Chapter 10 - Research
Publication Date: April 17, 2012
Responsible Executive: VP for Research
10.08 Cost Transfers on Sponsored Programs
I. POLICY STATEMENT
The University of Texas at San Antonio (UTSA) is committed to ensuring that all costs are timely charged to the appropriate Sponsored Program when such costs are incurred. When circumstances necessitate the transfer of any Sponsored Program cost after such cost is initially recorded in UTSA’s financial accounting system, the Cost Transfer must be supported by an acceptable justification and written documentation. It must also be accomplished in a timely manner that complies with applicable federal, state, The University of Texas System (UT System), and UTSA policies and procedures.
Cost Transfers are allowed to ensure that costs associated with a Sponsored Program are appropriately charged. However, Cost Transfers are closely monitored by the Office of Research Administration through its Office of Post Award Administration (OPAA) because, as noted in UT System Policy 163, Guidance on Effort Reporting and Certification Policies (UTS 163), the following may indicate poor Awards management: 1) a high volume of Cost Transfers, 2) a high volume of Cost Transfers that occur several months after the initial accounting transaction, 3) Cost Transfers that occur after an Effort Statement has been certified, and/or 4) a pattern of Cost Transfers from a Sponsored Program.
UTSA must meet the requirements of the federal Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions, and UTS 163. For this reason, Cost Transfers on all extramurally funded grants, contracts, and other agreements associated with a Sponsored Program must be identified, properly justified and processed, and completed in a timely manner with sufficient documentation to support the transfer.
This policy provides the mandatory criteria and requirements that must be met regarding Cost Transfers on Sponsored Programs.
This policy applies to all UTSA employees involved in or responsible for the fiscal administration of a Sponsored Program.
IV. WEBSITE ADDRESS FOR THIS POLICY
V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS
UTSA or UT System Policies or the Board of Regents' Rules & Regulations
- UT System policy 163, Guidance on Effort Reporting and Certification Policies
- UTSA Handbook of Operating Procedures (HOP) policy 10.05, Managing and Certifying Effort on Sponsored Programs
- UTSA HOP policy 10.06, Institutional Base Salary on Sponsored Programs
- UTSA HOP policy 10.07, Cost Sharing on Sponsored Programs
Other Policies & Standards
- OMB Circular A-21, Cost Principles for Educational Institutions (relocated to 2 CFR Part 220),
If you have any questions about HOP policy 10.08, Cost Transfers on Sponsored Programs, please contact the following office:
Office of Post Award Administration (OPAA)
Allowable: Cost incurred on a Sponsored Program that is reasonable, is Allocable, is consistent, and conforms to any limitations or exclusions of the Sponsor.
Allocable: Cost incurred that advances the work of a Sponsored Program and is chargeable to a particular cost objective.
Award: Depending on its context, either: (a) the terms and conditions associated with a Sponsor’s decision to select a UTSA Sponsored Program proposal or application for funding, or (b) the Notice of Award or other documentation reflecting such a decision by the Sponsor.
Cost: Equivalent to an expense that has been recorded to the University’s financial system.
Cost Transfer: Transfer of a cost or expenditure, salary or non-salary, to or from (and in rare circumstances, within) a Sponsored Program
Effort: The amount of time spent on any activity for which an Individual is compensated by UTSA. Effort is expressed as a percentage of the Individual’s Total Institutional Activities, which Total Institutional Activities typically include work on Sponsored Programs, teaching and instruction, service, or other duties for UTSA.
Effort Certification or Effort Reporting: Formal verification through UTSA’s electronic Effort Certification system that Committed Effort (whether paid from the Sponsored Program account or Cost Shared) has been performed.
Individual: An Individual is any UTSA employee who has Committed Effort (whether paid by the Sponsor or Cost Shared) on a Sponsored Program. Where appropriate in this policy, the following subcategories will be utilized: :
- A Primary Individualhas some responsibility for the overall conduct and management of the research or activity as described in the proposal/application or as identified in the Notice of Award of a Sponsored Program. A Primary Individual is typically identified in the Sponsored Program Award as the principal investigator, project director, co-investigator, or co-project director and typically, but not always, carries an academic (i.e., faculty) appointment.
- The PI/PD: In the Effort-Related Policies, when a duty or responsibility falls squarely on only one Primary Individual, that individual may be referred to as The PI/PD (Principal Investigator or Project Director).
- A Collaborating Individual is an employee with an academic appointment who expends Committed Effort on a Sponsored Program but does not serve as a Primary Individual on such Sponsored Program.
- A Supporting Individual is an employee other than a Primary Individual who does not have a faculty appointment and has expended Committed Effort on a Sponsored Program.
Sponsors: Entities, including government, industry, private entities or UTSA, that provide Awards to fund Sponsored Programs at UTSA.
Sponsored Programs: Activities conducted in research, instruction, training, or public service as a result of a formal written agreement (such as a grant, contract, or cooperative agreement), which agreement is typically obtained as a result of a formal application and approval process. These activities can be funded either externally by government, industry, or private sponsors; or, internally by UTSA. Sponsored Programs are separately budgeted and accounted for, meaning there is a defined scope of work, a budget that identifies the costs to be incurred in the performance of the work, and the accumulation of costs actually incurred in support of the project. Sponsored Programs usually involve a specific commitment of time for each Individual involved in achieving the aims of the project. Sponsored Programs may be thought of as transactions in which there are specified statements of work with a related, reciprocal transfer of something of value.
- The PI/PD
- Reviews expenditures on a monthly basis to determine if all charges to the Sponsored Program are Allowable and Allocable;
- Reviews Effort on a periodic basis to determine if all salary charges have been applied correctly;
- Ensures that any Cost Transfers are necessary, Allowable, Allocable and comply with applicable federal, state, UT System and UTSA rules, regulations, policies and procedures;
- Approves and initiates the request for a Cost Transfer;
- Submits the requested Cost Transfer including supportive documentation and a justification to the OPAA; and
- After OPAA has reviewed a Cost Transfer and it has been posted by Grants and Contracts Financial Services, reviews the approved Cost Transfer to ensure that it correctly reflects the approved cost adjustments or changes.
- Office of Post Award Administration (OPAA)
- Reviews and approves all Cost Transfer transactions ensuring the requested cost adjustments or changes comply with appropriate policies, rules and regulations;
- Reviews and approves Effort Cost Transfers prior to seeking the approval of the Office of the Senior Associate Vice President for Research Administration; and
- Submits Cost Transfer to Grants and Contracts Financial Services for posting.
- Grants and Contracts Financial Services
- Reviews and posts all Cost Transfers to the official accounting records found in UTSA’s financial accounting system.
- Office of the Senior Associate Vice President for Research Administration
- Approves Cost Transfers associated with Effort.
- Approves Cost Transfers associated with Effort.
- Except in rare circumstances, requests for a Cost Transfer will be made within ninety (90) days after the cost was initially posted into official accounting records found in UTSA’s financial accounting system. Any request for a Cost Transfer made after the ninety (90) day period will only be allowed if approved by the PI/PD and OPAA and only if the transfer benefits the Sponsored Program.
All requests for Cost Transfer must have a written justification and adequate supporting documentation showing why the transfer is necessary, Allowable, and complies with applicable rules, regulations, policies and procedures. To indicate “to correct an error” or “to transfer to correct project” are insufficient reasons.
- All Cost Transfers associated with Effort must be approved by OPAA and the senior associate vice president for research administration. A Cost Transfer for salaries that is related to changes in Effort is not permitted after Effort Certification statements are completed and signed by the Individual or after the Sponsored Program closeout date unless it benefits the Sponsor (i.e., a salary transaction is removed from a Sponsored Program account).
- As reflected above and in the Responsibilities Section, this policy has segregated the duties relating to Cost Transfers to ensure no one person or academic department has the sole authority to initiate, approve, and post a Cost Transfer into the official accounting records.
X. SPECIAL INSTRUCTIONS FOR IMPLEMENTATION
XI. FORMS AND TOOLS/ONLINE PROCESSES