UG – What is it?
Q: I have heard about a new regulation called the “Uniform Guidance”. How will this new regulation affect my sponsored activity
A: Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance” or “UG”) is found in Title 2, Part 200, of the Code of Federal Regulations (CFR). This regulation, which took effect December 26, 2014, impacts multiple areas pertaining to Federally funded projects. We will be sending out, via email, questions posed by faculty and staff regarding the UG, and in response, the most current information available about these changes. We’ll start today with a question on cost sharing.
Q: Is it true that the Federal government no longer requires cost share?
A: It is not true that the Federal Government no longer requires cost share. It is likely that certain Federal programs will continue to require a certain percentage of cost share from the applicant in order to support the goals of the program. This type of cost share is known as mandatory cost share.
What has changed is the Federal Government’s outlook on voluntary committed cost share. Here’s an excerpt from the UG:
Under Federal research proposals, voluntary committed cost sharing is not expected. It cannot be used as a factor during the merit review of applications or proposals, but may be considered if it is both in accordance with Federal awarding agency regulations and specified in a notice of funding opportunity. Criteria for considering voluntary committed cost sharing and any other program policy factors that may be used to determine who may receive a Federal award must be explicitly described in the notice of funding opportunity.
Your takeaway from this should be that unless the notice of funding opportunity specifically identifies voluntary committed cost share as a merit criterion for scoring and selection of proposals, you are not expected to include cost share in your proposal submission. Many Federal agencies go a step further and specifically direct applicants that they should not include cost share in a proposal.