The source for most of the information on this page: OSP Website
Page Contents- Background
- Policy and Guidance for Harvard University
- Procedure for Harvard Chan School
- Cost Sharing Types
- Cost Sharing Sources
- Companion Accounts to Track Cost Sharing
- Allowable Expenditures
- Changes Requiring a GMAS Request
- Supporting Documentation Required in GMAS
- Resources
- School Contact
Background
Cost sharing is any project cost that is not reimbursed by the sponsor to support the scope of work defined by the federal or non-federal sponsored award.
Harvard strongly discourages cost sharing, unless it's a commitment required by the federal or non-federal sponsor. If cost sharing is quantified in the budget and/or budget justification, it becomes committed (a binding requirement of the award), which must be tracked in GMAS and may require reporting. Failure to appropriately document cost sharing commitments from verifiable official University records could result in audit findings and require the return of funds to the sponsor.
Policy and Guidance for Harvard University
Research administrators are responsible for reviewing and following the information in Harvard University’s Cost Sharing Policy and detailed guidance. The Harvard Chan School resources referenced below are expected to be used in conjunction with the University-wide policy and guidance and the sponsor terms.
Procedure for Harvard Chan School
Research administrators are responsible for reviewing and following the information in Harvard University’s Cost Sharing Policy and detailed guidance. The Harvard Chan School Cost Sharing Procedure provides additional school-specific instructions. Our School's Cost Sharing Decision Tool and Cost Sharing Quick Reference Guide were created to help guide our administrators through the process and available resources. Important: It is expected that our School's procedure and resources are to be used in conjunction with the sponsor terms and University-wide policies and guidance, as they provide more information that isn’t referenced in this school-specific procedure.
Cost Sharing Types
Use the Cost Sharing Decision Tool to identify the Cost Sharing Type, which will help determine if the cost sharing commitment has to be recorded in GMAS, included in the proposal budget, and if expenses have to be tracked and reported to the sponsor.
Table 1: Cost Sharing Types and DescriptionsCost Sharing Type | Description | GMAS | Proposal |
Track Expenses |
Report Expenses |
---|---|---|---|---|---|
Mandatory | Mandatory requirement per the sponsor’s guidelines, written communication, or terms & conditions | ✔ | ✔ | ✔ | ✔ |
Voluntary Committed* | NOT a mandatory requirement per the sponsor BUT will be included anywhere in the proposal* | ✔ | ✔ | ✔ | ✔ |
Voluntary Uncommitted* | NOT a mandatory requirement per the sponsor AND will NOT be included anywhere in the proposal* | ❌ | ❌ | ❌ | ❌ |
Over-the-Cap Salary** | ONLY a portion of a faculty or staff member’s salary and associated fringe benefits exceeding regulatory maximum imposed by the sponsor (e.g., NIH’s salary cap) | ❌ | ❌ | ✔** | ❌ |
For SPH: Faculty Effort on Training Grants*** | Harvard Chan School's 10% institutional support for Faculty Effort (PD/PIs) on sponsored Training Grants that do NOT allow direct charging of PD/PI effort to the grant | ❌*** | ❌*** | ✔*** | ❌ |
* Per the Cost Sharing Policy, "Harvard strongly discourages cost sharing, unless it's a commitment required by the federal or non-federal sponsor. Voluntary cost sharing should not be included in a federal proposal."
** Over-the-Cap Salary: NOT recorded in GMAS but MUST be tracked via a companion account, which the department must create in Wasabi (Account Maintenance) and add to the person’s salary costing
*** Harvard Chan School Training Grants, please refer to the information provided in the Faculty Effort on Training Grants Policy
Cost Sharing Sources
Use the Cost Sharing Decision Tool to identify the Cost Sharing Source, which will help determine how the commitments will be made. For Mandatory & Voluntary Committed cost sharing types, it will also help determine how to complete the cost sharing details in GMAS, including which documents & prior approvals to upload to the GMAS document repository.
Table 2: Cost Sharing Sources and DescriptionsCost Sharing Source | Description |
---|---|
University/School/Department Funds | Commitments that are paid from University funds using gift, endowment, or other non-sponsored sources (represented by the 000001- 054999 and 300000-699999 fund ranges). These types of commitments are generally tracked via a companion account, which the department must create in Wasabi (Account Maintenance) and add to the person’s salary costing |
Sponsored Contributions (or Matching Funds) | Commitments that are paid from non-federal sponsored awards at Harvard (represented by the fund range 200000-299999). Prior approval or authorization must be obtained from non-federal sponsor providing the cost sharing commitment. These types of commitments must be tracked manually by the department or local unit managing the award |
In-Kind Cost Sharing | In-kind cost sharing are those contributions wherein the value can be readily determined, verified, documented, and justified but where no actual cash is transacted in securing the good or service comprising the contribution. When applicable, an estimated value of the in-kind cost sharing should be determined and documented based on the fair market value at the time of the accepting award. In-kind cost sharing must be tracked manually by the department/local unit managing the award |
Subrecipient Cost Sharing | Commitments, expenses, or in-kind cost sharing made by subrecipients where Harvard is the prime awardee. Cost share is included in the subrecipient’s proposal and documented in the subaward agreement. These types of cost sharing commitments cannot be tracked in Harvard’s systems; therefore, the commitments must be verified manually by the department or local unit managing the award through subrecipient invoices. Failure to comply will become Harvard’s (the Prime’s) responsibility |
Companion Accounts to Track Cost Sharing
When a sponsored project is awarded, a 33-digit sponsored account string is set up in GMAS and the general ledger. To track cost sharing, the department creates a companion account in the Account Maintenance module of Wasabi. A companion account is required for all committed cost sharing direct expenses associated with a sponsored award.
A companion account is an account that shares the same sponsored activity and subactivity value with a non-sponsored fund value in the Harvard Chart of Accounts. By transacting to a companion account, users can track and access the related financial expenditures in the GL that are not posted to the sponsored award. Companion accounts are used for University contributions to costs sharing and to capture over-the-cap salary for effort reporting purposes. and should be coded using a sponsored activity and subactivity value with a non-sponsored fund.
Companion Account Example
The 33-digit sponsored account string is set up in GMAS and the general ledger, using sponsored fund 123456. To track cost sharing expenses, the department creates a Companion Account using a non-sponsored fund and the sponsored activity-subactivity combination.
- Sponsored Account String: 275.23200.XXXX.123456.207171.0001.12345
- Non-Sponsored Account String (Companion Account): 275.23200.XXXX.000001.207171.0001.12345
Companion Account Decision Chart
Table 8: Decision Chart for Cost Sharing Companion Account Coding
|
Mandatory Committed Cost Sharing |
Voluntary Committed Cost Sharing |
Voluntary Uncommitted Cost Sharing |
Over-the- Cap Salary |
University Contributions are: University Funds (gift, endowment, or other unrestricted non- sponsored sources in the fund range of 000001-054999 and 300000-699999) |
Required* |
Required* |
Not required for non-salary expenses** |
Required* |
Sponsored Contributions are: Non-federal sponsored awards (in the fund range of 200000-299999) |
Not required |
Not required |
Not required |
N/A |
In-Kind Cost Sharing is: Non-cash contribution of goods and services from the University or donations from third parties |
Not required |
Not required |
Not required |
N/A |
* There may be exceptional cases in which a companion account cannot be used to track cost sharing. Therefore, a detailed listing must be provided at interim reporting periods and at award closeout.
** For Harvard Chan School, only salary-related expenses MUST be tracked via a companion account for the School’s F&A rate calculation and effort reporting purposes but do NOT have to be tracked in GMAS.
Allowable Cost Sharing Expenditures
Cost sharing commitments can be met using direct or indirect costs that are allowable, allocable, reasonable, and consistently accounted for in accordance with University and sponsor policies.
Direct Costs
1. Committed Effort
Salary and fringe benefits associated with faculty and staff committed effort. Note that over-the cap salary, or salary paid to an individual in excess of a sponsor-designated limit, cannot be used to meet a cost sharing commitment.
2. Other Direct Costs
Direct costs that are considered allowable on a sponsored award could be cost shared. Some examples include the following:
- Travel expenses (Note: Cost sharing for a federal award must comply with federal travel regulations including lowest economy airfare and the Fly America Act as outlined in the University Travel Policy.)
- Laboratory and other supplies
- Consultant costs and other professional services
- Equipment items that do not meet the capitalization threshold
The purchasing of goods and services as cost sharing expenses must comply with federal procurement requirements including use of the vendor justification form and debarment certification, as outlined in the University Procurement Policy.
3. Equipment
Moveable, tangible personal property with a useful life of one year or more and a per-unit acquisition cost of $5,000 or more. Capital equipment includes scientific equipment, fabrications, and software. Capital equipment is recorded on the University’s general ledger as a capital asset and expensed to the appropriate capital equipment object code.
Existing capital equipment cannot be offered as cost sharing. Rather than committing the use of existing Harvard-owned equipment as cost sharing, proposals should characterize the equipment as "available for the performance of the project at no direct cost to the sponsored award.”
Indirect Costs or Facilities and Administrative (F&A) Costs
Indirect costs or F&A are costs that are incurred for common or joint objectives and, therefore, cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity.
Indirect costs may be offered in a proposal to meet cost sharing requirements imposed by the sponsor and must be approved by the sponsor in order for the amount to be included as part of a cost sharing commitment.
Specifically, in the case of a federal award, the federal agency’s approval can be based on the acceptance of a budget that clearly includes F&A as part of cost share or a specific approval by the agency. Without such approval the indirect costs cannot count toward cost sharing requirements.
1. Unrecovered Overhead
The amount of indirect costs not recovered from a sponsor due to a sponsor funding an award with an indirect cost rate below the University’s federally negotiated F&A rate. This type of unrecovered overhead cannot be included as part of cost sharing or matching without the prior approval of the sponsor.
2. Overhead on Cost Shared University Resources
When direct costs using the University funds are included as cost sharing commitments, the associated indirect cost is not visible in General Ledger. Overhead on cost shared University resources may be included as part of the University cost sharing commitment only if it is approved by the sponsor.
Cost Sharing Changes Requiring a GMAS Request
Table 3: Types of Cost Sharing Changes Requiring a GMAS Request
# |
Type of Change |
GMAS Cost Sharing Request |
Dept Approval Required? |
---|---|---|---|
1 |
Change in total cost sharing amount |
Required |
Yes |
2 |
Change from One Source to Another (to or from University, Sponsored, In-kind, sub recipient) |
Required |
Yes |
3 |
Change from one sponsored fund to another sponsored fund |
Required |
Yes |
4 |
Change from one University fund to another University fund |
Recommended |
No |
5 |
Change to budget line items (no change to total) |
Recommended |
No |
6 |
Change from one sub-recipient to another |
Required |
Yes |
7 |
Change of In-Kind source and/or description |
Required |
Yes |
8 |
Change to or from Voluntary / Mandatory |
Required |
Yes |
Supporting Documentation Required in GMAS
Document |
Description |
At Proposal Phase |
At Award Phase |
During Award Phase |
At Closeout Phase |
Repository |
---|---|---|---|---|---|---|
Budget |
Included in proposal package |
Required |
|
|
|
Request |
Revised Budget (See Note 1) |
Included in proposal package |
|
Required (if changed from proposal) |
Required (if changed from awarded amt) |
|
Request |
Transaction Listing |
HART Report |
|
|
Required (at reporting) |
Required |
Cost Sharing |
Table 5: Sponsored Contributions (Matching) Documentation
Document |
Description |
At Proposal Phase |
At Award Phase |
During Award Phase |
At Closeout Phase |
Repository |
---|---|---|---|---|---|---|
Sponsor Approval |
Approves use of funds for cost sharing |
Required |
|
Required (if changed from Awarded amt) |
|
Cost Sharing |
Revised Budget (See Note 1) |
For sponsored matching fund |
|
Required (if changed from proposal) |
Required (if changed from awarded) |
|
Cost Sharing |
Acknowledgement of reduced commitment |
Provided by sponsor, if commitment is not met |
|
|
Required (if reduction is known during the award) |
Required |
Cost Sharing |
Document |
Description |
At Proposal Phase |
At Award Phase |
During Award Phase |
At Closeout Phase |
Repository |
Cost Share Commitment |
Sub-recipient commitment to cost share |
Required |
|
|
|
Subagreement |
Budget (See Note 1) |
Included in subagreement |
Required |
|
|
|
Subagreement |
Revised Budget (See Note 1) |
Included in Subagreement |
|
Required (if changed from proposal) |
Required (if changed from award) |
|
Subagreement |
Confirmation of Cost Share commitment |
From sub- recipient indicating commitment was met. |
|
|
Required (at reporting) |
Required (may be noted on invoice) |
Cost sharing |
Document |
Description |
At Proposal Phase |
At Award Phase |
During Award Phase |
At Closeout Phase |
Repository |
Value & Description of In-Kind Commitment |
Provided by entity best able to identify the value of the goods or services |
Required |
Required (if changed from proposal) |
Required (if changed from award) |
|
Cost Sharing |
Confirmation In-Kind commitment was met |
Provided by entity best able to identify the value of the goods or services |
|
|
May be required at reporting |
Required |
Cost Sharing |
Note 1: Budget & Revised budgets containing cost share information are noted here for consistency, but they are typically included in the proposal package (or subagreement for subrecipient cost sharing) and can be uploaded as they currently are in the Request or Subagreement document repositories. There should be no duplication of uploaded documents.
In addition to the documentation noted above that is uploaded by the department/local level managing units, OSP Research finance uploads all approved invoices and reports to the financial deliverables repository which include cost sharing information when applicable.
Resources
University-wide Resources
- Harvard University's Cost Sharing Policy
- Cost Sharing FAQ
- Completing the Cost Sharing Form at Proposal Job Aid
- Reviewing Cost Sharing – Department Administrator Job Aid
- Reviewing Cost Sharing – Central Administrator Job Aid
- Completing a Cost Sharing Request Job Aid
- GMAS Revision for Cost Sharing – Central Office Operations Job Aid
Harvard Chan School-specific Resources
- Cost Sharing Quick Reference Guide
- Cost Sharing Overview
- Harvard Chan School Cost Sharing Procedure
- Cost Sharing Decision Tool
- Cost Sharing on Sponsored Awards Fishbowl Presentation (Zoom video)
- Cost Sharing on Sponsored Awards Fishbowl Presentation (PowerPoint)
- Questions? Contact HSPH’s Cost Share Approver: Catalina Diaz
Related Policies
- Sponsored Expenditure Guidelines
- Effort Reporting Policy
- Sponsored Financial Reporting and Close Out Policy
Related Documents
- OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
- Memoranda 01-06 -- Clarification of OMB A-21
- National Institutes of Health (NIH) Salary Cap Summary
- Federal Acquisition Regulation: Limitation on Allowable Government Contractor Employee Compensation Costs (2016) - Applies to federal contracts only
- University Cost Sharing Procedure Guide
School Contact
Harvard Chan School's Cost Share Approver: Catalina Diaz, Associate Director, Research Finance & Compliance