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The University is responsible for financial accounting for all costs attributable to sponsor-funded projects, including cost sharing. Any quantifiable cost (mandatory or voluntary) offered in the proposal becomes a legally binding and accountable commitment of the University upon acceptance of an award.
PIs, department and school officials, and OSP are all responsible for ensuring that committed cost sharing expenses are allowable under OMB Circulars A21 and A110 and comply with the terms and conditions of sponsored awards as defined in the University Cost Sharing Policy.
If the proposal involves either university cost sharing or sponsored cost sharing, the department should fill out a Cost Sharing Form and check the “cost sharing” box on the Dean’s Approval Form for the University Area or on the Proposal Routing Form for the School of Public Health. Note that the Cost Sharing Form is not required at proposal stage for HMS proposals.
OSP, FAS RAS, SPA, and OFS are responsible for reviewing and approving proposed cost sharing and for ensuring that proposed cost sharing commitments are in compliance with the University Cost Sharing Policy.
School or department officials are responsible for preparing the University Cost Sharing Form and sending it to the submitting office upon receipt of the award notification. The submitting office will review and approve the University Cost Sharing Form completed by the school or department before setting up award accounts in GMAS.
For University cost sharing (when non-sponsored funds are used for cost sharing), the cost sharing account string, also called the “companion account,” should be set up as soon as the award is activated. The cost sharing companion account uses a non-sponsored fund number in combination with the activity and sub-activity value from the sponsored project on which the cost sharing was pledged.
For Sponsored cost sharing (when another grant is used for cost sharing), the cost sharing account retains its own activity value in GMAS because the current sponsored business rules do not allow sharing of activity values across funds. These types of cost sharing commitments must be tracked manually by the school or department managing the award.
School and department officials are responsible for regular monitoring of cost sharing commitments throughout the grant award period and for ensuring that all cost sharing transactions are allowable and are coded correctly in the General Ledger. At the end of the award period, OSP will confirm that the award-related cost sharing obligation has been fulfilled according to the terms and conditions of the award.
If the sponsor requires cost sharing reporting (either via a separate cost sharing report or by inclusion of cost sharing data in the financial report), OSP will contact the department to obtain the following information:
• GL Detail Listing Report from the department for cost sharing transactions using sponsored and/or non-sponsored funds for the reporting period.
• For cost sharing indirect costs that are not recorded in the General Ledger, OSP will prepare a “Cost Sharing Indirect Cost Calculation Summary Sheet” manually and forward it to the school or department for review and signoff.
If the sponsor does not require the reporting of cost sharing, OSP will review the cost sharing status during the final review of the award prior to the award close out. OSP will:
• Obtain a GL Detail Listing Report from the department for cost sharing expenses including sponsored and/or non-sponsored funds for the award period.
• Initiate a discussion with school or department officials if the cost sharing commitment did not meet the sponsor’s requirement or if cost sharing expenses were not in compliance with the University Cost Sharing Policy. In the event that cost sharing requirements were not met, if the sponsor does not agree to reduce or remove the requirements, the school and/or the department will be responsible for any financial loss due to the funding reduction by the sponsor.
Cost-shared expenses must be verifiable from the institution’s records, as required by OMB Circular A-110 Section C23 a (1), regardless of the reporting requirement of the sponsor. The school or department officials who are responsible for managing the award should retain cost sharing-related documentation and make it available for audit or other review.
For indirect cost sharing that is not recorded in the GL, the school or the department must certify the “Cost Sharing Indirect Cost Calculation Summary Sheet” prepared manually by OSP and return the form to OSP to be uploaded into GMAS. The certified summary sheet serves as the “verifiable” cost sharing information in Harvard’s official records.