Cost Transfer Guidelines
- Cost Principles
- After 90 Days
- Corrections that don't require Cost Transfers
- Systemic Problems
- UM Policy 410 - Cost Transfers
These guidelines set forth the definitions and cost principles related to cost transfers and the mechanism for processing cost transfers at the University of Montana. While these guidelines are based upon the federal definitions and principles, in order to maintain consistency in the administration of cost transfers, the requirements will be applied to all sponsored programs regardless of the funding source.
1.02 Cost Principles
Federal, state and private agency policies and audit guidelines have become quite stringent as they relate to cost transfers to, from, or between sponsored projects. A key federal regulation from the Office of Management and Budget, Circular A-21, contains the following statement:
"Any costs allocable to a particular sponsored agreement ... 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."
The University has a stewardship responsibility for all sponsored funds and these cost transfer guidelines will be applied consistently to all sponsored agreements regardless of the funding source in order to comply with UM's Cost Transfer Policy.
- A cost transfer is the moving of an expenditure from one index number to another, regardless of sources of funds.
- Transfer of costs between account codes within the same sponsored project index is not considered a cost transfer and does not require completion of a cost transfer form. See Corrections Where Cost Transfers Are Not Required.
II. Cost Transfer Guidelines
2.01 Standard Process
If a principal investigator determines that a cost transfer is necessary and appropriate. a Cost Transfer Request (separate forms exist for Payroll and Non-Payroll) must be completed and forwarded to the appropriate departmentally-assigned post-award specialist within 90 days of the original charge or, if at the end of a project, 15 days prior to the final grant expenditure report due date, whichever comes first.
- The applicable sections of the cost transfer request form must be filled in accurately and completely.The cost transfer request will not be approved if it contatins insufficient data or inadequate explanation.
The reasons for transferring the expenditure must be sufficiently stated to establish that the transfer is within the approved guidelines of the budget to be charged and is in direct support of the project objectives. It is important to stress the benefit to the program receiving the cost. The explanation must clearly indicate why the cost wasn't charged correctly initially, and why the cost is a proper and allowable charge to the transferee project. Where appropriate, the explanation should also indicate what steps have been taken to prevent similar errors from occurring in the future. An explanation that merely states that the transfer was made “to correct error" or "to transfer to correct project" is not sufficient and will not be accepted.
Cost transfers will not be approved if the justification given is to remove cost overruns on the transferor project, as this clearly violates the federal regulation cited above.
Requests should be signed by the principal investigator for each sponsored program budget involved in the transaction. If this responsibility is delegated, written authorization must be maintained at the department level. Designees should sign their own names followed by "for Name of PI." If the transfer involves a non-sponsored program account, any authorized departmental signature is acceptable for that account. In cases where the transfer is in excess of $300, the completed cost transfer request must be reviewed, approved, and signed by the department chair/unit head. If the department chair/unit head is the PI or otherwise signs for either the transferor or transferee account, then the dean/supervisor must approve on the department chair line.
2.02 Cost Transfers After 90 Days
Cost transfers after the standard 90 days may be considered only when unique, unavoidable circumstances exist. The unusual circumstance and corrective action taken must be explained on the Cost Transfer Request.
- Transfers to correct a central office (Business Services, ORSP, HRS) error do not require completion of a cost transfer form, and may be initiated by ORSP without approval of the principal investigator.
- Transfer of costs between account codes or within the same sponsored project do not require completion of a cost transfer form. These transfers can be requested by an e-mail to the appropriate sponsored programs specialist, explaining why the transfer to another account code is appropriate. As with all cost transfers, this request must be made within 90 days of incurring the cost or prior to the submission of the final grant expenditure report, whichever comes first.
III. Correcting Systemic Problems
3.01 Systemic Problems
Frequent errors in the recording of costs may indicate the need for improvements in the principal investigator's or the department's grant management system. Therefore, where frequent errors occur, the principal investigator and/or department will be required to evaluate the need for improvements and to make improvements as deemed necessary by ORSP.