General Policy Statement
As a recipient of federal funds, Syracuse University (the “University”) is required to maintain a financial management system that provides adequate safeguards to ensure that assets are used solely for authorized purposes. The University has established the following Policy and procedures for the processing of cost transfers to comply with the requirements of Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”), and federal regulations, policies and procedures.
Reason for Policy/Purpose
In accordance with OMB Uniform Guidance and federal regulations, policies and procedures, it is necessary to explain and justify transfers of costs for federally-funded sponsored awards, where the original charge was previously recorded elsewhere in the University’s general ledger. Timeliness and completeness of the explanation of the transfer are important factors in supporting allowability and allocability in accordance with federal requirements. This Policy provides guidance on how to identify and properly document transfers of costs for federally-funded sponsored awards.
Cost transfers are permitted for the retroactive reallocation of payroll or non-payroll costs, to a sponsored project or between sponsored projects, when all of the following requirements are met:
- the costs are allowable, allocable, reasonable, consistently treated, and comply with the award’s terms and conditions;
- the transfer is made in a timely manner;
- the transfer is supported by source documentation and adequately justified; and
- the transfer is authorized by the Principal Investigator or the Project Director or his/her designee and appropriate institutional officials.
The following cost transfers are not permitted:
- Payroll transfers to federal awards after the applicable certification has been completed;
- Cost transfers to meet deficiencies caused by cost overruns or other fund considerations;
- Cost transfers to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience; and
- Cost transfers that do not reasonably benefit project objectives.
Unless special circumstances exist, as determined by the Office of Sponsored Accounting, cost transfers to sponsored awards that cross fiscal years are not allowed after the University’s fiscal year end, even if otherwise allowable according to this policy.
Payroll Cost Transfers
Unless the terms and conditions of a sponsored award dictate otherwise, payroll cost transfers will be considered timely if made during the certification period in which the original transaction is posted in the general ledger, or within the period allowed for effort certification following the end of that period. Payroll transfers to federal awards after the certification period has closed are not allowed. Payroll transfers from federal awards to institutional funds are allowed as needed and as determined by the Office of Sponsored Accounting.
Non-Payroll Cost Transfers
Unless the terms and conditions of a sponsored award dictate otherwise, non-payroll cost transfers ordinarily will be considered timely if made within the two months following the journal date that the original transaction is posted in the general ledger.
Along with copies of source documentation (i.e., general ledger reports, invoices, etc.), the following elements comprise adequate documentation for a cost transfer that may be subsequently approved:
- Explanation of the specific nature of the accounting error;
- Description of why the cost was not properly assigned initially;
- Explanation of steps to be taken to avoid accounting errors of a similar nature in the future;
- Description of how the cost benefits the project to which it is being transferred; and
- Certification of transfer by responsible individual.
Monitoring and Enforcement
The Office of Sponsored Accounting will regularly monitor the cost transfers to ensure consistent adherence to this Policy. If it is determined that the cost transfer does not adhere to the above stated policy, the cost transfer will not be processed. The cost will be bore by the School or College Department from which it originated. Additional training will be offered.
Appendices (as applicable)
Cost transfer procedures are set forth by the Office of Sponsored Accounting at http://comptroller.syr.edu/resources/sponsored-accounting/sponsored-accounting-procedures/
Allocable: the expense can be associated to an award with a high degree of accuracy.
Allowable: costs are allowed under both the provisions of federal guidance and the terms of a specific award.
Cost transfer: is a journal entry that transfers an expense onto a federally-funded sponsored award that was previously recorded elsewhere in the general ledger and requires institutional approval before it can be posted.
- Other Related Policies and Documents