Effective December 26th, 2014, OMB Circulars A-21, A-110 and A-133 will be replaced by regulations under the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (also known as the Uniform Guidance). Please refer to the University’s Uniform Guidance website http://spa.columbia.edu/uniform-guidance for further details that may supersede information outlined in this policy. Revised policies will be posted once they are available.
Effective Date: December 1, 2006
Latest Revision: July 9, 2012
All of the resources necessary to carry out a sponsored project funded by a governmental agency, private foundation, or industrial or other sponsor ("Sponsored Project") should be budgeted on and ultimately charged to that project. There are occasions, however, when some of the costs of carrying out a Sponsored Project are to be funded from other sources, whether required by the sponsor as a condition of the award (Mandatory Cost Sharing), not required by the sponsor but nevertheless promised by the Principal Investigator to the sponsor (Voluntary Committed Cost Sharing), or not required by the sponsor and not promised by the Principal Investigator, but nevertheless charged to a funding source other than the Sponsored Project (Voluntary Uncommitted Cost Sharing).
The funding source of Mandatory Cost Sharing and Voluntary Committed Cost Sharing must be identified and approved by the person with authority over those funds at the time the commitment is made to the sponsor. For Mandatory Cost Sharing, a separate non-sponsored project must be created, and costs associated with Mandatory Cost Sharing must be applied there; they cannot be co-mingled with other expenses and/or funding sources. Further, those costs must be readily identifiable in the University's financial records to auditors and others in order to document that those cost sharing commitments have been met and are properly accounted for. Voluntary Uncommitted Cost Sharing does not have to be identified, nor does it have to be accounted for.