Cost Transfers on Sponsored Projects Accounts

Chapter 7055

Revised November 15, 2024

.040 Procedures for Non- Payroll Transfers

.041 Procedures for Payroll Transfers

.042 Procedures for Changes or Additions to Cost Sharing Salaries

.050 Examples of Acceptable Cost Transfer Explanations

.051 Examples of Unacceptable or Incomplete Explanations

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 shared 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 and deficient internal controls, particularly when projects with cost overruns or unexpended balances are involved.

.020 Federal Guidelines

Uniform Guidance 2 CFR 200 Subpart E Cost Principles:

Section 200.402-405 establishes basic cost considerations for allowability, allocability, and reasonableness.
Section 200.405 indicates any cost allocable to a particular sponsored agreement under the principles provided in this part may not be charged to other sponsored agreements to overcome fund deficiencies, to avoid restrictions imposed by Federal statutes, regulations, or terms and conditions of the Federal awards, or for other reasons not otherwise allowed by applicable cost principles. However, this prohibition would not preclude the non-Federal entity from shifting costs that are allowable under two or more Federal awards in accordance with existing Federal statutes, regulations, or the terms and conditions of the Federal awards. This part would also apply to the transfer of costs from non-federal to federally funded projects.

For example, an excerpt from the 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).”

.030 Policy

Principal Investigators and/or their delegate should regularly review the financial status of sponsored project accounts and prepare and submit transfers needed 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. However, it should also be noted that federally funded sponsored projects will normally require project closeout within 90-120 days of the project termination date. Unallowable expenditures identified during any agency audit occurring after the closeout of the sponsored project will still require transfer of expenditures to a departmental account.

.040 Procedures for Non-Payroll Transfers

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 and require additional explanation.
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 Office of Sponsored Programs, Sponsored Programs Accounting team, pursuant to 2 CFR 200 and specific sponsoring agency requirements. Normally, late transfers must move the costs to a non-sponsored account only.

.041 Procedures for Payroll transfers

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 Effort Report 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, to the extent that the reason for such transfer is not due to such costs being an unallowable cost.
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 OSP Sponsored Programs Accounting team for completion by the department. Again, excessive payroll transfers are viewed by the sponsoring agencies and auditors as an indication of poor management of funds and deficient internal controls, particularly when projects with cost overruns or unexpended balances are involved. Payroll transfers normally trigger auditors to also review effort commitments to ensure the institution has met their committed effort obligations.

.042 Procedures for Changes or Additions to Cost Sharing Salaries

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).

.050 Examples of Acceptable Cost Transfer Explanations

“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.”

.051 Examples of Incomplete or Unacceptable Cost Transfer Explanations

“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.”

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