The Principal Investigator/Project Director (PI/PD) is responsible for ensuring that all transactions are charged accurately and appropriately to the correct project, based on the benefit to the project and in a manner that is consistent with Federal regulations. A cost transfer is an adjustment of expenditures to a sponsored program in order to align costs with the actual benefit received by the sponsored program.
The PI/PD is also responsible for ensuring that cost transfers are conducted in a timely manner. Several government agencies have outlined their requirements for cost transfer timeliness.
The Department of Health and Human Services (HHS) Grants Policy Statement states the following with respect to the timing of cost transfers:
- “Permissible cost transfers should be made promptly after the error occurs but no later than 90 days following occurrence unless a longer period is approved in advance by the GMO [Grants Management Officer].”
NIH Grants Policy Statement states the following with respect to the timing for cost transfers:
- “Cost transfers to NIH grants by grantees, consortium participants, or contractors under grants that represent corrections of clerical or bookkeeping errors should be accomplished within 90 days of when the error was discovered.”
Both policy statements state that “[t]he 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 … An explanation merely stating that the transfer was made ‘to correct error' or ‘to transfer to correct project' is not sufficient.”
All cost transfers fall into one of two categories: personnel (for salary related cost transfers) and non-personnel (for anything other than salary related cost transfers)
Please see Cost Transfers Policy 600-029.