Timeliness of Cost Transfers

Timeliness of Identifying and Correcting Costing Errors - It is the responsibility of the Principal Investigator (PI) to ensure that verification of financial transactions on their respective sponsored agreements occur on a timely basis (at least monthly). A cost transfer for any identified errors shall be processed promptly after an error is discovered.

Untimely Cost Transfer Requests (> 90 days) – A cost transfer is considered untimely when a unit's submission date is greater than 90 days from the accounting date of the original posting of the cost. A Unit's submission date is the most recent signature date  from the initiating department on the cost transfer form. Untimely cost transfers will only be approved under extenuating circumstances and a Vice President signature is required for approval. Systemic corrective action will be required to prevent future occurrences of untimely cost transfers. The following HHS and NIH regulations supersede this general procedure statement on approving untimely cost transfer requests on sponsored agreements supported by these agencies.

• The Health and Human Services (HHS) grant policy has the following condition: “Permissible cost transfers should be made promptly after the error occurs but not later than 90 days following occurrence”.  Cost transfer requests > 90 days after the occurrence must be approved in advance by the Grant’s Management officer.

• The National Institutes of Health (NIH) grant policy prohibits transfers of costs from one project to another or from one competitive segment to the next solely to cover cost overruns. 

Determining timeliness - Examples and a calculator

• Payroll Cost Transfer Example - During the effort certification process in August 2012, a PI modifies her effort report to reflect 10% effort on “Grant A“ during the 4/1/12-6/30/12 time period and signs the effort report. The department submits a retroactive salary distribution on August 15, 2012 to reflect this change. Since the oldest expense being transferred occurred when the 4/1/12-4/15/12 payroll was posted on 4/15/12, the cost transfer request is > 90 days and would be considered untimely. The systemic corrective action by the department was a monthly measurement of how many Unit personnel complied with their required quarterly verification of effort and a prompting of the individuals who didn't comply.

• Non-Payroll Cost Transfer Example - Research supplies were purchased  on 7/1/12 to use on Grant B and charged to the department's suspense account. The sponsor allowed pre-award spending so the expenses were allowable. The department was notified by SPA that the award's budgets were available on 9/1/12. A journal was submitted by the department  for approval on 9/15/12. This transfer request would be considered timely.
  

Cost Transfer Calculator -  Click here to calculate the days between the original accounting date and the cost transfer submission date.