Cost Transfers on Sponsored Projects Accounts
Revised April 27, 2009
Table of Contents
.020 Federal Guidelines
For purposes of this policy, a cost transfer is defined as a transfer of expenditure, either payroll or non-payroll, from one account to another after the expenditure was initially recorded in the university accounting system when at least one of the accounts involved is a sponsored project account. In addition, changes or additions to cost sharing salaries are considered to be transfers. (See PPM Chapter 7070 for more information on Cost Sharing.)
The Federal government and other external sponsors expect costs to be charged appropriately at the time incurred and that proper procedures are in place to assure the integrity of any subsequent adjustments to those charges. It is generally recognized that cost transfers may be necessary to correct errors in original charges. However, frequent, late, inadequately explained transfers, or multiple transfers of the same cost are viewed as an indication of poor management of funds, particularly when projects with cost overruns or unexpended balances are involved.
OMB Circular A-21 “Cost Principles for Educational Institutions”:
Sections C.1 through C.4 establish basic cost considerations for allowability, allocability, and reasonableness.
Section C. 4.b-c specifically states: “Any costs allocable to a particular sponsored agreement under the standards provided in this Circular may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience. Any costs allocable to activities sponsored by industry, foreign governments or other sponsors may not be shifted to federally-sponsored agreements.”
NIH Grants Policy Statement states:
“Cost transfers to NIH grants by grantees…. Should be accomplished within 90 days …The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official of the grantee…Transfers of cost from one project to another or from one competitive segment to the next solely to cover cost overruns are not allowable…Frequent errors in recording costs may indicate the need for accounting system improvements, enhanced internal controls, or both. If such errors occur, grantees are encouraged to evaluate the need for improvements and to make whatever improvements are deemed necessary to prevent reoccurrence. NIH also may require a grantee to take corrective action by imposing additional terms and conditions on an award(s).”
Principal Investigators and/or their delegate should regularly review the financial status of sponsored project accounts and prepare and submit transfers to correct errors on a timely basis. Such corrections must be supported with documentation of why the error occurred and how the cost directly benefits the project to which the transfer is being made. Corrections should not require multiple transfers of the same cost. Additionally, sponsored projects accounts should never be used as “holding” accounts for costs benefiting other projects or objectives.
Transfers of costs to a sponsored project account that are not prepared and submitted on a timely basis will be considered “late transfers”. Such transfers will require additional documentation and will be permitted only in limited circumstances with appropriate explanation.
No time limit is imposed on removing expenditures from a sponsored account and transferring them to a non-sponsored account. If unallowable expenditures are discovered on a sponsored project account, they must be removed regardless of the timeframe.
Transfers of costs to a sponsored project must be prepared and submitted within 90 days after the end of the month in which the transaction was originally recorded. A complete explanation of the need for the transfer must be documented on the transfer of payment form. Explanations such as “to correct a clerical error” are not adequate.
Transfers of costs to a sponsored project account that are prepared and submitted after that time period will be considered late transfers.
Late transfers that move costs to a sponsored project account will be allowed only in limited circumstances. A complete justification must be provided on the transfer of payments form and such transfers will only be processed after approval by the Sponsored Projects Accounting Office. Normally, late transfers must move the costs to a non-sponsored account only.
Transfers must be prepared and submitted within 90 days after the effective date of the paycheck and prior to being certified on an Effort Report. Once salaries have been certified on an Effort Report, changes to the assignment of those costs may call into question the validity and integrity of the original certification. Allocation of the payroll costs, including cost sharing, should be carefully considered and adjusted prior to certification. See PPM Chapter 7080 for more information on Effort Reports.
Transfers prepared and submitted after that time period will be considered late transfers and normally must move costs to a non-sponsored account only. Transfers from a sponsored agreement account to a non-sponsored account normally need to be reported as cost sharing for the project they are transferred from.
Transfers that represent changes in the funding of cost sharing previously reported will also be considered a late transfer.
Late payroll transfers will be allowed only in limited circumstances and must be approved by the Payroll Office. The Funding Data Sheet and required additional documentation must be completed and submitted to the Payroll Office for approval before the transfer will be processed. If approved, a revised Effort Report also must be requested from the Sponsored Projects Accounting Office for completion by the department.
These actions are considered to be late 90 days after the original due date for reporting the cost sharing OR if the due date for the related Effort Report has passed. Late cost share changes or additions will be allowed only in limited circumstances. For all such transfers, a Late Cost Sharing Transfer Justification form must be completed and submitted to the Sponsored Projects Accounting Office for approval at the same time that the related cost share spreadsheet is submitted. (See PPM Chapter 7070 for instructions on submitting cost share spreadsheets).
“A clerical error was made when the original payment document was prepared. The account number 123456 was inadvertently entered as 132456”
“This PI has two projects that involve the study of wildcats and their eating habits. The PI inadvertently provided the wrong account number for the original charge. Future charges for this PI will be double-checked for the correct account number.”
“A review of the monthly statements for this account by the PI revealed an error in charging payroll. The personnel specialist had not been notified by the PI that a graduate student had been assigned to this project.”
“Receipt of the official award was delayed by the sponsor. The project started prior to the date an account was established.”
“The sponsor assigned a new award number to the new budget period of the project, therefore a new FIS account was set up. This transfer moves costs to the new FIS number.”
“A change in the personnel specialist position within the department caused a delay in changing payroll funding to accurately reflect employees assigned to this project.”
“To correct a clerical error”
“To move to correct project”
“Costs must be transferred to another sponsored project due to overspending”
“Costs need to be transferred to use up unspent funds before the sponsored project ends”
“The late transfer is needed due to workloads that prevented administrative staff/PI from doing account reviews until now”
“Costs were charged to sponsored project X until sponsored project Y was set up in FIS”
“The PI was unavailable at the time of the original charge so costs were charged to sponsored project X in the meantime”