Well, I don't really know enough yet. But one question is how did the sponsor find out about this other voluntary cost-share? If you told them, then it's voluntary committed, emphasis on the committed, cost-share. It becomes trackable at that point. There may be loopholes, depending on who the sponsor is, but... probably if you committed it, it's committed.

On Fri, May 8, 2020 at 1:49 PM Samantha Levin <xxxxxx@facs.org> wrote:

Hi everyone,

Has any had an experience where cost share was not required, but then a year or two in, when another non-federal funding source was contributing funds to the program, the federal funder tried to require that as reportable cost share? There are leveraged funds on the award, but currently no required cost share.

Is there a regulation that allows funders to add a cost share requirement in post-award?

Thank you,

Sam

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American College of Surgeons

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