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KUMC Cost Transfers On Federally-Funded Grants

Policy
Purpose: 

To set forth the circumstances for transferring charges to or from a sponsored award. 

Applies to: 

The University of Kansas Medical Center (KUMC), the KU Medical Center Research Institute, Inc. (KUMCRI), and each of their affiliated entities engaged in the conduct or administration of research supported by KUMC and KUMCRI.

Campus: 
Medical Center, Kansas City
Wichita
Salina
Policy Statement: 

The responsibility for compliance with KUMC and Federal regulations and guidelines and for maintaining supporting documentation for transfers/adjustments is in the originating department/unit.  Deans, Directors and Chairs, and those to whom authority to approve adjustments is delegated, are responsible and accountable for compliance with University and Federal regulations.

Upon being incurred, costs on a sponsored project must be allocated to the appropriate project. In the event a cost is applied to an incorrect project, federal guidelines must be followed in order to correct the error.

Cost Transfers exist to correct errors on federal projects regarding allowability, or to correct clerical errors. Per the Federal Uniform Guidance, allowability factors include reasonableness of the charge, allocability of the charge, and consistency. These factors need to be adhered to when submitting a request for a cost transfer. An excessive number of cost transfers is a “red flag” for auditors; be aware of how costs are being applied to a project.

PROCEDURE

  • Prior approval is required from the Director of Sponsored Programs before the transfer of costs can occur. This approval must be in written form to provide a complete audit trail.
  • Cost transfers must be supported by documentation and justification provided regarding the purpose of the transfer. The explanation must be specific and fully descriptive of the reason for the transfer.
  • Cost transfers must be completed within 90 days of the original charge, or within 90 days of the discovery of errors.
  • Transferring costs from one federally-funded project to another to correct cost overruns is not allowable.
  • The cost must be allowable on the grant to which it is being moved, must be covered by the available balance on the award, and must benefit that award.
  • When clearing overspent amounts on grant awards, the expenses can only be moved to a departmental or R&D account.
  • Occasionally it is necessary to move expenses to the correct budget period of the same award. This is only allowable when the expense was actually incurred within the current period but was posted to a previous budget period. If expenses were incurred prior to the start of the new project period, they must be transferred to a departmental or R&D account.
  • Contact your KUMCRI Post-Award Administrator with questions: http://www2.kumc.edu/researchinstitute/spa/SPA_Forms/accountant_list.xls
Exclusions or Special Circumstances: 

For transfers involving non-federally funded grants, refer to specific sponsor guidelines.

Contact: 

Executive Director, Research Institute: 913-588-5436 

Approved by: 
Vice Chancellor for Research
Approved on: 
Wednesday, April 30, 2008
Effective on: 
Tuesday, May 6, 2008
Review Cycle: 
Annual (As Needed)
Definitions: 

Cost Transfer: An after-the-fact reallocation of the cost, either salary or non-salary, to a sponsored project within a 90-calendar day period from the accounting date of a transaction.

Office of Management and Budget (OMB) A-21: Federal circular establishing principles for determining costs applicable to grants, contracts, and other agreements with educational institutions.

Office of Management and Budget (OMB) A-110: Uniform administrative requirements for grants and agreements with institutions of higher education, hospitals, and non-profit organizations.

Uniform Guidance: The Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Chapter I, Chapter II, Part 200, addressing the administrative requirements for grants and agreements with institutions of higher education, hospitals, and non-profit organizations.

Keywords: 
Allowability reallocation grant
Review, Approval & Change History: 

05/06/2016: Removed Date Last Reviewed
04/18/2016: Changed cost transfers from Research Institute to Vice Chancellor for Research
04/18/2016: Uploaded into Policy Library
11/15/2015: Updated contact

Research and Sponsored Projects Category: 
Research and Sponsored Projects

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