Cost Transfers (Salary and Non-Salary)

Learn about cost transfers on sponsored projects at Columbia University.

Details

While faculty and staff must make every effort to allocate sponsored project costs to the appropriate project(s) at the time the costs are incurred, it is recognized that under certain conditions, it may be permissible, or in the case of an error, necessary to transfer costs from one project to another. Cost transfers to sponsored projects are allowable only when:

  • There is a direct benefit to the project activity being charged;
  • The cost being transferred was incurred during an allowable time period;
  • The terms and conditions of the project do not explicitly prohibit the charge; and
  • The cost transfer is accompanied by required documentation.

Further, University policy requires that all cost transfers to sponsored projects be prepared and submitted within 90 days following the end of the month in which the original charge was posted to a University project; thereafter, cost transfers to sponsored projects will not be permitted except in extenuating circumstances. If a request for a cost transfer is not approved, the costs in question must be moved to a non-sponsored project.

Cost transfers that remove expenditures from a sponsored project are not subject to the 90-day time limit, and must be processed at the time when it is determined that an expenditure charged to a sponsored project is not appropriate to that project. For further information, see the University’s Policy on Cost Transfers.

 

Cost Transfers that Are Not Allowable

Certain Cost Transfers are not allowable under any circumstances. In particular, costs allocable to a particular sponsored project may not be transferred to other sponsored projects:

  • To correct deficiencies caused by overruns or other funding considerations;
  • To avoid restrictions imposed by law or by terms of the Sponsored Project; or
  • For other reasons of convenience.

At no time should sponsored projects be used to “park” charges which will subsequently be transferred elsewhere, including competing or non-competing continuations of the same project for which the notice of award or the new project has not been received.

In addition, costs may not be transferred to a sponsored project merely because there are unexpended funds available that would otherwise be returnable to the sponsor.

Cost Transfers that May Be Allowable

Sponsored Projects Finance of the Office of the Controller (SPF) determines whether a cost transfer is allowable. There are three prerequisites for SPF to find a cost transfer to be allowable:

  • The Cost Transfer must reflect a direct benefit to the Sponsored Project being charged;
  • The Cost Transfer must comply with both the University’s policies and the sponsor’s terms and conditions; and
  • The Cost Transfer must be fully documented.
Timing of a Cost Transfer

A cost transfer should be processed as soon as it is determined that an adjustment is necessary. Federal guidelines provide that cost transfers should be accomplished within 90 days; accordingly, cost transfers to sponsored projects requested beyond 90 days following the end of the month in which the original charge was initially recorded are strongly discouraged, and will not be permitted except in extenuating circumstances.

Extenuating circumstances DO NOT include:

  • Absences of PI or responsible administrator
  • Shortage or lack of experience of staff

Cost transfers should be submitted within one month of a project set up/extension.

For further information on allowability and timing, see the University’s Policy on Cost Transfers.

Required Documentation Supporting a Cost Transfer

The form of documentation necessary to support a cost transfer depends on the type of cost being transferred and is described below. In all cases, documentation that merely states that the cost transfer is being made “to correct an error”, “to transfer a cost to the correct Sponsored Project” or similar explanation is not sufficient as an explanation for the request.

Non-salary Costs: Cost transfers to a sponsored project made after the charge is posted must be accompanied by appropriate transfer documentation (“Documentation”).

Documentation for non-salary costs must include:

  • A description of each specific expense being transferred, including why and when the original cost(s) were incurred;
  • An explanation as to why the sponsored project to which the transfer is being made was not originally charged; and
  • An explanation of why it is appropriate to now charge that sponsored project.

Salary costs: Any salary cost transfer on the Sponsored Project must be accompanied by appropriate written documentation that provides justification explaining how the error occurred as well as a certification that the new charge is correct. This includes any cost transfers processed through the Retroactive Salary Distribution function in PAC. The written documentation must be maintained by the department and must be available for audit or review upon request. Additionally, grant specific information must be included in the justification comments in the online transfer request. The documentation is subject to the University Record Retention policy.

Additional Requirements for Cost Transfers Requested after 90 days

Documentation of cost transfers requested more than 90 days after the initial posting of the charge must further include an explanation of why the cost is being transferred at such a late date in order to be considered. As previously noted, such transfers will not generally be permitted.

For further information on documentation requirements, see the University’s Policy on Cost Transfers.

Policy

See the University's Cost Transfers policy.

Forms

Use the Cost Transfer Justification Form (xls) for expenses that have aged more than 90 days from the end of the month in which they were applied to a project.

Training

See the ARC Sponsored Projects Cost Transfer Guide (pdf) for full instructions about each of these processes.

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