Administrative Policies and Procedures Manual - Policy 2450: Cost Transfers

Date Originally Issued: 06-01-2006
Revised: 12-01-2006, 01-01-2008, 07-01-2015

Authorized by RPM 5.9 ("Sponsored Research")
Process Owners:  University Controller and HSC Senior Executive Officer for Finance and Administration

1. General

Cost transfers are after-the-fact allocations of direct charges (including labor redistributions) to, from, or between federally sponsored projects. Cost transfers are subject to the same direct cost requirements as the original cost as discussed in Section 3.2.1 of UAP 2410 ("Accounting for Federally Defined Allowable and Unallowable Costs").  Also refer to UAP 2485 ("Over-Expenditures, Losses, and Gains on Contracts and Grants").

2. Cost Transfer Requirements

Four (4) requirements must be met before a cost transfer is submitted: the transfer must be allowable, reasonable, allocable, and timely. Supporting documentation must accompany the submission. Federal allowability is defined by the Office of Management and Budget in Section 200.403 of 2 CFR Part 200 ("Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards") and the Federal Acquisition Regulations (FAR), 48 CFR Part 31, Subpart 31.3.  See Section 4.2 of UAP 2410 ("Accounting for Federally Defined Allowable and Unallowable Costs") for a discussion of allowability and reasonableness according to University policy and federal regulations.

2.1. Reasonable Costs

Costs are considered to be reasonable if the goods or services acquired and the dollar amount of the cost:

• reflect a prudent and responsible action,
• are generally recognized as ordinary and necessary,
• are in accordance with all applicable external regulations and terms, and
• are consistent with University policies governing the action.

2.2. Allocability

Allocability is another criterion for allowability. As a general rule, costs are chargeable or assignable to a specific sponsored project in accordance with the relative benefits received or any other equitable relationship. A cost is allocable to a sponsored project, and may be transferred to that agreement, if it:

• is incurred solely to advance the work under the sponsored project, or
• benefits both the sponsored project and other work of the institution, in proportions that can be approximated through reasonable methods, and
• is necessary to the overall operation of the institution, and, in accordance with the Uniform Guidance, is assignable in part to sponsored projects.

2.3. Timeliness

A cost transfer must be made as soon as the need for it is identified. Supporting documentation for any cost transfer submitted later than ninety (90) days after the original date of the transaction must include an explanation for the delay and approval of the applicable dean or director. A more restrictive deadline may apply if required by the sponsoring agency. It should be noted that corrections in the government's favor have no time limit, and the close-out of a sponsored project does not affect the obligation of the University to return funds due as a result of later refunds, corrections, or other transactions.

2.4. Supporting Documentation

Supporting documentation must accompany all cost transfer submissions and include a:

• description of the cost,
• reason for the transfer,
• explanation as to how the receiving sponsored award benefits from the cost,
• justification of allowability of the cost to the receiving sponsored award,
• corrective action to ensure transfers are not required in the future (if applicable), and
• signature of the dean or director and an explanation for delay if the correction exceeds ninety (90) days after the original charge.

3. Compliance Risk

Cost transfers are always an audit target and can be a significant compliance risk. The following types of cost transfers are subject to audit scrutiny because they are an indication of activities deemed unallowable by federal regulations and University policy:

• numerous cost transfers,
• cost transfers with insufficient documentation,
• cost transfers made more than ninety (90) days after original charge,
• cost transfers made more than sixty (60) days after the end date of the sponsored project,
• cost transfer decisions based on available funding (caution: do not move excess funds from one sponsored project to an overspent sponsored project), and
• inappropriate effort certification for redistributed salaries.