Type of Policy
Administrative
Policy No
3.9
Effective Date
Last Revised
Review Date
Policy Owner
Office of Grants and Contracts Accounting
Contact Name
Josh Rosenberg
Contact Title
Senior Director, Grants and Contracts Accounting
Contact Email
josh.rosenberg@business.gatech.edu
Reason for Policy

Cost share (Matching) funds are those funds contractually obligated by the Institute to meet the financial requirements specified in a sponsored award. These expenses represent the Institute’s contribution to an externally funded sponsored project. When a cost share obligation is identified in the sponsored agreement, it must be accounted for in the Institute’s accounting records and reported to the sponsor. Cost share expenses should generally be incurred at the same rate as the sponsor’s portion of award expenses.

Policy Statement

The Federal Government’s Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements (2 CFR 200 – 200.306 “Cost sharing or matching”) indicates that all contributions, including cash and third party in-kind contributions, must be accepted as part of the recipient's cost sharing or matching when such contributions meet all of the following criteria:

  1. Are verifiable from the recipient's records.
  2. Are not included as contributions for any other Federal award.
  3. Are necessary and reasonable for accomplishment of project or program objectives.
  4. Are allowable under Subpart E – Cost Principles.
  5. Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
  6. Are provided for in the approved budget when required by the Federal awarding agency.
  7. Conform to other provisions of this Part, as applicable.

If any expense cannot meet the above criteria, it is not eligible to be recorded and reported as cost share. In addition to expenses incurred by Georgia Tech, the following types of expenses may be counted as cost sharing if properly approved, documented, and supported:

  • Unrecovered F&A (indirect) costs, including indirect costs on cost sharing or matching, with the prior approval of the Federal awarding agency based on approved rates.
  • Unrecovered tuition remission costs with the prior approval of the Federal awarding agency based on approved rates.
  • Donated supplies, equipment, or property based on current fair-market values and period-of-use requirements [reference 200.434 “Contributions and donations”].
  • Third party contributions of personal services, supplies, equipment, property based on current fair-market value and period-of-use requirements [reference 200.434 “Contributions and donations”].

Generally speaking, only expenses that would be allowable to the sponsored project are allowable as cost sharing expenses. Any exceptions to this rule must be approved and documented (i.e., salaries in excess of the NIH salary cap or waived Tuition Remission expenses).

Scope

All employees engaging in sponsored research activity.

Policy Terms

Unrecovered F&A
The difference between the amount charged to the Federal award and the amount which could have been charged to the Federal award under the recipient’s approved negotiated indirect cost rate.

Internal Institutional support
Internal institutional funding provided to the unit upon successful receipt of a research award, which is not contractually obligated by the sponsored program.

Procedures

The GM System obtains contract information directly from the OSP database. Since all projects with Cost Sharing requirements must be managed by OSP, the GM System receives all authorized Cost Share/Matching information at the time of the award or any subsequent amendment. Upon completion of an agreement by OSP, Project Numbers are assigned. If there is a contractual Cost Sharing requirement a Cost Sharing Project number will be assigned.

The amount of the Cost Sharing requirement is entered into the Project Demographic section of the GM Project files. Cost Share budgets are entered by the departments via the Institute budgeting process into the Institute’s General Ledger System. These budget amounts are subsequently added to the GM project files systematically. The budgets in the GL System will only reflect the amount of funds budgeted by the departments.

The Grants Management (GM) System allows for all companion cost share projects to be linked, summarized, and reported in accordance with applicable requirements. For this reason, all cost share projects should be associated with the appropriate sponsored award/fund within the GM system.

The GM System reports Cost Share Obligation on the "Fund" Demographics Panel. The amount of the budget to be reflected in the cost share project(s) is to represent the funded amount available to spend (plus amounts already expended). A comparison of the total amount budgeted (including State funded cost sharing and GTRC funded projects) to the obligation will indicate the amount of additional funding required.

All related cost share projects are linked to the sponsored project for reporting purposes. Additional companion Cost Share projects may be established by appropriate personnel throughout the life of a sponsored project to properly account for all applicable cost sharing expenditures. When this occurs, the Office of Grants and Contracts Accounting should be notified immediately in order to ensure proper set-up in the GM System.

Projects should not be set up or allocated in the accounting records as cost share projects unless they are contractually required by the sponsor. Internal institutional support that is necessary but not contractually required should be set up by the Budget Office as other State funds outside of the matching fund group of sponsored projects.

Cost Share Documentation Requiring Special Certification and Approval Authorization
On an exception basis, cost share expenses posted to non-companion discretionary projects may be recorded as cost sharing for the applicable sponsored award. In these cases, the Principal Investigator and appropriate unit financial officer are required to complete the cost share certification form, which certifies the project can be used as matching contribution. Source accounting system support and pertinent summary schedules must accompany this certification page.

Documentation and certification of prior fiscal year cost share expenses posted to “non-companion” projects must be approved by the Director of Project Accounting or Senior Director of Grants and Contracts Accounting prior to processing. Requests that exceed 120 days of the initial posting date will follow the Late Cost Transfer process for review and approval.

Federal Salary Limitations (NIH Salary Cap)
The Cost Sharing accounting mechanism referenced above should be used to account for salary limitations applicable to NIH grant and cooperative agreement awards and extramural research and development contract awards. In so doing, the appropriate amount of effort devoted to the NIH award is visible in the accounting records of the Institute.

Refer to the G&C website for Frequently Asked Questions related to cost sharing.
http://grants.gatech.edu/main/wp-content/uploads/2014/03/FINAL_Cost-share-FAQ_1.pdf

Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for additional guidance related to sponsored cost transfer requests.

Responsibilities

Principal Investigators, assigned delegates, and unit financial officers are responsible for providing proper oversight and management of sponsored projects during the performance and close-out periods.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
11-05-2014 Office of Grants & Contracts Accounting Align with requirements of 2 CFR 200
04-01-2014 Office of Grants & Contracts Accounting Administrative review