|Policy Approval Authority
|Division of Research and Innovation Partnerships
|Responsible University Office
|Sponsored Programs Administration
|Assistant Vice President for Research and Sponsored Programs
|Dara Little, email@example.com
|Effective Adoption Date
|Last Review Date
Finance / Risk Management
Sponsored Funding/Grants and Contracts
Federal regulations (2 CFR §200.405) require NIU to explain cost transfers to sponsored awards to ensure that the transfer is not occurring for the following reasons.
A cost transfer is an after-the-fact reallocation of costs to a sponsored award. Costs for a specific sponsored project should be charged to the appropriate sponsored project when the expense is incurred. Doing so is important for proper cost allocation and enables accurate accounting of expenses necessary to support sponsor payment and indirect cost recovery.
Auditors and sponsors routinely monitor cost transfers to assess the internal controls NIU has in place to ensure charges to a sponsored award are allowable, reasonable, and provide a direct benefit to the project. It is recognized that transfers may be necessary to correct bookkeeping or clerical errors or to allocate closely related work, but transfers need to be done in a timely manner. An acceptable timeframe is within 90 days of the original transaction date though NIU’s year-end financial reporting requirements may limit this timeframe.
To avoid compliance findings that can affect NIU’s eligibility for funding, NIU should avoid cost transfers with the following characteristics:
Has primary responsibility for ensuring compliance with federal regulations as well as monitoring of expenditures, timely correction of errors and proper allocation of expenses.
Assist PIs in the timely review and reconciliation of expenditures, prepare cost transfers and maintain adequate documentation of questionable costs, and ensure that all personnel engaged in the financial administration of sponsored awards are familiar with this policy; ensures that the costs transferred are allocable, allowable, and reasonable; coordinate with SPA to initiate and document cost transfers, prepare, and submit timely approved Cost Transfer Request Form when required.
Maintains the policy and accompanying procedures for costs transfers and addresses questions regarding the policy. Grants and Contracts Associates approve cost transfers less than 90 days. The Associate Director Post Award approves cost transfers greater than 90 days. The Assistant Vice President for Research and Sponsored Programs approves cost transfers greater than 120 days.