R. Cost Transfers on Externally Sponsored Programs
1. Introduction. Acceptance of federal awards requires compliance with allowability and allocability standards as established in the federal cost principles. Federal cost principles require consistency in costs applied to federal and nonfederal awards; therefore, this policy applies to all sponsored programs.
UNH policy requires charging costs to the appropriate sponsored program when first incurred. There are, however, circumstances in which it is appropriate to transfer costs to or from a sponsored program after the costs are initially recorded. Additionally, appropriate routine cost redistributions occur during the normal monthly business cycle.
2. Definition. A cost transfer is the after-the-fact reallocation of actual costs to or from a federal or non-federal sponsored program (grant, including cost share and program income, or contract) after the initial expense has been posted to any USNH fund.
3. Policy. Expenses incurred on behalf of sponsored programs should be charged to the appropriate sponsored funds promptly, accurately, and in accordance with applicable rules and regulations. In certain circumstances, however, there may be a need to transfer expenses to a sponsored program subsequent to the initial recording of the charge. Cost transfers must adhere to UNH policy and the sponsor's standards of allowable costs. They must be timely, explained in detail, and clearly documented, including notation of appropriate authorizations.
Cost transfers may be initiated by Business Service Center (BSC) staff to correct an obvious error or at the direction of the Principal Investigator (PI) or Project Director (PD) or a responsible official within the unit who may reasonably be expected to have knowledge of the sponsored program and its terms and conditions. Business Service Centers are responsible for maintaining evidence of proper authorization for all charges to sponsored funds.
All cost transfers initiated less than 90 days after the end of the monthly accounting period of the original transaction posting date are subject to after-the fact review by Sponsored Programs Administration (SPA).
Pre-approvals from SPA, based on adequate supporting documentation and justification, are required before entering transactions into the USNH financial accounting system for any of the following:
3.1 Transfers (payroll and non-payroll) initiated 90 days or more after the end of the monthly accounting period of the original transaction posting date.
3.2 Transfers of expense previously transferred to a sponsored program.
Additional approvals are required from Office of the Senior Vice Provost for Research for any:
3.3 Proposed labor redistribution that affects a certified effort report (http://www.usnh.edu/olpml/UNH/VIII.Res/S.htm).
4. Unallowable Cost Transfers. The following are unallowable cost transfers:
4.1 Transfers of expenses near the end of the award period to consume remaining funds.
4.2 Cost transfers solely for the purpose of shifting expenses between grants to remove a bottom line deficit, to remedy over expenditure, or to compensate for lack of appropriate project monitoring.
5. Documentation. All cost transfers, other than allowable, routine cost redistributions during the monthly accounting cycle, must include related supporting documentation and specific details regarding the basis/cause of the transfer, and be responsive to the following questions:
a) Why the original charge is now deemed to be incorrect and/or inappropriate?
b) What makes the expense an appropriate and allowable charge for the grant to which the expense will be transferred?
Documentation must also include the date and evidence of authorizing approvals. When approval is required from SPA (see 3.1, 3.2, 3.3), identification of the authorizing SPA representative and the date approved is also required.
BSC's maintain the original documentation of all cost transfers.
References: OMB Circular A-21:C.4 Allocable costs OMB Circular A-110:Subpart C, __.21 Standards for financial management systems __.27 Allowable costs __.52 Financial reporting Administrative Responsibility: UNH Senior Vice Provost for Research Effective date: 7/1/95; revised 7/16/97, 12/14/98, 4/26/07, 2/21/12
The College of Life Sciences and Agriculture (COLSA) and UNH Cooperative Extension (CE) manage externally sponsored programs, including federal appropriations that are outside the purview of SPA. COLSA and CE oversee cost transfers affecting these sponsored programs and have authority to approve transfers beyond the 90 day limit and transfers removing a bottom line deficit for AES and CE programs.