This page includes answers to a number of questions about cost sharing. Scroll through the list of questions. By clicking on the question, you will see the answer. If you have additional questions that are not addressed here, send a note to the Director, Cost and Management Analysis.

Any resources linked to an answer will open in a separate browser window.

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COST SHARING OF EFFORT (General questions)

1. If an individual commits 50% FTE to a project, what is that 50% of? What does the concept of 100% FTE mean?
   
   
2. A postdoc in my department is funded 100% on three different sponsored projects. She increases the number of hours that she works on one project, but does not decrease her effort on the other projects, i.e., she is working more hours. Should we treat the extra effort as cost sharing?
   
   
3. When I prepared the proposal, I committed to cost share a percentage of an individual's effort. I knew the person's current salary, but did not know for sure the future salary. I included an estimate of the salary increase, but the individual's actual future salary may be more or less than my estimate. Is my cost sharing commitment tied to the estimated dollar amount included in the budget or the percentage of effort?
   
   
4. When preparing my proposal budget, can I use the term "as needed" and not include any dollars as committed cost sharing when referring to personnel who may be asked to consult or advise occasionally on the sponsored agreement?
   
   
5. When preparing my proposal budget, can I use the term "part-time at no cost" and not include any dollars as committed cost sharing when referring to personnel who will be working on the sponsored agreement?
   
   
6. If someone "works" in support of a sponsored project, but the position was not in the proposal and is paid by gift or other non-sponsored funds, is the effort cost-sharing?
   
   
7. What if someone is paid by gift funds (or other non-sponsored funds) and is committed to more than incidental effort in the narrative of a sponsored project proposal? If the individual is budgeted at 0% FTE (and consequently no dollar amount), is that cost sharing?
   
   
8. If a sponsor lines out the effort of a specific person in the awarded budget, for example, a 50% FTE Research Assistant, is that cost-sharing?
   
   

PI EFFORT (Mandatory requirement)

9. A PI is submitting a proposal for research project funding. He does not want to charge any of his salary to the project, and therefore lists no commitment of effort in the project budget. Is any effort that he puts in to the project "voluntary," and therefore not required to be cost shared?
   
   
10. For the proposal described in Question 9 (above), if the PI says in the proposal that he expects to contribute 10% of his time to this project, must he cost share 10% of his salary, or is 1%, the mandated minimum, adequate?
    
    
11. A PI commits to summer effort only on a project. Is that an adequate commitment of effort by the Principal Investigator?
    
    
12. If a PI requests summer funding only, how is Academic Year effort related to that project treated?
    
    
13. A PI is submitting a proposal for a small grant intended to fund the time of a graduate student Research Assistant only. The award is specifically to fund that activity, and the sponsor does not expect any PI effort. Is this what OMB refers to as a "student augmentation" award?
    
    
14. A PI is submitting a proposal for an equipment grant. Must she specify some level of her own effort to be committed to the project?
    
    
15. Do I need to include cost sharing in my proposal for the PI who directs a research project but only provides minimal effort as opposed to active participation?
    
    
16. Do we need to set up a cost sharing activity/account for a faculty member who directs a student on an NIH training grant?
    
    

PI EFFORT (Other questions)

17. A PI commits effort and requests salary on a sponsored project, but then rebudgets his salary mid-year without reducing his effort. Is this considered cost sharing?
    
    
18. Do we need to cost share effort for faculty with a joint VA/SU appointment?
    
    
19. Is the effort of a faculty member who was committed in a research project proposal considered cost sharing if it the salary is paid from clinic activities/accounts (e.g. funded by Stanford Hospital and Clinics)?
    
    
20. I've heard that the School of Medicine requires that all faculty effort be proposed and budgeted, and not offered as cost sharing. Is this true?
    
    

ACADEMIC YEAR vs. 12-MONTH APPOINTMENTS

21. How do we account for cost sharing effort for faculty with a 9-month academic appointment, who is paid over 12 months?
    
    

NIH SALARY CAPS

22. How do we account for effort on NIH grants for faculty over the NIH salary cap?
    
    

STUDENT COSTS

23. If a graduate student who was committed in a proposal devotes effort to a sponsored agreement and receives salary support from a gift or fellowship activity/account, it is cost sharing? Is a distinction made if support is in the form of a stipend versus a salary?
    
    
24. If a student is participating on a sponsored agreement with no salary requested because he/she is supported partially by a training grant and partially by a gift activity/account, is the portion supported by the gift cost sharing?
    
    
25. If a sponsor won't pay part or all of the tuition allowance for an RA working on a sponsored project, and that tuition allowance is charged to other department funds, is it accounted for as cost sharing?
    
    

EQUIPMENT AND FACILITIES

26. If a proposal states that University equipment will be used to complete the project, do we have to account for this as cost sharing?
    
    
27. If a project will require the purchase of a new piece of special-purpose equipment, can part or all of its costs be offered as cost sharing?
    
    
28. Can University facilities such as laboratory space be offered as cost sharing?
    
    
29. How should I document a third-party in-kind contribution of equipment that is used to meet part of a cost sharing commitment? What are the guidelines for estimating the value of third-party in-kind contributions?
    
    

BUDGET REDUCTIONS AND ACTIVITIES FROM MULTIPLE FUNDING SOURCES

30. On my proposal for a "major project," I included administrative costs related to the project, but the sponsor disapproved them. Must these costs now be treated as cost sharing?
    
    
31. If the total amount of a proposed budget is reduced by the sponsor when the award is received, is the difference cost sharing?
    
    
32. If a sponsor provides a portion of funds in support of an existing university program is the balance (University supported) cost sharing?
    
    
33. When a conference is funded by a grant, and the amount of the grant plus the conference registration fees is not enough to cover the entire cost of the conference, is the amount borne by Stanford considered cost sharing? How is it accounted for? What if a company underwrites a portion of the conference?
    
    

HANDLING OVERDRAFTS

34. Are activities/accounts with cost overdrafts or overruns, that are not reimbursed by the sponsor, accounted for as cost sharing?
    
    
35. I had an award which began before September 1994 that now has an overrun. Is it necessary to record the overrun as cost sharing, since the award itself did not fall under the policy?
    
    
36. Must I fill out a Cost Sharing Authorization Form to request a cost sharing activity/account related to an overdraft?
    
    
37. If I am monitoring my activity/account, and anticipate that it might go into overdraft, and therefore transfer costs from the activity/account before the end of the award, is that accounted for as cost sharing?
    
    
38. If the overdraft is a small dollar amount, must it be be captured in a cost sharing activity/account?
    
    
39. How do I handle overdrafts in a function 1 sponsored instruction account?

COST SHARING FROM PRIOR FISCAL YEARS

40. Ooops! I have a five-year sponsored project, now in year five, which requires cost sharing. We never charged anything to a cost sharing activity/account! How do I account for cost sharing from previous fiscal years?
    
    

VETERINARY SERVICE CENTER TRANSFERS

41. How do I make a transfer of a Veterinary Service Center charge from a sponsored activity/PTA to a cost sharing PTA?
    
    

MANAGEMENT OF COST SHARING ACCOUNTS

42. If we have cost sharing on more than one activity/account (e.g., related to two separate awards), will we have to initiate fund transfers to both?
    
    
43. How do you account for cost sharing on an award that includes several different departments and/or schools?
    
    
44. What kinds of things can I use to meet a cost sharing requirement? Are there any that do NOT have to be tracked in cost sharing activities/accounts?
    
    
45. Can funds from either a federal or non-federal source be used to cost share on another award?
    
    

EFFECTIVE DATE AND APPLICABILITY TO PROPOSALS/AWARDS

46. When did Stanford's cost sharing policy become effective?
    
    
47. After September 1, 1994, is the cost sharing policy applicable to continuations? supplements? incremental funding? no-cost extensions?
    
    
48. Does cost sharing apply to non-federal sponsors?
    
    

For a full-time employee, 100% Full-Time Equivalent (FTE) encompasses all of the time that an individual spends doing the work for which he or she is being paid. For exempt staff, including faculty and Academic Staff, compensation is not based on the number of hours worked, but rather it is for whatever amount of time it takes to get the necessary work accomplished. Any of the "extra" hours that an individual may spend doing Stanford work, sometimes called "midnight oil" or "sweat equity," is part of 100% FTE. If a faculty member commits 50% FTE to a project, he or she is saying that half of ALL THE EFFORT he or she puts into their Stanford work will be directed toward that project. SEE ALSO Effort Allocation Resource Page

No. Since there can be no more than 100% FTE, there can be no cost sharing when 100% FTE is funded by sponsored projects. However, in this situation, you may have to go back and adjust her allocation of effort on all three projects.

Whenever anyone is funded 100% on sponsored funding, it is very important to assure that the apportioning of time and effort is reasonably accurate. Effort is allocated over the base of ALL time spent doing Stanford work. In this case, 100% effort includes the total amount of the postdoc's effort on the various projects on which she is working. If she significantly increases the %FTE spent on one project, then the %FTE on the other projects will necessarily be reduced and payroll records must be adjusted.

REMINDER: NO faculty should be 100% funded on sponsored projects. Effort should be reserved and charged to non-sponsored accounts for the other academic and administrative duties of the faculty member.

The cost sharing commitment is tied to the specified percentage of effort. Depending on what happens with salaries in the future, the effort may represent more or less than the estimated amount included in the budget. As long as the committed effort has been expended, the cost sharing commitment has been met.

Yes, because it is difficult to determine the amount of time the personnel will contribute, you may use the term "as needed" when personnel are expected to work an undetermined, incidental amount of time. In this situation you do not need to include dollars as committed cost sharing or track them in a cost sharing activity/account.

No, the amount of time expected to be contributed on a part-time basis to a sponsored agreement needs to be estimated and the associated dollars should be recorded in the proposal budget as cost sharing. See question 4 for personnel used purely in an occasional advisory or consultative capacity.

No. According to both Stanford policy and the clarification issued on this point by the Office of Management and Budget (OMB), effort devoted to a sponsored project which was not committed to the sponsor in the proposal is not considered cost sharing.

The clarification [ pdf file ] issued by OMB in January, 2001, states:

Voluntary uncommitted cost sharing should be treated differently from committed effort and should not be included in the organized research base for computing the F&A rate . . .

Yes. If the effort is more than incidental, then it has been committed and must be recorded in a cost sharing activity/account. The proposal and budget should specify the level of effort committed and related dollar amounts identified. If this amount is not identified as a project expense, then it is cost sharing.

If the scope of work is reduced and the individual does not work on the project, then there is NO cost sharing. However, if the individual still works on that project as proposed, and is funded with other University funds, then it IS cost sharing.

Stanford's policy states that "proposals should accurately represent the amount of time that key personnel are committing to the project." Stanford requires its Principal Investigators to commit at least 1%FTE during the period in which effort is devoted (academic year, summer quarter only, or both). [see memo from Charles Kruger and Geoff Grant]

This requirement does NOT extend to:

• equipment grants
• dissertation support, training grants or other awards intended as "student augmentation"
• limited-purpose awards characterized by Stanford as Other Sponsored Activities, including, for example, travel grants, conference support, etc. (See RPH 3.2 for definition and further examples of Other Sponsored Activities.)
  
  

When a commitment of PI effort is made and a corresponding amount of salary is NOT directly charged to the project, that amount of salary must be treated as cost sharing.

See further discussion in question 10, below.

This faculty member should propose all direct effort as he intends to devote it (taking into account the fact that adjustments may be required later based on the actual award and progress of the work). If he intends to expend 10% of his effort directly on this project, he should include that in his proposal. If the project is awarded on that basis, and he expends that amount of effort, but does NOT charge the project, then 10% of his salary should be treated as cost sharing. [See also Proposing, Charging and Reporting Faculty Effort.]

Yes. Stanford and sponsors expect that research projects require SOME commitment of PI effort, but that effort may be expended at any time during the year - summer months only, academic year only, or both.

There are a few possible answers to this question, depending on circumstances:

1. If the PI requests and receives salary support to work on a project during the summer, expends the effort during the summer, and makes no further commitment of academic year effort to the project, then effort during the academic year is "voluntary" and does not need to be accounted for as cost sharing. During the School Year, it may be impossible to separate effort that is "research" from that which is "teaching," as it is all part of the faculty member's academic effort.
   
   
2. If, on the other hand, the PI expects to dedicate a significant portion of his effort during the academic year directly to the research project, then that commitment of effort, in addition to summer effort, should be expressed in the proposal. For example, concentration on a research project with a resulting decrease in teaching load would be an example of "significant academic year effort." If the project is funded and the effort expended, then the salary initially proposed for the summer is charged directly. Additional, significant effort committed during academic year effort should be either charged directly or cost-shared.
   
   
3. Occasionally, a PI receives summer funding, but uses it, with the sponsor's approval, to support work done during the Academic Year (and not during the summer). In this case, the academic year effort should be charged to the project when it is expended. This may require rebudgetting of the award, which most sponsors will allow.
   
   

Yes. This is one example of an award intended to provide support to a student. Other examples include fellowship awards and training grants. In these cases, the PI's effort will be spent working with the student, and can be appropriately categorized as "academic oversight."

See also the answer to question 16.

No. The OMB clarification supports Stanford's policy that some kinds of projects, including equipment grants or projects for dissertation support or "student augmentation," do not require a commitment of PI effort.

Yes. Stanford requires a commitment of AT LEAST 1%FTE on the part of the Principal Investigator during the period in which effort is devoted. This commitment of effort, if not reflected in a corresponding direct salary charge, must be accounted for as cost sharing. Any exception to this policy for research projects requires a written explanation and the approval of Office of Sponsored Research (or the School office submitting the proposal). [see memo from Charles Kruger and Geoff Grant]

No, this is not a cost sharing commitment by the faculty member. These proposals should include the following statement:

"The effort listed for each training faculty member reflects a commitment of their overall academic responsibility related to instruction and not a percentage of their sponsored research effort."

See also the answer to question 13.

Yes, because the PI is providing the effort committed in the proposal, the effort must be captured either on the sponsored project or in a cost sharing activity/account. As soon as this occurs, you should set up a cost sharing activity/account by sending the Cost Sharing PTA Attribute Setup Request [ downloadable file ] to the Office of Sponsored Research (OSR).

No, we surveyed departments that have joint VA/SU faculty and found that those faculty that have a portion of their salary paid by Stanford rarely devote effort to a project without requesting commensurate salary.

Yes, because the source of the salary is University funds and the salary is paid through the University's payroll, even though the funds are transferred from Stanford Hospital and Clinics.

Yes, the School of Medicine requires that all grant/contract proposals and/or awards must contain and identify faculty effort, and reflect salary support for the faculty in an amount equal to the percentage of time to be spent on the project, consistent with the policies of the sponsor.

If you are in the School of Medicine, please contact your RPM for more information about this.

Cost sharing is based on effort and salary earned, which may or may not be directly connected with the pay process. For example, if Prof. Nobel cost shares 10% of effort during the academic year, and does not expend any effort during the summer, the amount of cost sharing is 10% X 9-month salary, regardless of when it is paid. There is no effort during the summer, therefore no cost sharing in the summer.

If Prof. Nobel elected to receive his 9-month salary spread over 12 months, the sponsored project and related cost sharing activity/account should be charged the appropriate percentage of his 9-month salary during the academic year.

Apply the effort percentage to the cap amount to calculate the charge to the project or to a related cost sharing activity/account. Use the "Unallowed Salary Over Cap" GL code (92195 or 94185) for the amount over the cap, and charge it to a non-sponsored activity/account. "Unallowed Salary Over Cap" GL code should not be used with a cost sharing account. The use of the special GL code allows these costs to be appropriately included in the organized research base. However, since they are unallowable, they should not be reflected in a cost sharing activity/account, as they may not be reported to the sponsor nor used to meet a cost sharing commitment.

Please refer to Research Policy Handbook 3.8, Salary Cap Administration, and to the cost sharing salary cap examples provided.

If the student is being paid a stipend from another source, it should NOT be accounted for as cost sharing because stipends are paid to students for training rather than effort, and are not included in the Modified Total Direct Cost (MTDC) base. If the student has an appointment as a Research Assistant and is being paid a salary from another non-sponsored project source, it IS cost sharing. Salaries are paid for work being performed, and are part of the MTDC base.

YES, if the gift activity/account is being charged SALARY; NO, if the gift activity/account is being charged a STIPEND. Stipends are not part of the MTDC base and are never accounted for as cost sharing. Similarly, the portion charged to the training grant is NOT cost sharing. See also question 23.

No. The tuition allowance is excluded from the MTDC base, so it does not have to be accounted for in cost sharing activities/accounts. In this case, the tuition allowance could be offered to a sponsor in order to meet a cost sharing requirement or as voluntary cost sharing, but there is no separate requirement to record it in a cost sharing account/activity.

No. Stanford does not allow the cost sharing of Stanford-owned or government-owned equipment, unless the receipt of the award is contingent upon such cost sharing. This is because removing cost-shared equipment from the equipment depreciation cost pool requires cumbersome accounting procedures.

As an alternative to offering equipment as cost sharing, you may use the following recommended wording in the proposal's budget justification or "resources and environment" section:

The equipment is available for the performance of the sponsored agreement at no direct cost to the sponsor.

Yes. If a project requires the acquisition of new equipment as a condition of an award, it is acceptable to purchase the equipment and cost share all or part of it. For example, in an equipment grant award, the equipment can be accounted for as cost sharing. We would account for the piece of equipment as cost sharing by recording it in a cost sharing PTA. The equipment must be identified as cost sharing in Stanford's Capital Asset Management System, Sunflower Assets.

No, University facility costs are charged to sponsors through the indirect cost rate. Instead of characterizing the use of facilities as cost sharing, the proposal budget justification may state that the facilities are "available for the performance of the sponsored agreement at no direct cost to the project."

Gifts of property for university purposes are recorded at fair market value as of the date of the donation (see Administrative Guide Memo 42.2 [pdf file]). The Departmental Property Administrator (DPA) will create a record of the donation by using iProcurement to set up a no-cost Rapid Purchase Order (RPO), then create a single Sunflower Assets (SFA) record for the main item. The Property Management Office (PMO) will determine the Fair Market Value (FMV), modify the SFA record to reflect discounted prices and FMV, and will maintain complete files on donated equipment. Detailed information is available in the Property Manual, Chapter 2 "Donations to Stanford."

Yes, when a sponsor disapproves a proposed administrative expense, AND the cost is still incurred to support the project, the actual amount expended for the project and not funded by the sponsor must be treated like cost sharing and placed in a cost sharing (Fund Class 127) account. In this situation, the amount that is cost shared may be less than the amount that was originally proposed. These costs, while disapproved by the sponsor, are not unallowable. Once incurred they must be captured in a Fund Class 127 account. They can be used to satisfy a cost sharing commitment. See Research Policy Handbook 3.6, Charging for Administrative and Technical Expenses and related questions in the Administrative Charging Implementation Guidelines for more guidance.

No, as long as the reduced award reflects a corresponding reduction in the scope of work. In some cases it may be prudent to prepare and submit a revised budget and scope document.

In this context, the distinction between a grant and a contract is relevant. A grant is used when the purpose is to accomplish a "public purpose," including carrying out research, defined in A-110 as "a systematic study directed toward fuller scientific knowledge or understanding of the subject studied." This basic research is not intended to result in a specific product, but rather to follow a general direction. In the case of a grant, a reduction in budget does not indicate an agreement to cost share.

In contrast to a grant, a contract is a procurement transaction between the sponsor and the recipient. In the case of a contract, the reduction in budget and scope must be clearly documented.

No, the University-funded portion of the research program would not represent cost sharing, unless it had been COMMITTED to the sponsor as part of the University's proposal for the sponsored portion of the research program. Absent this commitment, the University-supported effort would be treated as departmental research, a function 1 activity. In this context, it is important to note that space used for departmental research is coded differently than space used for sponsored research. This is also true for non-research programs, such as Sponsored Instruction or Other Sponsored Activities.

When preparing the budget for a conference grant, the estimated registration fees are included to fund a portion of conference costs and are accounted for as program income. If the actual registration fees received are less than anticipated, and the combination of the awarded grant amount and the registration fees are inadequate to cover the COMMITTED conference costs, the difference must be accounted for as cost sharing. A function 1 cost sharing activity/account should be opened in fund class 127. If the conference is being partly underwritten by a corporate sponsor, the terms of that arrangement must be evaluated. The funding from the corporate sponsor might itself qualify as "Other Sponsored Activities." If the funding qualified as a gift, and we committed it in the conference grant proposal, then it should be accounted for as cost sharing.

Yes, although overruns were not contemplated during proposal preparation, and were therefore not identified as cost sharing, they need to be ACCOUNTED FOR as cost sharing in order to assure that those costs are included in the Modified Total Direct Cost (MTDC) base.

An overrun means that Stanford spent more to complete the objectives of a sponsored award than it originally anticipated, and has thus "overrun" the budget. The definition of cost sharing, according to our policy is "that portion of the total project costs of a sponsored agreement borne by the University, rather than the sponsor." These amounts must be accounted for in the same manner as committed cost sharing. The fact that cost overruns are unallowable costs increases our obligation to properly account for them. See further guidance on the definition of an overdraft in question 37.

Yes, since the overrun was incurred after September 1994, it is necessary to set up a cost sharing activity/account to which to transfer the overrun.

No. When an overdraft occurs which must be cleared to a cost sharing activity/account, the Cost Sharing Authorization Form is not required. An activity/account can be opened based on an Email request from the department. When departments are clearing overdrafts to cost sharing accounts, it is not necessary to open more than one account. Multiple overdrafts can be cleared to a single cost sharing account if desired.

No. If you anticipate an overdraft, you can legitimately transfer the expense onto another research-related gift activity/account or sponsored activity/account which ALSO benefited from the cost. If there is no such activity, then the costs related solely to that sponsored project and, when transferred, must be moved to a cost sharing activity/account.

Please see the Sponsored Account Cost Transfer Decision Trees.

No. If the total overdraft is less than $500, transfer the lump sum (net of indirect costs) using a new ijournal and Expenditure Type 56135 (which allows the Cost and Management Analysis group to segregate these costs for purposes of indirect cost calculation). Use the Transferring Small Dollar Overdraft tool [downloadable Excel spreadsheet] to help you.

Activity/account function should follow project function (meaning function 1 for sponsored instruction, and function 2 for organized research). If an overdraft occurs in a sponsored instruction account, a function 1 activity/account should be opened in fund class 127.

If you did not incur any of the costs to be cost-shared in those earlier years, you will want to incur as much of the committed cost sharing as possible in year 5. Stanford may also want to contact the sponsor's administrative officer to see if they will agree to modify the cost sharing requirement. Contact the appropriate individual in the Office of Sponsored Research (OSR) to discuss whether this would be appropriate.

If you did incur the cost sharing expense, but accounted for it incorrectly (not in cost sharing activities/accounts), prepare a spreadsheet documenting the nature, date and amount of the costs and the PTA to which they had been charged. Provide this spreadsheet to OSR, who will use it to report cost sharing to the sponsor. Also prepare a journal charging the correct cost sharing account so that the accounting record will reflect the correct treatment of these costs.

The Veterinary Service Center (VSC) has its own indirect cost rate and expenditure types. Information about the rates, expenditure types and various examples on transferring VSC expenses on sponsored project and cost sharing activities are found at http://ora.stanford.edu/supporting_files/VSC%20Cost.pdf (pdf file).

Please use the resources listed at the above site if you have further questions.

Yes. Each account must be funded independently. These instructions may be included on the Cost Sharing PTA Attribute Setup Request [ downloadable file ], on which you can request an account to be funded at inception.

Because the funding sources for cost sharing on such an award are generally provided by different areas of the University, it is probably best to request multiple cost sharing activities/accounts. The activities/accounts may then be monitored by the individual units involved, and the funding is accomplished as for any individual cost sharing activity/account.

However, if the award is being administered through one activity/account, it may be easiest to use only one cost sharing activity/account. This activity/account can be funded from multiple sources which can be specified on the Cost Sharing PTA Attribute Setup Request [ downloadable file ].

Some costs are not captured in cost sharing activities/accounts because they do not affect our organized research base, but they DO benefit the sponsor and may be offered to meet required cost sharing in most cases. These include:

• the difference between full tuition and that charged to a sponsored project
• the value of any waived indirect costs or fringe benefits
• the value of the indirect costs associated with any direct costs being cost shared.

Federal awards: NO, funds from a federal award may NOT be utilized as the source of cost sharing except as authorized by statute. In this rare case, the cost sharing arrangement must be authorized by BOTH sponsors.

Non-federal awards: Per OMB Circular A-110, funds from non-federal awards may be utilized as the source of cost sharing ONLY if authorized by the non-federal sponsor.

The policy on cost sharing is effective for proposals submitted and awards received after September 1, 1994.

Yes, a commitment to cost share made to a non-federal sponsor must follow the cost sharing policy. A cost sharing account/activity must be opened to record the activity because the organized research base includes both federal and non-federal research costs.