5-400 Allowability of Costs Shared

5-410 General Restrictions

Allowability of cost sharing costs is usually determined by the specific award terms and conditions. When a project is funded by a federal grant, University practice follows the guidance on allowable costs given in 2 CFR 215, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations, (OMB Circular A-110) section 215.23.(See 5-F01).

According to this section, mandatory cost sharing/matching and in-kind contributions must be verifiable, related to program objectives, allowable under the applicable cost principles, not from another federal award (unless the terms of that award specifically permit the funds to be used as cost sharing or matching), and shown in the approved budget. The cost principles applicable to the University are those in 2 CFR 220, Cost Principles for Educational Institutions. (See section 6-F01 of this Manual.) Funds from any source which have already been committed as cost sharing to another project cannot be committed twice. In addition, income earned under the grant may not count as cost sharing unless expressly authorized by the granting agency. (See section 6-F03 of this Manual.)

The University-funded salaries of faculty and other employees directly engaged in the project, together with related employee benefits and indirect costs, constitute the most appropriate cost sharing contribution to federal research projects. Sabbatical leave pay may be claimed if it is identifiable with the project. Particular care must be taken to insure that University-furnished space or equipment is not claimed as a cost contribution since these costs are reimbursed by application of the indirect cost rates. Costs financed by departmental budgets or any other non-federal fund source may be claimed as a cost sharing contribution if they are directly identifiable with the applicable federal research project and are contributed during the performance period of the grant or contract. Departmental administrative expenses (e.g., secretaries, clerks, supplies) generally do not qualify as cost sharing since these expenses normally benefit and are distributed across all activities and objectives of a department and are, therefore, included in the determination of the indirect cost rate. In summary, costs meeting all of the above criteria are allowable as a University cost sharing contribution under federal research grants and contracts provided they:

  1. qualify as allowable costs under provisions of 2 CFR 220 (OMB Circular No. A- 21);
  2. do not duplicate the type of costs included in the University's indirect cost rates; and,
  3. have not been charged to any other federal contract or grant.

5-420 In-Kind Contributions

In-kind contributions represent the value of non-cash contributions provided by the University or non-federal third parties to a sponsored project when such contributions directly benefit that project. Such contributions generally may be counted as cost sharing. However, any property purchased with federal funds may be contributed to a federally- sponsored project only if authorized by federal legislation. Typical examples of in-kind contributions are services provided by volunteers and property donated by non-federal third parties. University procedures on documenting in-kind contributions conform to 2 CFR 215 (OMB Circular A-110), 215.23. (See 5-500 and 5-F01).