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It is the policy of New York University (NYU, “the University”) that cost sharing must be identified and tracked in accordance with federal and other sponsor requirements. Cost sharing is that portion of a project or program cost that is not reimbursed by the sponsor (whether Federal or non-Federal) and as such, represents a commitment of institutional resources that would otherwise be devoted to other University purposes. As a matter of longstanding policy, NYU discourages unnecessary and unsupported cost sharing. As described in Memoranda 01-06 – Clarification of the Office of Management and Budget (OMB) A-21 Treatment of Voluntary Uncommitted Cost Sharing and Tuition Remission Costs (http://www.whitehouse.gov/omb/memoranda_m01-06), there are three forms of cost sharing:
Cost sharing may be required by the sponsor as a condition of the award (mandatory cost sharing) or it may be offered by NYU (voluntary committed). Mandatory and voluntary committed cost sharing becomes an obligation once an award is made. Federal regulations require that Mandatory or Voluntary Committed Cost Sharing be treated consistently and uniformly in documenting, accounting and reporting. They should comply with NYU’s (DS-2) Federally approved cost accounting practices and be reflected in the University’s Time & Effort Certification. The expenses associated with cost sharing or matching contributions must be allowable in accordance with OMB Circular A-21, Cost Principles for Higher Education and/or University and sponsor policies.
The purpose of this policy is to provide guidance for proposing and administering cost sharing on sponsored projects, in accordance with Federal and other sponsor requirements.
This policy is applicable to all schools, departments, units and personnel of the University involved in administering sponsored awards.
Obtaining Approvals for Cost Sharing
The Office of Sponsored Programs (OSP) is responsible for determining whether proposed cost sharing complies with the requirements of the sponsor guidelines and determine whether it is mandatory or voluntary. The approval of all sources of the cost sharing contributions (e.g., Department Chair, Dean, Provost, third party collaborator) is required at the time of the proposal.
NYU Restrictions on Cost Sharing
As a general rule, the contribution of a Principal Investigator's (PI's) academic year effort as voluntary committed cost sharing is subject to the following NYU restrictions:
These are the methods of calculating cost sharing:
Documentation of Cost Sharing in the Proposal Budget and Narrative
PI's should discuss cost sharing requests with their Chairs and Deans and when applicable with the Senior Vice Provost for Research. Approval is conveyed by the NYU Cost Share Form, which must accompany the proposal to OSP. Cost sharing commitments may be included in the budget, the budget justification and the proposal. Care should be taken so that statements about unbudgeted key personnel involvement or tasks will not be inadvertently construed as voluntary cost sharing commitments. Where the proposal describes casual consultation that will enhance the likelihood of the success of the project, such consultation may be included in the narrative portion of the proposal, but not in the budget section. In these cases, no quantifiable effort should be stated in the narrative:
The PI should notify the Department Administrator (DA) of the reduction in effort. The DA should communicate the change to OSP through a Request for OSP Action form. OSP will request sponsor approval, if reduced effort is requested. Both types of changes require the approval of the Chair/ Dean. The second type of change requires Senior Vice Provost approval, as indicated above.
Federal Standards for Acceptable Cost Sharing
Under Federal awards, items committed as cost sharing must meet all of the following criteria in accordance with OMB Circular A-110 Section §__.23 (http://www.whitehouse.gov/omb/circulars_a110/#23):
Appropriate Justification for Cost Sharing
The following are illustrations of when cost sharing may be appropriate in sponsored projects:
Sources of Cost Sharing
The following non-sponsored (and in rare cases sponsored) sources would be considered appropriate sources of funds that the University may use to meet cost sharing commitments:
Costs Not Acceptable for Meeting Cost Sharing Commitments
The following costs may not be used to meet cost sharing commitments:
Creating Cost Sharing Projects
It is the responsibility of the PI and the department to document the fulfillment of cost sharing. Cost sharing is documented through the creation of a separate project in the University’s accounting system which parallels the project established with sponsor funds. The following steps list the process for creating cost sharing projects:
Cost Sharing Identified During Project Lifecycle
Documenting Third Party Cost Sharing (including Sub-awards / Sub-agreements / Subcontracts)
The department is required to maintain records identifying the cash contribution (which may arrive in the form of a gift, grant or contract) or non-cash contribution and its fair market value. Documentation sent to SPA should include a letter of intent (available through OSP) or letter of actual completion, which includes documentation of the basis for determining the value of personal services, material, equipment and other direct expenses as well as written acknowledgement of the contribution, including:
Monitoring Cost Sharing Accounts
Cost sharing may occur as a one-time expense, or incrementally over the life of the project. It is the responsibility of the Principal Investigator (PI) to ensure that charges are incurred against the cost-sharing program as it occurs and in a timely manner.
Project Closeout and Financial Reporting to Sponsors
At project closeout, SPA will email the Cost Share Form to the PI and the department/school administrator for confirmation and verification of cost sharing amounts as recorded in the University’s general ledger.
PI’s and Departmental Administrators should work closely with SPA to ensure accurate reporting of cost sharing on financial reports to sponsors.
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|Effective Date:||September 01, 2013|
|Issuing Authority:||Sponsored Programs Administration|
|Responsible Officer:||Assistant Vice President for Post-Award Administration|
The portion of a project or program cost that is not reimbursed by the sponsor (whether Federal or non-Federal) and as such represents a commitment of institutional resources that would otherwise be devoted to other University purposes. Normally at NYU, cost sharing involves personnel effort; however other costs, such as equipment, may be used.
Non-cash donation of tangible or intangible goods and services provided by a third party; In-kind services that are committed as matching must be documented and may require a certification of fair market value.
Mandatory Cost Sharing
Costs borne by the institution and required by a sponsor as a condition of obtaining an award; Mandatory Cost Sharing is a binding commitment on NYU and must be documented, tracked and reported in accordance with the Cost Sharing Policy.
The requirement by some sponsors that grant funds be matched in specific proportion with funds from NYU or another party, whether received from another sponsor or committed by a collaborating organization.
Third party contributions
The value of cash or non-cash contributions directly benefiting a grant-supported project or program that is provided by non-Federal third parties.
Voluntary Committed Cost Sharing
Quantifiable contributions reflected in the proposal narrative, budget, and/or budget justification, but which are not mandated by the sponsor. Voluntary committed cost sharing becomes a binding commitment on the University when proposed and accepted in the award.
Voluntary Uncommitted Cost Sharing
Faculty-donated additional time above that agreed to as part of the award.