COST SHARING AT-A-GLANCE THE FOLLOWING IS PROVIDED AS A BRIEF OUTLINE OF THE BASIC REQUIREMENTS OF EMORY’S COST SHARING POLICY. FOR COMPLETE INFORMATION, PLEASE READ THE FULL TEXT OF THE POLICY LOCATED ON THE FINANCE DIVISION WEB SITE UNDER POLICIES. FOR QUESTIONS ABOUT THE POLICY CONTACT OGCA.

APPLICABILITY The Cost Sharing Policy applies to –All sponsored accounts Federal and non- Federal –All accounts within the OGCA range 5 ledger 6 ledger 6-37xxx-6-47xxx Specified overrun and cost share 2-ledger accounts

TYPES OF COST SHARING Mandatory: Cost contribution required by the sponsor as a condition of the award. Voluntary: Offered by the University, but not a condition of the award. Can either be anticipated and budgeted in the proposal or not planned, but occurs during the project period.

DOCUMENTATION Both types of cost sharing must be captured in the accounting and effort systems and are included in the indirect cost base. Cost sharing must be specifically documented for each sponsored award.

UNIVERSITY POLICY Cost sharing represents a University commitment to provide resources to a project. In all situations, the use of cost sharing should be kept to a minimum, because of the burden that cost sharing places on University resources.

UNIVERSITY POLICY Cost share should be limited to only those situations where it is mandated by the sponsor. Voluntary cost share should only occur when necessary because of the nature of the program.

ELIGIBLE COSTS Cost share must meet the same requirements as costs directly expensed to the award: –Allowable and Allocable –Certifiable if salary costs –Necessary and related to project objectives –Capable of being quantified and documented –Within the award period

INELIGIBLE COSTS Costs used as cost sharing on a sponsored award cannot normally be paid from another sponsored account. –Some exceptions are authorized for non-Federal awards Costs classified as normally F&A costs (e.g., clerical salaries) cannot be used as Federal cost share, unless an exception has been authorized. Costs used as cost share may not be used for more than one award (i.e., used more than once). Costs otherwise restricted in the award terms cannot be used as cost sharing, unless an exception has been authorized.

PRE-AWARD PROCEDURES Consider: –The sponsor’s requirements. –The percentage of time already committed to other projects and functions (e.g., teaching and administration). –The amount of time devoted by others such as co-investigators. –The size and complexity of the project. –Departmental financial resources.

PRE-AWARD PROCEDURES Ensure that the necessary cost share funding will be provided. Indicate cost sharing on SPAF and provide documentation. If cost sharing is across School or Departmental lines, secure commitment from all involved entities. (Dept. A cannot commit cost sharing for Dept. B.)

COST SHARE RISKS Once an award is accepted with a commitment to cost share, failure to do so may result in a loss of sponsored funds. Proportional use is expected. Any reduction in a cost share commitment may require sponsor notification and approval. Unnecessary cost share squanders University resources and diminishes departmental flexibilities to utilize those resources. Inappropriate cost share or insufficient documentation can lead to disallowed costs.

POST-AWARD PROCEDURES Cost shared effort is documented through the effort system. Non-labor and effort cost share is documented through financial reports in the OGCA audit file. A separate account will be required for each project to track both mandatory and voluntary non-labor cost sharing. Separate accounts are not required for effort-only cost share but are strongly encouraged.

POST-AWARD PROCEDURES All cost share must be documented within the University’s accounting system. Effort cost share cannot come from affiliated entities (e.g., Hospital, Clinic, VA salaries, etc.). Only University salaries are eligible for cost share. Collaborative cost share from other entities must be documented in writing on appropriate letterhead or other official correspondence.

POST-AWARD PROCEDURES Non-labor cost share must be tracked in a unique, project-dedicated cost share account. Effort cost share must be tracked through the Effort Certification Reports. Effort may not be used as cost share unless it is shown as such on the effort report. All cost share accounts will be established by OGCA, as restricted 2-ledgers.

POST-AWARD PROCEDURES OGCA will contact the Department to establish a cost share account when cost share is mandatory. OGCA will contact the Department to establish a cost share account, when it is obvious voluntary cost share is occurring. Departments should contact OGCA, when they are aware of voluntary or mandatory cost share, to determine the need for a cost share account.

POST-AWARD PROCEDURES Departments should request cost share accounts, as soon as the need is obvious. Delaying the account set up will only complicate the documentation process. Failure to establish an account or to declare cost share, on a timely basis, can jeopardize the use of expenditures for reporting cost share.

Audit Cost share expenditures and documentation are subject to the same audit requirements as the sponsor’s funding. Cost share commitments and documentation are increasingly of interest to sponsors and cost share requirements have become “high profile” in audits and desk reviews. PIs and departments should maintain strong documentation of the appropriateness and justification of any cost share.