Cost Transfer Request Form Instructions

This guidance applies to requests to transfer costs to or from a sponsored project contract and grant (award). A cost transfer is the reassignment of a previously incurred cost (expense) from one award to another. The Cost Transfer Request Form (xlsx) is to be used when a cost is determined to benefit another project (in whole or in part) in accordance with generally accepted cost principles and Sponsor terms and conditions. Examples when the form is not required include: org-key/object code adjustments within the same award agreement, expenses related to new account establishment, or unallowed or disallowed costs.

Section 1: Identification of Cost (Expense)

Non-personnel costs (e.g. supplies or travel), the following should be provided: Identify the costs to be transferred by providing the org-key/object code charged, description of cost, and provide the correct org-key/object code to be charged.

Personnel costs (e.g. salaries and wages) the following should be provided: Identify the Org Key, Employee Name and Pay Period for the expenses that must be transferred and provide the correct account that is to be charged.

Section 2: Justification for Transfer

Because federal regulations assume that cost transfers are exceptions, it is imperative to appropriately justify in writing (1) the reason why the cost was not charged to the correct project and (2) how it benefits the project to be charged.

The following are general examples of inappropriate or incomplete justification:

  1. To correct an error (which may be an incomplete justification)
  2. Charged a sponsored project for a bulk purchase and are moving costs to the appropriate sponsored projects.
  3. Charged another sponsored project in anticipation of future funding.
  4. To move costs to a sponsored project with available funds or to cover a deficit.

Section 3: Exception Request for Late Cost Transfer Requests (90+ Days)

Per cost accounting Standards and Regulations, it is required that a cost transfers be requested within 90 days of the charge. Only in cases of exceptional circumstances will cost transfers be permitted more than 90 days after the charge. Additional explanation is required to document the reason for the lateness of the request. The department chair, or next higher authority must approve all late cost transfers.

OMB Circular No. A-21 states that, “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.” Other federal regulations require cost transfers to be made in a timely manner. Timely is defined as taking place within 90 days of the incurrence of the cost. Cost transfers requested after 90 days of their incurrence will be reviewed on a case-by-case basis and will require signature approval by the appropriate Chair or Dean.

Section 4: Certification and Approvals

Name and signature of Project Investigator/Director or other Authorized Designee for the account the cost is being transferred to (i.e. the correct project). Additional Approval is required when Section 2 (a) is applicable. The Sponsored Programs Director (or designee) and/or the Dean of Research may approve an exception to the use of the Cost Transfer Form on a case-by-case basis.

Principal Investigator’s Responsibility

Project Investigators/Directors are responsible for monitoring and notifying appropriate personnel should an error be identified. To ensure compliance with applicable policies and procedures, the principal investigator is responsible for ensuring that cost transfers are:

  1. Made within 90 days after the month in which the cost was recorded on the Financial Accounting System Reports or sooner when required by the Sponsor (i.e. project close-out).
  2. Supported by a written explanation that describes in detail why the transfer is necessary.
  3. Additional explanation and approvals are provided when a transfer request is 90 days after the cost after the month in which the cost is recorded.

Authority

To maintain consistency in the management of sponsored projects accounts, this policy applies to all federal and non-federal sponsored project awards (Fund 04) in accordance with the applicable federal, state, and other regulatory guidance.

This guidance has been established to meet federal regulations and compliance standards and internal control expectations set forth in:

Title 2 in the Code of Federal Regulations (2 CFR), Part 220, Cost Principles for Educational Institutions (formerly Office of Management and Budget (OMB) Circular A-21) Appendix A – Principles for Determining Costs Applicable to Grants, Contracts, and Other Agreements with Educational Institutions, C.4.b. Basic Considerations – Allocable Costs.

Title 2 in the Code of Federal Regulations (2 CFR), Part 215, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and other Non-profit Organizations (formerly Office of Management and Budget (OMB) Circular A-110) Subpart C.53.e. – Post Award Requirements, Retention and access requirements for records.

NIH Grants Policy Statement revised 12/03, Part II, Subpart A, Terms and Conditions of NIH Grant Awards – Cost Considerations – Cost Transfers, Overruns, and Accelerated and Delayed Expenditures.