Handling Cost Sharing, Matching and In-Kind Contributions After Award Acceptance

If the project was awarded as proposed:

No adjustments to the budget or cost sharing or matching/in-kind will be necessary.

If the project was awarded more funds than proposed:

Because this would be a rare event, these projects will be handled on a case-by-case basis.

If the project was awarded less funds than proposed:

Cost sharing or matching/in-kind commitments listed in the proposal assume full funding by the sponsor. If funding is reduced, the grant administrator in SPA may reduce any voluntary commitments in proportion to the sponsor's reduction. If the award includes committed cost sharing, the commitment must remain at the level listed in the award document unless sponsor approval is obtained to decrease the commitment. Cost share commitments must be honored in full regardless of PI reductions in effort.

If this reduction conflicts with the sponsor's award, the sponsor's award prevails.

If the decreased award results in a need to cost share some of the project costs to accomplish the project workscope, then the resulting cost sharing is considered voluntary uncommitted.

 

2. Communicate Cost Sharing or Matching/In-Kind Documentation Requirements

If the cost sharing question on the Proposal Routing Form was checked 'Yes," the Notice of Grant/Contract Award (NOGA) will indicate that a cost sharing or matching/in-kind commitment was made. The grant administrator in SPA is responsible for indicating on the NOGA the nature of the commitment (e.g., dollar amount or percent effort) and whether it is reportable to the sponsor.

If the NOGA does not reflect cost sharing or matching/in-kind but should, the department is still responsible for meeting the commitments and must notify the grant administrator.

Committed Cost Sharing or Matching/In-Kind Contributions

What is considered 'committed'? If the proposal budget, budget justification or award specifically pledges cost sharing or matching, it is considered committed, regardless of whether at proposal time it was mandatory (required by the sponsor), or voluntary (offered by the principal investigator).

Uncommitted Cost Sharing or Matching/In-Kind Contributions

If a principal investigator decides to donate additional departmental resources (equipment or staff time) to the project, it is a decision that must be made with the consent of the department head. These additional resources are considered "uncommitted cost sharing or matching/in-kind."

Faculty and senior researchers (these are principal investigators without faculty rank) do not have to certify uncommitted cost sharing on their effort statements. All other project personnel, including graduate students and post-docs, must certify this effort (this is a federal regulation). Because the NOGA does not show uncommitted cost sharing, department personnel are responsible for ensuring that cost sharing is reflected on the effort statement. See the Effort Certification policy for further information.

3. Document the Cost Sharing or Matching/In-Kind Commitments

Requirements: The following requirements apply to committed cost sharing and matching/in-kind contributions. These commitments:

• are stated on the Notice of Grant/Contract Award (NOGA);
• must be consistent with the terms and conditions of the sponsored agreement, including direct costing provisions;
• must be allowable, allocable as a cost to the project, and reasonable and necessary for performance of the project;
• must be documented according to the section below on "Documenting Cost Sharing or Matching/In-Kind";
• are reported to the sponsor by Sponsored Financial Reporting, if required by the sponsor; 
• must be specifically designated for only that project, i.e., they cannot include contributions used on other projects unless prior approval has been received (for example a gift designated as a match on one project cannot also be used as a match on another project); and
• cannot originate from sponsored funds unless specifically authorized by the sponsor of those funds.

How to document committed cost sharing or matching/in-kind contributions: Accurate records must be maintained by the department to verify that committed funds have been provided through the use of other resources. These records must be dept in the department's project files for as long as other document are kept. These records must be auditable because they may be reviewed by auditors.

• Salary or wages: These expenses are documented through certification of Effort Statements.
• Third-Party Labor Contributions: The organization must document the time commitments through its own financial system and this documentation must be retained by that organization for audit purposes. If this cost sharing must be reported to the sponsor, the provider of the cost share must send a letter or report to the PI or unit administrator that identifies the time and the value of that time. This letter must be written after the individual has contributed the effort. Estimates cannot be accepted. The PI / unit administrator must then forward the letter to Sponsored Financial Reporting for reporting to the sponsor, if required.
• Non-salary items: For each cost sharing/matching expense, include the cost sharing value in the transaction line. If there is a programmatic need, it is possible to set up a specific cost sharing/matching account to document cost sharing/matching for a particular project. It will be a nonsponsored account set up according to the procedure for setting up accounts.

Committed:

First check the terms and conditions of the award and the sponsor's policies. Some sponsors require prior approval for changes in levels of committed cost sharing. Cost sharing or matching that was required as part of proposal submission (mandatory) also often requires prior approval for these changes. Note that changes to the source of funds can change without prior sponsor approval.

How to obtain prior sponsor approval:

1. Generate a letter that explains why the change is necessary. Route the letter through the appropriate grant administrator in Sponsored Projects Administration.

2. The grant administrator will review the letter and forward it to the sponsor.

3. The grant administrator will send the sponsor's response to the principal investigator and department administrator, copy Sponsored Financial Reporting so that any required reports will be adjusted.

 

If prior sponsor approval is not necessary, department personnel and principal investigators must document the reasons for the changes, send copies to SPA and SFR, and keep this documentation with the department's project files. Cost sharing and matching is often checked by auditors and this information will be necessary in case of an audit.

Uncommitted:

Because most types of uncommitted cost sharing or matching/in-kind do not need to be documented, these adjustments can be made without providing documentation for the file. However it is necessary to document changes to uncommitted cost-shared effort by anyone other than faculty and principal investigators without faculty rank. These changes do not need to be communicated to the sponsor.

5. Report Cost Sharing or Matching/In-Kind

If required by the sponsor, Sponsored Financial Reporting, with the assistance of the department, reports committed cost sharing or matching/in-kind. Either the terms and conditions of the particular award or the sponsor's policies will indicate whether the cost sharing or matching/in-kind is reportable. If the sponsor is silent, Sponsored Financial Reporting will not report it, however departments must maintain supporting documentation.

6. Cost Sharing Oversight

At project end, any cost sharing or matching/in-kind commitments listed on the NOGA must have been documented at the level indicated on that document. The principal investigator must document any changes to that commitment, either through a prior approval request or a note in the project file (see step 4, above). This documentation may be reviewed by auditors.

When the project terminates, Sponsored Financial Reporting will remind the principal investigator and department that cost sharing/matching/in-kind commitments must be met.