COST TRANSFERS AT-A-GLANCE

1. COST TRANSFERSAT-A-GLANCE THE FOLLOWING IS PROVIDED AS A BRIEF OUTLINE OF THE BASIC REQUIREMENTS FOR EMORY’S COST TRANSFER POLICY. FOR COMPLETE INFORMATION, PLEASE READ THE FULL TEXT OF THE POLICY LOCATED ON THE FINANCE DIVISION WEB SITE UNDER POLICIES. FOR QUESTIONS ABOUT THE POLICY CONTACT OGCA.

2. ALL COSTS MUST BE: • Reasonable • Necessary • Allowable • Allocable • Within the award period • In compliance with specific award terms, conditions, requirements

3. COST TRANSFER TYPES • Journal Vouchers (non-payroll) • Inter-Departmental Charges and Transfers (non-payroll) • E-journals (non-payroll) • Retroactive Salary Transfers (payroll) • All cost transfers on sponsored accounts must be approved/signed by OGCA.

4. APPLICABILITY • The Cost Transfer Policy applies to • All sponsored accounts Federal and non-Federal • All accounts within the OGCA range • 5 ledger • 6 ledger 6-37xxx-6-47xxx • Specified overrun and cost share 2-ledger accounts

5. GENERAL RULES • The account allocation should be carefully reviewed before documents are submitted for payment processing. • The sponsor and the University expect adequate oversight of expenditures and accurate accounting transactions. • Quality control and compliance review is everyone’s responsibility. • Costs should only be placed on the account that actually incurs the expense and benefits from the use of the item. • Costs should not be “parked” on a restricted account. • Cost transfers should be kept to a minimum and should not be a routine method of account management. • Late or frequent or high volumes of cost transfers may be indications of inadequate stewardship and oversight.

6. GENERAL RULES • The cost transfer must be within 90 days of the expenditure. • 90+ day transfers should be extremely rare and only processed under unusual circumstances. • Costs should not be transferred more than once. Second transfers are usually only authorized to an unrestricted account. • Cross-Departmental transfers should be approved by both Departments.

7. SPECIAL REQUIREMENTS • Transfers over 90 days require the PI’s signature and an “exceptional circumstance” explanation. • Transfers related to financial reports (FSRs) must be to OGCA (in hand) prior to the FSR, usually a maximum of 30-60 days from the budget period end date. • Transfers will not normally be processed across FSR periods.

8. SPECIAL REQUIREMENTS • Late transfers will not normally be processed that affect (increase) a filed FSR or final invoice. • Late transfers will be processed that decrease a filed FSR or final invoice. Costs cannot be “swapped” and the resulting balance will be restricted or returned to the sponsor, based on sponsor requirements. • Transfers to continuation accounts should be processed within 30 days after the new account is established in FAS.

9. SPECIAL REQUIREMENTS • All transfers over $10,000 require School or Administrative Entity level approval. • All transfers over 90 days require School or Administrative Entity level approval. • Fund transfers over $3,000 require the PI’s signature. • Special signature requirements, for all cost transfers, have been established by each School/AE.

10. SPECIAL REQUIREMENTS - RSTs • For monthly employees, RSTs will not be processed across effort certification periods unless: • Transfer reconciles to an ECR already on file • Transfer removes charges to a non-restricted account for cost share purposes (effort not changed) or reduces charge to the grant • Transfer does not affect an FSR or final invoice

11. SPECIAL REQUIREMENTS - RSTs • For bi-weekly employees, RSTs will not normally be processed unless there is a system issue such as: • Entry reconciles/matches to on-line certification • Transfer is to a successor account • Transfer is to an unrestricted account (reduces charge to the grant) • Transfer does not increase/affect an FSR • See on-line effort certification process for additional information

12. BEST TIPS • In order to avoid cost transfer problems: • Request Provisional Account Numbers (PAN), as soon as the need is known. • Request account freezes as soon as a deficit occurs or as soon as it is known that a project is terminating. • Review account transactions on a timely basis. • Process necessary cost transfers prior to the termination date of a budget period.

13. BEST TIPS • Review salary distributions/HRAFs on a frequent and timely basis. • Review standing order accounting assignments on a frequent and timely basis. • Submit necessary corrections as soon as the need is discovered. Do not delay processing.

14. SIGNATURES • By signing a cost transfer, all signatories are certifying that the transaction has been reviewed, and it is their belief that the transaction is allowable and appropriate and is in conformance with Federal regulations, this Policy and other University policies. • ALL signatories should carefully review each cost transfer to assure compliance with these requirements and to minimize potential audit issues.

15. SIGNATURE REQUIREMENTS • Special signature requirements for cost transfers have been established by each School or Administrative Entity • Only the designated individuals may sign/approve a cost transfer in the OGCA range of accounts. • All Departmental/School/AE signatures must be completed prior to submission of the entry to OGCA. • OGCA may reject entries that do not have appropriate signatures.

16. AUTHORIZED SIGNATORIES • The authorized signatories for cost transfers will change periodically, based on changing staff or other needs. • For current authorized cost transfer signatures, contact your Departmental Administrator or your OGCA representative.

17. AUDIT • All cost transfers are subject to specific audit review by the sponsor or other audit teams; especially for timeliness and appropriateness of the cost. • Cost transfers may be disallowed by the auditors. • Cost transfers should be kept to a minimum. • PIs and departments should maintain strong documentation of the appropriateness of any cost transfer. • Cost transfers are “high profile” transactions in any audit or desk review.