuse University (the “University”) must ensure that cost sharing requirements of sponsored agreements are proposed, accounted for, and reported in a manner consistent with the requirements set forth in federal regulations. Cost sharing is that portion of a federally- or other externally-sponsored project or program cost that is borne by the University or some third party rather than the sponsor. This Policy describes the circumstances under which cost sharing may be offered on sponsored projects and the management of resulting cost sharing obligations.
Reason for Policy/Purpose
The spending of any funds awarded by the federal government to the University is governed by 2 CFR 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), published by the United States Office of Management and Budget (OMB). The Uniform Guidance and federal regulations codified at 2 CFR 200.306 require the University to identify and track cost sharing to ensure 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, and e) included in the approved budget when required by the federal awarding agency. This Policy provides guidance for proposing and tracking cost sharing on sponsored projects or programs.
- Cost sharing is the portion of a project’s total cost that is not reimbursed by the sponsor. Total project costs should be appropriately and fairly borne by either the sponsor, the University, a third party, or some combination thereof as presented in the award.
- Cost sharing should be limited to the following circumstances:
- It is mandated by sponsor guidelines as an eligibility or review criterion;
- It is a consequence of mandatory key personnel effort that will not be charged to the sponsor; or
- It will enhance the competitiveness of the application (e.g., training grants) as determined by the Vice President for Research, in consultation with the Office of Sponsored Programs (OSP) and the applicable dean(s).
- To qualify for cost sharing on a federally-sponsored award, the cost must satisfy all of the following criteria:
- Be allowable and allocable, and consistently treated in accordance with federal regulations or the terms of the specific sponsored agreement;
- Be verifiable from the University’s records;
- Not be used as cost sharing for any other award;
- Not be paid by the federal government under another award, except where authorized by statute;
- Be necessary and reasonable for the performance of the project’s objectives;
- Be incurred during the award’s project period; and
- Be included in the approved budget when required by the federal awarding agency.
- Principal Investigators (“PIs”) and Project Directors (“PDs”) are responsible for ensuring that cost sharing obligations are fulfilled. The PI or PD is responsible for obtaining all necessary authorizations for cost sharing prior to proposal submission.
- Where cost sharing is not required by the sponsor or necessary to ensure the competitiveness of a proposal, the rationale for offering cost sharing should be provided to OSP. These instances are often referred to as voluntary cost sharing. In all cases, the amount of cost sharing should be kept to a reasonable level due to the impact on University and departmental financial and personnel resources.
- Allowable Sources of Cost Sharing
The following types of costs may be eligible for costing sharing:
- Costs associated with efforts of the PI, PD and/or employees devoted to sponsored agreements, including associated fringe benefit costs in proportion to effort devoted. This effort is subject to the same effort reporting procedures as costs borne by the award;
- Equipment (and associated installation and other costs required for operations) purchased during the award’s project period;
- Supplies and services directly associated with the award;
- Third Party cost sharing including sub-recipient cost sharing;
- The University contribution to graduate student tuition;
- Unrecovered indirect cost, if approved by the sponsor; and
- Cost overruns.
- Unallowable Sources of Cost Sharing
The following types of costs are not eligible for cost sharing:
- Administrative salaries and services that are not appropriate as direct costs (Uniform Guidance);
- Unallowable costs;
- University facilities such as laboratory space. Such resources should be described as “available to support the project at no direct cost to the sponsor”;
- Salary in excess of federal salary caps;
- Depreciation on equipment on existing University owned or government funded equipment. Existing equipment cannot be offered as cost sharing; and
- When the sponsor has explicitly prohibited it (e.g. the National Science Foundation).
Appendices (as applicable)
- Cost sharing identification and tracking procedures are set forth by the Office of Sponsored Accounting at http://comptroller.syr.edu/resources/sponsored-accounting/sponsored-accounting-procedures/
- DefinitionsAllocable: the expense can be associated to an award with a high degree of accuracy.Allowable: under both the provisions of federal guidance and the terms of a specific award the costs are allowed.Cost sharing: the portion of a project’s total cost that is not reimbursed by the sponsor.Mandatory cost sharing: the sponsor requires some proportion of project costs to be borne by non-sponsor sources. The amount of cost sharing offered may be an eligibility requirement (e.g. all applicants must offer a specified fixed amount or defined proportion of total project costs) or a review criterion (e.g. the more cost sharing offered above a minimum threshold, the more points received).Reasonable: the cost reflects what a “prudent person” would pay in a similar circumstance.Voluntary cost sharing: cost sharing in excess of that required by the sponsor. Voluntary committed cost sharing is any cost associated with a project identified anywhere in the proposal (e.g. proposal narrative, budget narrative or current & pending support) that is not borne by the sponsor. Common examples include commitments of effort that will not be compensated by the sponsor, or purchases of equipment not borne by the sponsor.
- Other Related Policies and Documents
Date: June 26, 2014
Amended: April 25, 2016