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A cost transfer moves costs from one account to another to correct an error, reimburse service center or departmental costs, or for other reasons associated with a department’s regular financial operations; it may not be used as a means for managing project funds (e.g., spending down an award that is expiring).
A transferred cost must comply with all UNH policies and sponsor terms and conditions, including rules for allowability, reasonableness, allocability, and consistency.
Cost transfers, when necessary, must be timely; late cost transfers (more than 90 days after the end of the month in which the transaction occurred) must meet additional documentation criteria and be approved by Sponsored Programs Administration (SPA).
Why it’s important
Expenses being transferred to or from a sponsored project prompt scrutiny of the reasons for the transfer and the justification for moving those charges. Any time you initiate a transfer, you invite the assumption that controls are lacking; hence, the initial transaction was not handled properly.
How to comply
Initiate cost transfers involving sponsored projects only under these circumstances:
Principal Investigator, their designee, or a responsible official within the BSC who may reasonably be expected to have knowledge of the sponsored project and its terms and conditions:
- To correct an error (e.g., number transposition);
- When the transfer is within the same agreement and otherwise is an allowable cost;
- To allocate costs benefiting more than one sponsored project;
- To transfer retroactive expenses (including pre-award costs) when there has been a delay in finalizing contract negotiations. Transfers under these circumstances are still subject to approval when not completed within 90 days;
- To correct erroneous charges as documented and authorized by the Principal Investigator, their designee, or a responsible official within the BSC who may reasonably be expected to have knowledge of the sponsored project and its terms and conditions;
- When there is supporting documentation and evidence of approvals as needed that provides sufficient information to allow for a clear audit trail; and
- When there is an appropriate explanation, if not processed within 90 days after the end of the month in which the transaction occurred.
Cost Transfer Procedures
- Necessary cost transfers may be requested by communication between you and your BSC. The BSC will require documentation of your approval for the cost transfer.
- You and your BSC representative must document the answers to the following questions:
- Why is the original charge now deemed to be incorrect and/or inappropriate?
- What makes the expense an appropriate and allowable charge for the grant to which it will be transferred?
The BSC will maintain documentation regarding the cost transfer which may be required in the event of an audit or review.
3. If the proposed cost transfer is a labor redistribution that will affect a closed Effort Certification period, you must provide compelling justification and documentation which explains how/why the original effort report was certified even though it did not accurately reflect the effort expended.
The Senior Vice Provost for Research must approve changes to completed effort certifications.
4. For cost transfers initiated 90 days or more after the end of the month of the original transaction posting date, you and your BSC representative will need to submit documentation to SPA using the Cost Transfer Justification Request form available on the Research Office website. SPA will review the documentation and rationales provided, then approve or disapprove the transaction with a written response to the requesting party.
Per the UNH Policy on Cost Transfers on Externally Sponsored Programs, 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.
SPA Staff are available to assist in the interpretation and application of University policy.
PI Essentials: Guidance Document #5