|History:||Issued||-- July 31, 2015|
|Last Reviewed -- July 24, 2019|
|Related Policies:||Compensation from Sponsored Awards and Effort Certification Policy; Post-Award Principal Investigator Handbook; Reporting Financial Irregularities Policy; Sponsored Award Costing Policy;|
|Additional References:||Cost Transfer Request Form; Sponsored Accounting Office|
|Responsible Official:||Director, Sponsored Accounting tel. (202) 319-6402|
I. Policy Statement
Cost transfers are subject to scrutiny by external award sponsors. The Principal Investigator (PI) for each Sponsored Award is responsible for carefully budgeting expenses for his/her award(s) so as to avoid cost transfers. In the event a cost transfer is necessary, it must be instituted in accordance with the limitations and requirements set forth in this policy.
A. Cost Transfer means the after-the-fact movement of costs between one Sponsored Award and another, or to a non-sponsored departmental organization code.B. Sponsored Award means a grant, contract or other method of funding provided to the University by an external entity (such as the federal government or a private foundation or company) and for which there are actual or implied conditions or expectations that the University must meet. Such conditions and expectations often include, but are not limited to:
- sponsor control of the scope of the project;
- technical, financial, or progress reporting;
- a cost sharing component;
- recoveries for facilities and administrative (i.e. indirect) costs; and/or
- re-granting or subcontracting of some of the funds to other entities.
Sponsored Awards often involve activities such as research, teaching/training, or the provision of services by University personnel to other entities.
III. Cost Transfer Limitations and Requirements
Federal rules stipulate that costs must be charged to the award to which they are related. Each PI should give careful consideration at the time of hiring setup to ensure that the costs for all research staff will be charged according to the anticipated effort on that particular project. A cost transfer request for movement of salary or other expenses can be made if the costs have been charged to the wrong award or, in the case of salary costs, if the amount of effort on an award has changed from what was originally anticipated and set up in the payroll system. Costs cannot be moved, under any circumstances, based solely upon which award has budgeted funds available.
B. Initiating a Cost Transfer
It is the responsibility of the PI, working with his/her School, to ensure that the award financial activity is monitored at all times during an active project. Any cost transfers should be requested immediately when the need for transfer is noticed and generally not more than 90 calendar days after the original posting date. To request a cost transfer, a Cost Transfer Request Form must be provided to the Sponsored Accounting Office, including a specific justification and supporting documentation for the transfer. The justification should specify why the cost was originally charged to the first award and why the cost directly benefits the new award. Justifications must be more specific than "moving costs to proper project" or "correction of an error". Transfer requests submitted beyond 90 calendar days after the original posting date are subject to the requirements and limitations in section C. below. All cost transfer requests require the approval of the PI, the Director of Sponsored Accounting, and for situations where the PI's own salary is being moved, the PI's Department Chair or Dean.
C. Initiating a Cost Transfer Beyond 90 Days
The University is obligated to move an unrelated cost out of an award no matter how much time has elapsed. After 90 calendar days have elapsed from the original posting date, the PI must submit the Cost Transfer Request Form with an alternative funding source and a thorough explanation along with the supporting documentation as to why the transfer was not requested within the 90 day period. The cost transfer will only be made to another sponsored award if it meets one of the following extenuating circumstances and receives approval from both the appropriate Dean and the Controller:
- Another University department did not respond timely to a request that would have moved the charges sooner;
- The award or agreement was not received until after the project start date and the expense being transferred is within 90 days of the date of the formal execution of the award;
- Sponsor requirements dictate the need for the cost transfer
If a cost does not meet one of the extenuating circumstances mentioned above, the cost may be transferred to a non-sponsored organizational code (aka "org" or "DEPTID") within the PI's academic area.
Transferring a cost to another sponsored award is not justifiable in situations where funding was not yet received for the anticipated award project but expenses were incurred. An expense should never be recorded initially in an award for which it is not directly associated. The expenses can only be funded from a non-sponsored departmental funding source.
Under no circumstances will a transfer be made to a closed award.
A PI who repeatedly requests cost transfers after 90 calendar days from the original transaction will be reported to the appropriate Dean and the Provost by the Sponsored Accounting Office.