Policy Title: Sponsored Reallocation of Charges & Cost Transfer Policy
Policy Statement: It is the policy of Dartmouth College that costs should be charged to the appropriate sponsored project award when first incurred. However, there are circumstances where it may be necessary to transfer expenditures to a sponsored project award subsequent to the initial recording of the charge. It is the policy of Dartmouth College that charges to sponsored project awards be reviewed on a regular and timely basis to assure appropriateness of charges and to prepare corrections on a timely basis.
Reason for Policy: To comply with allowability and allocability requirements of the Uniform Guidance and to promulgate best practices for all sponsored project awards (federal and non-federal), it is necessary to explain and justify the transfer of charges to federal awards from other federal or non-federal accounts. Timeliness and completeness of transfer explanations are important factors in supporting allowability and allocability in accordance with the principles set forth in the Circular. The transfer of charges involving sponsored project awards is closely examined by auditors. Frequent, tardy or unexplained (or inadequately explained) transfers can raise serious questions about the propriety of the transfers and our accounting system and internal controls.
Affected by this Policy: Any Dartmouth College Department who manages Federal and Non-Federal Sponsored Project Awards.
Who Should Be Aware of this Policy: Office of Sponsored Projects Staff, Department Grant Manager's, Principal Investigator's and faculty who work on their sponsored project awards and Divisional/Central Financial Administrators.
Contacts: Please direct general questions about this policy to your unit's administration. If you have questions about policy issues, please contact the Director of the Office of Sponsored Projects. If you have questions about process issues, please contact your OSP Sponsored Research Manager.
OSP electronically reviews and approves Wage Transfers, Cost Transfers and Simple Re-Class SPUD Journals using OnBase.
See OnBase instructions on attached powerpoint slides
Simple Reclassification: Are instances when SPUD Journals and Wage Transfers can be submitted in OnBase without needing PI approval. Please refer to the below Word document for a list of Simple Reclassification scenario's:
Preparing Simple Reclassification's: If non-payroll transactions are being moved, the submitter (Department Grant Manager or Finance Center) completes a Corrections, Journals and Cost Transfers eForm in OnBase which includes attaching a completed SPUD Journal (Excel Form) to the eForm. The eForm is then submitted for approvals and processing. If payroll is being moved, the submitter completes a Wage Transfer e-Form in OnBase. Please follow the OnBase instruction powerpoint slides referenced above for submitting these forms in OnBase. Please note that Simple Re-Class Wage Transfers need to include supporting documentation for the transactions being moved.
Simple Reclassification Approvals:
Processing Simple Reclassification's:
Cost Transfers: Cost Transfers move a previously recorded non-payroll transaction which typically involves a PTA Account. When moving non-payroll transactions, the submitter (Department Grant Manager or Finance Center) needs to complete a Corrections, Journals and Cost Transfer eForm in OnBase which includes attaching a completed Cost Transfer (Excel Form). Cost Transfers do not include Simple Reclassification's. All Cost Transfers require adequate justifications which include answering the following questions on the forms:
If the original transaction was incurred more than 90 days preceding the transfer request, the justification must also address:
Wage Transfers: Wage Transfers move a previously recorded payroll transaction which typically involves a PTA account. When moving a payroll transaction, the submitter (Department Grant Manager or Finance Center) needs to complete a Wage Transfer eForm in OnBase. All Wage Transfers require adequate justifications which include the same questions referenced above for Cost Transfers.
Cost Transfer and Wage Transfer Documentation: Cost Transfer and Wage Transfer Forms require adequate documentation (examples include IRA OGA/GL Transaction Detail - Expenditures Reports, Labor Change Reports, Wage Transfer Reports, Invoices, etc.) to support the transactions being moved. These always need to be included as attachments when electronically submitting these forms in OnBase for approvals and processing.
Timely Submissions of Cost Transfers and Wage Transfers: Each Cost Transfer and Wage Transfer should be completed within 90 days of the date of the incurrence of the original transaction. Cost Transfers and Wage Transfers over 90 days will only be approved under extenuating circumstances. Examples of acceptable extenuating circumstances for Cost Transfers and Wage Transfers over 90 calendar days (note that all of these exceptions still require submission of the Cost Transfer and Wage Transfer Form) are as follows:
Please Note: Acceptable extenuating circumstances do not include Absences of the PI or Administrator, Lack of Staff, Inexperienced Staff, or Lateness of Reconciliations.
Preparing and submitting Cost Transfers and Wage Transfers in OnBase: Please follow the OnBase instruction powerpoint slides referenced above for submitting these forms in OnBase.
Cost Transfer and Wage Transfer Approvals:
Related Documents & Tools:
The NIH Grants Policy Statement (REV. 10/1/13) link: http://grants.nih.gov/grants/policy/nihgps_2013/
NIH Grants Policy Statement:
"Cost Transfers to NIH grants by grantees...should be accomplished within 90 days...The transfers must be supported by documentation that fully explains how the error occurred and a certification of the correctness of the new charge by a responsible organizational official of the grantee...An explanation merely stating that the transfer was made "to correct error" to "transfer to correct project" is not sufficient. Transfers of costs from one project to another or from one competitive segment to the next solely to cover cost overruns are not allowable. Grantees must maintain documentation of cost transfers, pursuant to 45 CFR 74.53 or 92.42 (record retention requirements) and must make it available for audit or other review...Frequent errors in recording costs may indicate the need for accounting system improvements and/or enhanced internal controls.
revised February 5, 2016
Last Updated: 2/5/16