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POLICY NO : 6106
EFFECTIVE DATE: 07/01/09
Basis of the Policy
Acceptance of federal awards obligates the University of Nebraska Medical Center (UNMC) to comply with the federal government’s rules, regulations and guidelines applicable to sponsored programs. Federal cost principles per the OMB circular A-21 “Cost Principles for Educational Institutions” require costs to be properly allocated to the program that received the benefits of the costs incurred.
Purpose of the Policy
This policy establishes requirements for processing transfers of direct costs to sponsored accounts. Federal regulations, generally accepted accounting principles, and good management practices require that all costs incurred be appropriate to and for the direct benefit of the project charged, and that accounting records be maintained on a timely and accurate basis. The federal government considers an excess number of cost transfers to be a sign of ineffective financial controls.
Although it is preferable to charge costs to the correct account when they are incurred, cost transfers may occasionally be necessary. These transfers must be properly documented and processed within a reasonable time (normally within 90 days of the original entry).
- The costs being transferred to a federally sponsored award must be allowable to that award per UNMC Policy No. 6100, Direct Costs.
- For this policy and the cost transfer procedure “federal award” includes both federal awards to UNMC and federal pass-throughs where UNMC received federal funding indirectly through another institution.
- The transfer must be supported by the Cost Transfer Explanation and Justification form to clearly explain why the transfer is being made. The explanation must be sufficient for a reviewer to understand the transfer and conclude that it is appropriate. A statement that merely says "to correct error" or "to transfer to correct account" is not sufficient.
- Whenever possible the department creating the transfer must also maintain documentation for the original charge that is being moved, such as a copy of the original vendor invoice, SAP document, etc.
- The transfer should be submitted as soon as possible after the error is discovered, and must normally be processed within 90 days of the original entry. Transfers or charges more than one year old will not be allowed.
- In addition to the Cost Transfer Explanation and Justification questions, Sponsored Programs Accounting may require additional documentation for any cost transfer where the aggregate cost being moved to a federal award is greater than $500. If the documentation is not sufficient to support the transfer Sponsored Programs Accounting will reverse the entry.
- Under no circumstances may expenditures be placed on a sponsored account for reasons of convenience or funding availability with the intention that they will be moved at a later date. Costs may not be transferred to a project that is near completion in order to use up funds.
- If a cost transfer affects two departments, both departments must approve the cost transfer.
- Costs transfers that have been justified, documented and accepted as appropriate will not be allowed to be moved again.
- Retroactive payroll transfers can affect a previously certified effort report. Therefore, UNMC requires recertification of effort under specific circumstances as explained in UNMC Policy No. 6105, Effort Certification and the related procedure.
Any questions about this policy should be referred to Financial Compliance and Cost Analysis.
Cost Transfer Procedure / Office of Management and Budget Circular A-21 / Cost Transfer Explanation and Justification
This policy updates UNMC Policy #6101 issued on 10/27/02. This page updated on Monday, July 13, 2009, by dkp.
Last Review by Policy Owner: Tuesday, June 16, 2009.