ROWAN UNIVERSITY POLICY

Title: Cost Transfer Policy                                                                                          

Subject: Office of Sponsored Programs

Subject: Cost Transfer Policy                                                                                          

Policy No: OSP: 2015: XX

Applies: University-wide                                                   

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Responsible Officer:  Vice President for Research                                     

Adopted: XX03/XX13/2015

Last Revision:

Last Reviewed: 03/13/2015

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C. Rowan University Policies

1. Contracting and Procurement
2. Travel Related
3. Fixed Asset 

V. POLICY

A. Principal Investigators are in the best position to determine what research costs are necessary for performance of a sponsored agreement. Consequently, they shall assume primary responsibility for justifying cost transfers to or between their sponsored agreements when such transfers are necessary. The principal investigators must review the fiscal status of their sponsored agreements at least monthly and promptly correct expense transactions that are incorrectly recorded. Ultimately, a principal investigator is responsible for resolving any disallowed cost transfer, which may result in the reimbursement of disallowed costs.

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1. An explanation merely stating that the transfer was made to “correct error” or “to transfer to correct project” is not sufficient.
2. A cost transfers from one budget period to the next solely to cover cost overruns is not allowable.
3. Examples of acceptable explanations include the following:
   1. Payroll forms were not processed timely because the financial plan for the award was being revised.
   2. Individual transferred from one project to another, but the appropriate paperwork could not be processed before the payroll deadlines.
   3. Individual was transferred from one project to another for only one pay period.
   4. Data entry error occurred when entering the fund number on the original transaction.
   5. The individual that prepared the original transaction misunderstood the principal investigator’s instructions.
   6. The principal investigator mistakenly gave the wrong information to the individual that processed the original transaction.

E. Cost transfers will not be charged back to a previous fiscal year in Banner once the University has provided its initial Financial Statement drafts to the auditors during the beginning of the annual year-end audit test work period. Only entries approved by the Accounting Services department and reviewed by the auditors can be processed once a draft is submitted.

F. Grantees and administrative offices of the incorrectly charged account must maintain copies of the approved cost transfers as well as the supporting documentation that must be made available for audit or other review. Frequent errors in recording costs may indicate the need for additional training and/or enhanced communication among the principal investigator, Accounting Services department, and Payroll Services department to ensure compliance with all appropriate university payroll, reimbursement, accounting, and personnel policies and practices.

VI. ATTACHMENTS

A. Attachment 1, Sponsored Project Cost Transfers

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1. Late issuance of a Notice of Grant Award or Contract and full execution of a subcontract subsequent to the start of a budget year or other period of performance.
2. Failure of another department to take action on a properly submitting Cost Transfer Form.
3. Cost transfer is initiated within the allowable timeframe but returned for additional signatures, justification, and/or supporting documentation.
4. Transfer expenditures on a Federal/State project to a non-grant/unrestricted fund which was incurred prior to the expiration date in order to eliminate a deficit or after the expiration date in order for the grant to be closed and inactivated.
5. An extenuating or unusual circumstance as deemed appropriate and authorized by the Responsible Organizational Official of the grantee.

H. Cost transfers that would result in the revision of a Final Financial Status Report or final invoice will be reviewed on a case-by-case basis.