Overview
Definitions
Form Requirements
Responsibilities
Procedures
Payroll Cost Transfers
Policies and Forms
Overview
The University of Texas at San Antonio (UTSA) recognizes that cost transfers are sometimes necessary to correct bookkeeping or clerical errors; to allocate allowable costs that support more than one project; to transfer allowable pre-award costs; or to reallocate allowable costs originally charged to a central administrative account. Requests for cost transfers must meet The University of Texas at San Antonio “Cost Transfers on Sponsored Projects” policy as provided in the UTSA Handbook of Operating Procedures (HOP 10.08).
In order to meet cost allowability and allocability requirements according to the requirements of Uniform Guidance, 2 CFR Part 200 – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, and Cost Accounting Standards for Education Institutions (48 CFR 9905), justification of transfers on all externally sponsored projects must be identified and corrected in a timely manner with sufficient documentation to support the transfer.
If it is necessary to process a cost transfer that involves a sponsored project, a request for a cost transfer should be initiated promptly, within 90 days of the original transaction date, and contain sufficient documentation and justification to support the cost transfer. Cost transfers requested more than 90 days after the initial cost or after the project end date will only be processed if the transfer benefits the sponsored project. Salary Cost Transfers are not permitted after Effort Certification reports are completed and signed by the Individual or after the Sponsored Program closeout date unless it benefits the sponsor.
Definitions
Cost transfer: An after-the-fact reallocation of costs, salary or non-salary, to or from a sponsored project.
Allowability: cost incurred on a sponsored project that are reasonable, allocable, consistent, and conform to any limitations or exclusions.
Allocable: cost incurred solely to advance the work of a sponsored project.
Form Requirements
All Cost Transfer requests must have adequate documentation as to the reason it is necessary. To indicate “to correct an error” or “to transfer to correct project” are insufficient reasons. As general guidance, acceptable justifications should address the following:
- Why the expense was originally charged to account from which it is now being transferred.
- Why the charge needs to be transferred to the proposed receiving project.
- Why the charge is allowable and allocable based on the terms and the conditions of the receiving award.
For cost transfers requested more than 90 days after the original transaction date, the justification must also include the following items:
- How does this cost transfer benefit the sponsored project?
- Why the cost is being transferred more than 90 days after the original transaction date?
- What corrective action has been taken to eliminate the need for cost transfers of this type in the future?
Roles and Responsibilities
Principal Investigator/Project Director (PI)/(PD)
- Reviews expenditures on a monthly basis to determine if all charges to the Sponsored Program are Allowable and Allocable;
- Reviews Effort on a periodic basis to determine if all salary charges have been applied correctly;
- Ensures that any Cost Transfers are necessary, Allowable, Allocable and comply with applicable federal, state, UT System and UTSA rules, regulations, policies and procedures;
- Approves and initiates the request for a Cost Transfer;
- Submits the requested Cost Transfer including supportive documentation and a justification to the Office of Sponsored Project Administration/Research Service Center (OSPA/RSC); and
- After OSPA/RSC has reviewed a Cost Transfer and it has been posted by Grants and Contracts Financial Services, reviews the approved Cost Transfer to ensure that it correctly reflects the approved cost adjustments or changes.
Office of Sponsored Project Administration (OSPA)/Research Service Center (RSC)
- Reviews and approves all Cost Transfer transactions ensuring the requested cost corrections comply with appropriate policies, rules and regulations;
- Reviews and approves Effort Cost Transfers prior to seeking the approval of the Assistant Vice President for Sponsored Project Administration; and
- Submits Cost Transfer to Grants and Contracts Financial Services for posting.
Grants and Contracts Financial Services
- Reviews and posts all Cost Transfers to the official accounting records found in UTSA’s financial accounting system.
Assistant Vice President for Sponsored Project Administration
- Approves Cost Transfers associated with Effort.
Procedures
Requests for cost transfers involving a sponsored project must be made using the Cost Transfer/Voucher Correction Request Form per the following procedures. Cost transfer procedures are appropriately segregated to ensure no one person or academic department has the sole authority to initiate, approve, and post a Cost Transfer into the official accounting records.
Principle Investigator/Project Director (PI/PD)
- Review Statement of Accounts on a monthly basis to determine if all charges have been applied correctly.
- Review effort on a periodic basis to verify time has been allocated correctly.
- Identify any necessary corrections.
- Ensure any cost corrections are necessary, allowable, allocable and comply with appropriate rules and regulations.
- Review and approve cost transfer forms completed by the department/center/institute support staff.
Preparer of Cost Transfer Form
- Complete required cost transfer form.
- Review form for allowability, completeness and accuracy per form requirements
- Ensure necessary support documentation is provided
- Obtain necessary signatures from the PI/PD, Department Chair or Center/Institute Director
- Forward the form to OSPA/RSC for review.
Office of Sponsored Project Administration (OSPA)/Research Service Center (RSC)
Research Award Administrator (RAA)
- Review and approve all cost transfer forms, ensuring the form is complete and the requested cost corrections comply with appropriate policies, rules and regulations.
- Obtain required signatures from RSC director and Assistant Vice President for Sponsored Project Administration, when applicable
- Forward cost transfer request to GCFS
RSC Director
- Provide a secondary review and approval of all cost transfer forms, ensuring the form is complete and the requested cost corrections comply with appropriate policies, rules and regulations.
Assistant Vice President for Sponsored Project Administration
- Review and approve payroll cost transfers
Grants and Contracts Financial Services (GCFS)
- Enter and post cost transfer accounting transactions into UTSA’s official accounting system.
Payroll Cost Transfers
Cost transfers for payroll can affect the University’s time and effort reporting process. OSPA/RSCs must review all requests for retroactive changes to payroll costs and their impact on effort reporting. Cost transfers for salaries are not permitted after Principal Investigators have completed and certified their effort statements unless it benefits the sponsor.
