To ensure sponsored project related regulatory requirements are met when costs charged to sponsored projects were initially charged to other accounts.
June 2023Responsible Office
When allowable sponsored project costs are initially charged to other accounts they may be considered “Cost Transfers” by regulatory agencies and may be subject to additional regulatory timing and documentation requirements. The additional regulatory timing and documentation requirements may vary by sponsor and any specific sponsor requirements need to be followed.
This includes, but is not limited to the following HHS agencies:
Under this policy, unapproved costs that are charged to awards from these HHS agencies more than 90 days after the occurrence will be considered unallowable.
Regulatory agencies have specified the following transactions in their guidance as “Cost Transfers” requiring compliance with the Uniform Guidance Cost Principles and additional documentation within specified time frames:
The Principal Investigator and their delegates, including Business Administrators, are responsible for ensuring the timeliness, accuracy and allowability of costs charged to sponsored projects and preparing and maintaining the associated supporting documentation.
Authorized Administrators/Delegates are required to complete cost transfer training prior to gaining access to perform cost transfers on sponsored project accounts. Upon completion of the required training, delegates with the authorization and ability to record costs to sponsored projects will use the University’s financial accounting system Sponsored Project Journal Entry Responsibility and the appropriate categories. Journal entries must include a reference to the original transaction entered in the accounting system.
The primary control to ensure proper charging of costs to sponsored projects requires the journals for the costs initially charged to other accounts and or corrections be prepared by authorized administrators or delegates with the authority and ability to ensure the allowability of the costs.
Secondary controls to further ensure the accuracy and timeliness of journal entries charging costs to sponsored projects will be deployed as follows:
Categorized and tracked in “control reports” used by PI delegates to ensure additional documentation requirements have been met
The journal entry categories used in the “control reports” are as follows:
Examples of Category 14 cost transactions include but are not limited to the following:
Over 90 Day Costs
Additional Documentation Requirements:
Measuring, Monitoring, and Audit
ORS will develop, lead, and maintain a Shared Research Governance Process with representatives from the schools/centers to measure and monitor the control process described above and ensure it is operating as intended. This includes but is not limited to:
The “control reports” will be utilized, at least quarterly, by formally assigned school/center representatives to ensure the following:
SPP 2114 Effort Reporting
Business Administrators or Other Delegates
School and Center Audit Representatives
Office of Research Services