The University of Kansas Center for Research, Inc. (KUCR) has
compiled the following policy and procedures related to cost
transfers in accordance with the cost allowability and allocability
requirements of OMB
Circular A-21, Cost Principles for Educational Institutions.
A cost transfer is defined as an expense that is transferred
between sponsored projects and other accounts after the expense
is posted in the financial accounting system. These guidelines
also apply to reclassification of sponsored project expenditures.
Examples of allowable cost transfers include:
- Transfer of allowable pre-award costs;
- Reassignment of personnel in accordance with their appropriate
effort on a project;
- Correction of account number transposition errors; and
- Allocation of expenses incurred to departmental funds that
are easily identified with project activities through maintenance
of logs or other departmental records.
Responsibilities
The Principal Investigator (PI), or departmental staff acting
on behalf of the PI, is responsible for providing the written
cost transfer request and appropriate supporting justification
to Post Award Services for review
and approval.
Post Award Services is responsible
for oversight of cost procedures and for determining allowable
and unallowable costs charged to externally-sponsored projects
based on federal and sponsor guidelines.
Before a non-personnel cost transfer to a sponsored agreement
is approved, a Post Award Services staff member reviews the cost transfer request
to determine whether the cost is allowable under OMB Circular
A-21 and sponsor guidelines. All expenditures charged to externally-sponsored
projects must meet the following criteria:
- Both the nature and amount of a cost must reflect prudent
action at the time the decision was made to incur the cost;
- A cost must be incurred solely to advance the work under
the sponsored agreement. It must reasonably benefit the sponsored
agreement. It must be necessary to the overall operation of
the institution and can be assignable to a specific sponsored
project;
- Each cost must be given consistent treatment according to
generally accepted accounting principles appropriate to the
project; and
- Each cost must conform to principles outlined in OMB circulars
or specific agency guidelines.
A cost transfer to a sponsored agreement will not be approved
for any of the following reasons:
- To meet deficiencies caused by overruns or other fund considerations;
- To avoid restrictions imposed by law or by the terms of the
sponsored agreement; or
- For other reasons of convenience.
Procedures
The PI, or departmental staff working on behalf of the PI,
must submit a written request to Post Award Services staff. The request must detail the account numbers and
amount to be transferred. Appropriate justification for the transfer
should also be provided.
Transfers of personnel costs are often initiated at the PI's
department or research unit. Post Award Services performs a post-audit review
in these cases.
Cost transfers must be made within 90 days of posting.
Questions? Please contact:
Barbara Armbrister
785-864-7688 | barmbris@ku.edu
Interim Manager | Post Award Services