How should COs certify costs claimed by non-Federal entities in cost-share arrangements?

• A. Verify allowability, reasonableness, and allocability; ensure documentation and agreement terms are met.
• B. Accept costs if within budget.
• C. Certification is not required.
• D. Only verify reasonableness.

Answer: (A)

When cost-share is involved, the key responsibility is to verify that the costs claimed by the non-Federal entity meet the standards of allowability, reasonableness, and allocability, and that the documentation and terms of the agreement are fully satisfied. In practice, this means checking that the contributed funds or in-kind charges are permitted under the applicable cost principles, that they reflect what was necessary to accomplish the project, and that they can be properly tied to the project activities in a consistent way. It also requires confirming there is solid support for the claimed amounts—records, valuations for in-kind contributions, and any matching or timing requirements laid out in the award documents. This ensures the government’s share is accurately represented and that the cost-sharing arrangement is auditable and enforceable under the grant or cooperative agreement.

Simply staying within a budget does not guarantee this level of scrutiny, because budget lines alone don’t prove allowability or proper documentation. Certification is required precisely to validate these aspects, and focusing only on reasonableness would overlook the necessity of ensuring allowability, allocability, and proper support.