OMB Circular A-110, Subpart C – Post-Award Requirements, Section 23 states:
a) All contributions, including cash and third party in-kind, shall 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 federally-assisted project or program.
3. Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
4. Are allowable under the applicable cost principles.
5. Are not paid by the Federal Government under another award, except when 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 Circular, as applicable.
b) Unrecovered indirect costs may be included as part of cost sharing or matching only with the prior approval of the Federal awarding agency.
In Plain Words
· Cost sharing must be tracked. The funds for the cost sharing must be available if it is committed in the proposal! Cost sharing should be limited to circumstances that are required by the Sponsor (if mandatory in order to receive the award) or involve an unusual situation.
· If the cost sharing involves effort, it must be included on the personnel effort report. Make sure to work with the Office of Grants and Contracts to ensure the contributed effort is entered for the personnel effort report in order for the person to certify their effort correctly.
· Cost sharing involving operating expenses requires the establishment of a separate speedtype in order to specifically tie the cost sharing to the specific award.
· Cost sharing that is designated for one award can not be used as cost sharing for another award.
· All expenses charged to the cost sharing speedtype must be restricted to the same cost principles as the main award and must be necessary costs for the accomplishment of the award objectives.
· Expenses that are not allowed on the main award are also not allowed to be charged to the cost sharing speedtype.
· Cost sharing can not be provided by federal funds.
Refer to the campus Cost Sharing policy for further definition, requirements, and processes.
OIG Audit Report: “Audit of Head Start Matching Costs for the Period March 1, 2006, Through February 29, 2008 - Community Action Commission of Belmont County, Inc.” March 9, 2009, Office of Inspector General, Department of Health & Human Services