This GIM sets out the policy and outlines procedures for the administration of expenditure transfers for sponsored program funds consistent with federal regulations and sponsor policy statements.
Federal, state, and private agency policies and audit guidelines are quite stringent as they relate to cost transfers between sponsored programs. 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 per cost principles set out in Title 2 in the Code of Federal Regulations (2 CFR), subtitle A, chapter II, part 220. ( formerly Office of Management and Budget, Circular A-21.)
The Department of Health and Human Services (DHHS) has issued a definite policy statement containing specific guidelines on cost transfers. Since DHHS has the Federal audit responsibility at most universities, including the University of Washington (University), these guidelines are extended in audit practice to the University's sponsored programs from other Federal agencies as well. State and public auditors use similar audit guidelines when reviewing nonfederal grants and contracts. Since the University has a stewardship responsibility for all funds made available for research and training, these cost transfer guidelines are applied consistently to all sponsored agreements.
Frequent or inadequately explained cost transfers raise serious questions about the propriety of the transfers themselves as well as the overall reliability of the department's cost distribution system, and may result in a comprehensive audit by internal and/or external auditors. Departments must have procedures in place which ensure accurate accounting for costs and timely correction of errors.
UW Principal Investigators and Departments, Subrecipients, Office of Sponsored Programs, Payables Administration, and Grant and Contract Accounting.
Cost transfers into a sponsored programs budget must be made within 90 days of when the error is discovered. If, however, the transfer is requested more than 120 days after the transaction date, an explanation for why the transfer is late must be included. The 120 days is from when the transaction posted to the originating budget to when the transfer is submitted.
When it is necessary to correct these errors, departments must provide convincing evidence that the goods and/or services are properly allocable and that the budget receiving the transferred cost actually received a benefit from the goods and/or services involved.
A single cost is not to be transferred more than once.
Grant and Contract Accounting
Faculty Effort Certification (FEC): Periodic review and certification that the distribution of faculty salaries represents a reasonable reflection of effort.
Grant and Contract Certification Report (GCCR):Documentation to certify the reasonableness of salary and wages charged to sponsored projects, with the exception of faculty salaries, which are certified via the Faculty Effort Certification process.
|Cost Principles for Educational Institutions||OMB Circular A-21|
|NIH Grants Policy||http://grants.nih.gov/grants/policy/nihgps_2011/index.htm|
|Grant and Contract Certification Report procedures||http://f2.washington.edu/fm/gca/spending-invoicing/payroll-topics/grant-contract-certification-reports-formerly-payroll-certificatio|
|Grant and Contract Accounting Deficit Transfer Process||http://f2.washington.edu/fm/gca/close-budget/closing-types|
|Non-grant and contract salary transfers||MyFinancial Desktop customer Supportemail@example.com||206-543-3877|
|Salary transfers involving grant and contract budgets||Grant and Contract Accounting (GCA)||firstname.lastname@example.org||206-616-9995|
Research Accounting and Analysis
SUPERSEDES: GIM 15 (Rev/January 2009)