Objective: Identify allowable/eligible cost sharing costs, describe costs in proposal budget, expect to track and document all cost sharing costs during award.
Important Points for DLCI Administrators include:
- Cost sharing should be limited to only situations where it is mandated by a sponsor or the Institute has determined that such a contribution is necessary to ensure the success of a competitive award or proposal.
- Under the OMB Uniform Guidance, it is further specified that voluntary cost sharing is not expected in federal research proposals and cannot be used as a factor during merit review.
- Cost sharing should not be included in federal research proposals unless it is explicitly described in the notice of funding opportunity, and for non-federal proposals it should be kept to a reasonable level because of the burden placed on Institute or departmental resources.
- If the PI offers cost sharing on a project when there is no requirement for such cost sharing imposed by the sponsor, the PI or the DLCI will be responsible for funding both the direct and the F&A costs associated with such a commitment. It is not possible to cost share direct costs without also cost sharing associated F&A costs.
Action Items for DLCI Administrators include:
- Examine proposal guidelines/program solicitation to determine whether cost sharing is Mandatory or Voluntary
- PI must identify and provide resources for cost sharing of direct costs
- Confirm that all identified cost sharing funds are allowable/eligible as cost sharing
- Use MIT-preferred cost sharing
- Graduate Student Research Assistant tuition subsidy
- Equipment purchase
- AY Faculty effort (discouraged unless cost sharing is mandatory), benefits, and F&A
- Prepare cost sharing budget in same level of detail as sponsor-requested budget
- Obtain letters of commitment from subrecipients and third parties
- Confirm source of F&A funds associated with cost sharing
- Do not include commitments of effort or other forms of cost sharing in text of proposal or in Current & Pending Support summaries
- Identify MIT unit responsible for fulfilling MIT-funded cost sharing commitments
- Please follow instructions for entering cost sharing in KC proposals as referenced in the KC eLearning module “KC Budget”
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Both in-kind and cash contributions by a recipient are acceptable as cost sharing when all of the following criteria are met:
- Verifiable from recipient records,
- Not included as contribution for any other federally assisted program,
- Necessary and reasonable for proper and efficient accomplishment of project or program objectives,
- Allowable as a direct cost under applicable cost principles,
- Not paid by another federal award (except as authorized by statute),
- Provided for in the approved budget when required by the federal awarding agency,
- Conform to other provisions in OMB Uniform Guidance or A-110 as applicable.
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The following cannot be offered as cost sharing commitments in sponsored projects:
- Other federal awards (if proposed project is federal funding)
- Use of MIT-owned equipment
- Institute facilities such as laboratory space
- Unallowable costs as defined in OMB Uniform Guidance, Subpart E or OMB Circular A-21, Section J
- Salary dollars above a regulatory cap, such as the NIH salary cap
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Documentation from the third party describing the value of the donated materials, supplies, and effort should be provided to RAS and sponsored accounting to substantiate the cost sharing claim.