Cost Sharing Procedure

Background

Per the Cost Sharing Policy, 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. Voluntary cost sharing should not be included in a federal proposal.

Procedure for Harvard Chan School

This page provides the Harvard Chan School-specific cost sharing procedure. Our School's Cost Sharing Decision Tool was created to help guide our administrators identify Cost Sharing types and sources. The HCSRA Cost Sharing Overview page provides an overview of the Cost Sharing information listed in the University's Cost Sharing Policy.

Important: The information on this page is a summary of information. Research administrators are responsible for reviewing the University’s Cost Sharing Policy and detailed guidance

Reason for Procedure

If cost sharing is quantified in the budget and/or budget justification, it becomes committed cost sharing (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.

This procedure and the Cost Sharing Decision Tool were created to help Harvard Chan School administrators to determine 1) if the cost sharing type has to be recorded in GMAS and 2) how to record the cost sharing source details in GMAS. However, research administrators are responsible for following the University’s Cost Sharing Policy and detailed guidance.

Summary of Procedure Steps

Procedure for Harvard Chan School

Step 1: Identify Cost Sharing Type

Use the Cost Sharing Decision Tool to identify the Cost Sharing Type, which will help determine if the commitments must be communicated to the sponsor & recorded in GMAS (if you should: quantify in budget/justification, obtain School approval, record, track, and report expenses). 

Cost Sharing Type Description GMAS Proposal Track
Expenses
Report
Expenses
Mandatory Cost sharing commitment that's a mandatory requirement per the sponsor’s guidelines, written communication, or terms & conditions ✔   ✔   ✔   ✔  
Voluntary Committed * Cost sharing commitment that's NOT a mandatory requirement per the sponsor BUT will be included anywhere in the proposal* ✔   ✔   ✔   ✔  
Voluntary Uncommitted * Cost sharing commitment that's NOT a mandatory requirement per the sponsor AND will NOT be included anywhere in the proposal* ❌  ❌    ❌ 
Over-the-Cap Salary Cost sharing commitment that's ONLY a portion of a faculty or staff member’s salary and associated fringe benefits that exceed 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 effort of Program Directors (PD/PIs and Co-PD/PIs) on sponsored training grants, awarded to the School, that do not allow direct charging PD/PI effort to the grant budget ***

* 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."
** Although Over-the-Cap Salary doesn't have to be recorded in GMAS, these expenses MUST be tracked via a companion account. The department must create the companion account via the Account Maintenance module in Wasabi and add the account string to the person's costing
*** For Harvard Chan School Training Grants, follow the steps provided in the Faculty Effort on Training Grants Policy to properly allocate and track PD/PI effort

Step 2: Identify Cost Sharing Source

Use the Cost Sharing Decision Tool to identify the Cost Sharing Source, which will help determine how the commitments will be made & recorded in GMAS (how you should: complete the GMAS request, track commitments, and document backup/approvals).

Cost 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

Step 3: Record Committed Cost Sharing in GMAS (only for Mandatory and Voluntary Committed)

Any quantifiable committed cost sharing (mandatory or voluntary) becomes a legally binding and accountable commitment to the University upon acceptance of an award; therefore, committed cost sharing must be appropriately tracked and managed to ensure the commitments are fulfilled according to the federal regulations, University policy, and the terms and conditions of the sponsored award.

The process steps below contain summarized guidance for Mandatory and Voluntary cost sharing types. Research administrators are responsible for reviewing the University’s detailed guidance:

Step

Role

Task/Activity

1

PI/GM

PI confirms, sponsor guidelines indicate, or department determines that there will be Mandatory or Voluntary Committed cost sharing on a project. Commitments for these two cost sharing types have to be recorded in GMAS, included in the proposal budget, and expenses tracked and generally reported to the sponsor

Note: A project could contain multiple cost sharing types and sources. To prevent confusion, please use the decision tool separately for each cost sharing type & source identified

2

GM

Review the Cost Sharing Policy and sponsor terms & conditions to determine allowability of cost sharing commitments

3

GM

During proposal development, inform ADF that the project includes cost sharing and ensure the cost sharing commitments are included in the proposal budget

4

GM

Mark the GMAS cost sharing approval attribute as “yes”

GMAS - Edit approval attributes

5

GM

GMAS - cost sharing approval screenshotOn the GMAS request homepage, click the “Edit” button to record the cost sharing details and upload the required documentation.

Note: Different panels will be displayed in the cost sharing form based on the cost sharing sources selected. Use the Cost Sharing Source Decision Tool to identify the source(s) and click the links below to determine how to complete GMAS, required documents to upload to the document repository, and if additional approvals have to be obtained:

 

  • Select the Cost Sharing Type and Source(s)
    • Cost Sharing Type – select Mandatory or Voluntary committed cost sharing from the drop-down list
    • Cost Sharing Source(s) – select the source(s) of the cost sharing (check all that apply)

 

 

  • Complete cost sharing details for all Budget Periods

Note: Budget periods automatically populate based on the budget periods entered in the proposal. If more than five budget periods are included in the proposal, click the right arrow to display additional budget periods

GMAS - cost sharing approval screenshot

6

GM

When complete, ask the Cost Share Approver (Catalina Diaz) to review the GMAS approval PRIOR to locking-and-routing the request

7

Cost Share Approver

Review the GMAS cost sharing details and documentation uploaded to the approval’s document repository. Work with GM, if information or clarification needed during review

8

Cost Share Approver

Notify GM after review is complete and confirm if approver could be added to signatures when GMAS request is locked-and-routed

9

GM/SRA

Notify Cost Share Approver (Catalina Diaz) when GMAS request is ready to be signed (after PI and ADF have signed request)

 

Note: For Cost Sharing GMAS requests (generated under specific conditions), list the following signatories for the Harvard Chan School [School-specific guidance]:

  • Sponsored Programs Approver = GMAS defaults to AD but Cost Share Approver will sign for this role
  • Principal Investigator = PI
  • For fellowhips: Mentor
  • Department Approver = ADF
  • Cost Sharing Approver = Catalina Diaz [GM to notify approver after ADF signs the request]

At Award Stage

10

PI/GM

Review the terms and conditions of the Notice of Award (award letter) to determine if there have been changes to the proposed Cost Sharing commitments

11

PI/GM

After reviewing committed cost sharing in the Notice of Award and the information in the GMAS approval, the department will select “Actions” at the top of the GMAS Approval screen and choose the appropriate action from the drop-down menu:

  • If no changes: if the proposed cost sharing remains the same, select “Confirm current version of form.” The status of the approval will be updated to “Done.” IMPORTANT: Inform the SRA that the award includes Cost Sharing. This could be done by email or by completing the Award Setup Checklist
  • If Changes: select “Create new version of the form”. The status of the approval will be updated to “Needed” and the homepage of a new cost sharing request will be displayed. When this new cost sharing request is generated, a new version of the cost sharing form will be created with all data fields pre-populated
  • If applicable, creates a companion account to track expenses and update the person costing to include the new companion account

 

Note: GM’s are required to enter the GL budget in GMAS after award set-up

12

SRA

Reviews the Award Setup checklist and submits a Datasheet Jotform to OPS

 

Note: GMAS must reflect Cost share: Key information (segment homepage) and Approvals. Please inform OPS Team if any modifications need to be made.

13

OPS

Reviews the Datasheet Jotform and the Key information section of GMAS, to see if committed cost sharing was included in the project. Enters the applicable cost sharing information 

Step 4 (At Award Stage): Track (companion account) and Report Commitments, if applicable

Mandatory and Voluntary Committed cost sharing MUST be recorded in GMAS; follow the instructions provided above. Over-the-Cap Salary cost sharing MUST NOT be recorded in GMAS but MUST be tracked via a companion account. The department must create the companion account via the Account Maintenance module in Wasabi and adds the account string to the person's costing.

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 WasabiA 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: 275.45300.XXXX.123456.377171.0001.15399 
  • Non-Sponsored Account String (Companion Account): 275.45300.XXXX.000001.377171.0001.15399

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

Resources

University-wide Resources

Harvard Chan School-specific Resources