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Financial
Please note - process overviews have been developed as guidance only and can be changed at any time. Please contact your Sponsored Projects Administration team with any questions.
Definition: Cost sharing is the portion of a project or program cost not borne by the sponsor. It is the University's share in the cost of conducting the project/program. Cost sharing occurs either when a sponsor requires, or the University commits, funds beyond those awarded by the sponsoring agency to support a particular grant or contract.
The allowability of specific costs as cost sharing is usually determined by the sponsor's specific award terms and conditions. Cost shared expenses must meet the same standards that apply to costs that are directly charged to a project.
- Allowable and allocable.
- Verifiable from University records.
- Necessary and reasonable for proper and efficient accomplishment of project objectives.
- Identified in the approved award budget.
Cost sharing accounts are managed in the same manner as project accounts. Certain types of cost sharing are set up in a IXXS Fund and tracked through the Grants and Contracts Office. The documentation for cost sharing is the responsibility of the PI/Department and must conform to the requirements of 2 CFR 200.
REPORTING OF COST SHARING TO SPONSORS
The Grants and Contracts Office has the responsibility to provide and certify information to sponsoring agencies which demonstrates that the University has fulfilled its cost sharing requirements under a specific award. It is expected that PI’s and departments will respond promptly to the Grants and Contracts Office request to gather information that may be needed in addition to information specified on the “Certification of Cost Sharing Form”.
Multi-Year Projects: It is recommended that departments work with the Grants and Contracts Office to verify cost sharing information on an annual basis, even if this information is only required at the expiration of the project.
Process Owner: Office of the Vice President for Research (OVPR)
Process Overview:
Institutional cost sharing approvals on extramural grant applications must be obtained from the PI’s Chair and Dean as well as the Office of the Provost and the Vice President for Research. It is expected that these approvals be obtained as early in the development of a proposal as possible; estimated cost share commitments are acceptable. Note that cost share approval is not guaranteed. If the cost-share is not approved, the proposal cannot be submitted unless cost sharing is removed or the PI’s department or school agrees to absorb the cost. To obtain approval, faculty should prepare a request in writing that includes the information detailed below. Once a PI has their Chair and Dean’s approval, the request should be submitted to the Provost’s office and then to the Vice President for Research.
The following are required in a cost-share request:
- The completed cost-share request form.
- A cover memo from the Dean of the relevant school indicating both support for the proposal and the best-guess odds of the proposal’s success.
- A one-page executive summary including:
- Working title of proposal;
- Sponsor name;
- CFDA number or Funding Opportunity number;
- Total dollars requested of the sponsor, with estimated direct costs/indirect costs as well as the indirect cost rate for the proposal;
- A 1-paragraph description of the project; and
- A justification of why the cost share will benefit the Institution, explaining why it is required, and detailing how the amount requested was determined.
4. Once the proposal is approved and the Notice of Award is received an account award account will be created for this purpose with the code IXXS.
Associated Forms/Resource Links:
Definition: Cost transfers are defined as after-the-fact re-allocations of costs, either labor or non-labor, to and from a sponsored project. Federal and non-federal sponsors have policies and rules defining the circumstances in which cost transfers are allowable and the documentation that is required in support of cost transfers.
Process Owner: Grants and Contracts Accounting Services (GCAS)
Process Overview:
Initiation of Cost Transfer Requests
It is recognized that cost transfers are sometimes necessary in order to correct errors made in an initial charge to a sponsored agreement. In order to ensure the integrity of cost charges and financial reporting, however, such errors must be identified and corrected in a timely manner. Errors in charging costs to a sponsored agreement should be identified and correction should be initiated within sixty (60) days after posting of the original transaction in order to allow for timely completion of the review process (normally ninety (90) days after posting). Further, the principle of consistency in cost accounting periods requires that, where practicable, errors be corrected in the same fiscal year in which they were made. A cost must be reasonable, allowable and allocable to a sponsored agreement to be transferred to that agreement. Transfers based solely on funding considerations (e.g., solely because there are funds remaining in the destination account at the close of the agreement), or for other reasons of convenience unrelated to the actual allocability of the cost, are prohibited. In addition the following will apply:
- A cost transfer to a sponsored agreement will not normally be made later than ninety (90) days after the original posting of the cost. Accordingly, cost transfer requests should be submitted as soon as possible after initial posting.
- Any cost transfer to a sponsored agreement that is not completed in the fiscal year in which the expenditure was first posted will receive added scrutiny.
- Where a request is made to transfer costs from one sponsored agreement to another because of an asserted error in the initial charge, and the transfer request is disapproved, the cost will generally be removed from the sponsored agreement initially charged and the department in which that sponsored agreement was housed will be charged for the cost. Only if the reviewing office determines, based on persuasive evidence, that the initial charge was not in fact erroneous may the charge remain on the sponsored agreement to which it was originally charged. All cost transfers that result in transfers from sponsored agreements to ‘C’ and ‘R’ funds and that may result in refunds to the sponsors will be processed regardless of the time limits.
Documentation Requirements
Documentation must accompany or be inserted on the Labor redistribution for payroll transfers and the Departmental Correction Form (DCF) for non-payroll transfers. Information regarding how the error occurred and approval/certification of the correctness of the charge by an organizational official must accompany all cost transfers. Any cost transfer request, whenever submitted, must contain the following documents and information:
- Copy of original invoice or source document
- Report from where expense originally was booked (i.e., Budget Performance Report and/or Oracle report GM139)
- Detailed written justification for cost transfers: o Since the federal regulations assume that cost transfers are exceptions, it is important to explain in writing the reason why the cost was not charged to the correct project originally and how it benefits the project to be charged. It is recognized that it will not always be possible to reconstruct with certainty why or how an error occurred, but in many cases it is apparent that an incorrect posting has been made because of a transposition of numbers in data entry or because of a miscommunication. In other cases, the fact that a charge is clearly allocable to a certain sponsored agreement will itself be evidence that the charge was mistakenly allocated originally to another sponsored agreement. The justification provided in support of the cost transfer should be in writing and will serve as an audit source document. o If an inadequate justification is provided, the cost transfer request will be disapproved. For example, simply stating, “To correct an error” would not be an adequate justification.
With this in mind, OVPR has created a “Cost Transfer Justification Form” that is required with the submission of all DCF forms. This justification form will serve as an audit source document. If an inadequate justification is provided, the cost transfer request will be disapproved. For example, simply stating, “To correct an error” would not be an adequate justification.
4. Once all documentation has been compiled in support of the DCF, including the “Cost Transfer Justification Form”, it should be submitted to OVPR for approval. All DCFs should be submitted to OVPR using the “AP Online Submission Form”.
Responsibility for Compliance
The primary responsibility for recording charges to the correct sponsored agreement is at the department level when the costs are incurred and recorded. Suitable fiscal practices at the department level should permit identification of any clerical or bookkeeping errors in a timely manner usually no later than sixty (60) days after initial posting, allowing cost transfers to be processed within ninety (90) days or sooner after initial posting. Responsibility for following these guidelines lies with Principal Investigators, department chairs and departmental/school fiscal personnel. GCAS has the ultimate approval policy. In certain circumstances, the Comptroller or designee will review cost transfers in certain circumstances as stated above to ensure that financial reporting internal controls are met to reduce the occurrence of late or questionable cost transfers in the future.
Associated Forms/Resource Links:
- GCAS' Departmental Corrections form
- GW's Policy on Cost Transfers
- OVPR's Cost Transfer Justification Form
- AP Online Submission Form
Definition: Interest Awards are set up in Oracle to capture the amount of interest earned from funding on Sponsored Project Awards. The awards are made with the terms and conditions set forth by the sponsor requiring the University to invest the funds in an interest bearing account. Stipulations on the use of the interest are found in the terms and conditions of the award document or in the terms and conditions of the sponsor’s institutional guidelines and my include:
- Using the interest earned to further the research proposed during the life of the award
- Using the interest for the research with any remaining balance being returned to the sponsor at the end of the award
- Earning interest on the unspent balance through the life of the award and refunding all interest to the sponsor
- Allowing the University to keep the interest and use it to further enhance the goals of the University
Process Owner: Office of the Vice President for Research (OVPR), Grants and Contracts Accounting Services (GCAS), GWU Comptroller's Office
Process Overview:
- OVPR sets up the Interest Award at the time the main Award is created
- The Comptroller’s Office calculates the interest monthly and sends the amount earned to OVPR (GCO)
- OVPR (GCO) adds the monthly interest to the award
Definition: Program Income is a gross income earned by a recipient that is directly generated by a sponsored activity or earned as a result of the award.
- These funds should be used to further project or program objectives
- At times program income funds are used as a cost share funds when necessary
- Fix priced program income
Income generated through non-federal awards is handled according to specific sponsor rules as referenced in the award document
Process Owner: Office of the Vice President for Research (OVPR)
Process Overview:
- The PI is responsible for notifying OVPR staff if any sources of program income are identified during the award management stage that was not disclosed at the proposal or award set up stage.
- The PI should contact OVPR with any questions about program income.
- OVPR will set up the award for the program income
Associated Forms/Resource Links:
For more information, please contact your SPM Team.