1. Sponsored Programs at Penn
Cost Transfers

2. Cost Transfers What are Cost Transfers?
On Sponsored Project funds, adjusting entries that meet certain criteria may be considered a Cost Transfer by regulatory agencies and may be subject to additional regulatory timing and documentation requirements (and may also vary by sponsor)
Criteria considerations include but are not limited to:
Transactions being moved onto a sponsored project from another sponsored project or a non-sponsored project.
Amount of the transaction
Number of days since the month-end of the original transaction date

3. Cost Transfers
Regulatory agencies have specified the following transactions in their guidance as “Cost Transfers”:
Corrections of amounts initially charged to a sponsored project account (Corrected Costs)
Amounts charged to a sponsored project account from another sponsored project account (Grant to Grant Costs)
Amounts charged to sponsored project accounts over 90 days after the end of the month of the original transaction date (Over 90 Day Costs)
On Sponsored Project funds, adjusting entries that meet certain criteria may be considered a Cost Transfer by regulatory agencies and may be subject to additional regulatory timing and documentation requirements (and may also vary by sponsor)

4. When
University Best Practices are to make any adjustments, corrections, or other entries to correct costs as close to the date of the original transaction as possible
A periodic review with the PI is to be performed and documented
In general, cost transfers should be performed within 90 days of the month-end of the original transaction date. In extraordinary circumstances, ORS will approve cost transfers exceeding the 90 day threshold

5. Responsibility / Training
The Principal Investigator and his/her delegates, including BAs, are responsible for ensuring the timeliness, accuracy and allowability of costs charged to sponsored projects and preparing and maintaining the associated supporting documentation
Shared Research Governance Process with schools/center representatives
BEN Training is required, in order to access appropriate Responsibility within BEN
All Grant and Contract Cost Transfers are processed within the Journal Entry – G&C Cost Transfers for Expense responsibility and will fall under one of three categories

6. Controls
Category 14 ADJUST is for adjustments under $1K and within 90 days of the month end of the original transaction date. Also can be used for certain adjustments greater than $1K and/or over 90 days that are not defined as cost transfers
Category 14 journals will post nightly
Category 15 G&C UN90 is for cost transfers that are within 90 days of the month end of the original transaction date
Category 15 journals will post nightly
Category 16 G&C OV90 is for cost transfers that exceed 90 days of the month end of the original transaction date
Category 16 journals require ORS review and approval prior to posting

7. Decision Tree

8. Documentation
Grant & Contract Cost Transfers must include the following:
Explanation of the Cost Transfer
Original Batch Name and Original Period of the transaction being corrected
Original Source Documentation
Explanation of the Direct Scientific Benefit to the Funding Source
Authorization of BA/Delegate
BEN Financials is the tool to capture the above information (attachment function available)
NO MORE SUBMISSION TO CostTransfer ACCOUNT

9. Cost Transfer Report

10. Other J/E Categories for 5-fund Related Transactions

11. Example #1
Upon reviewing MAR-18 fund reports, the PI indicates that the following transactions need to be move to a different project/award:
A $ travel expense, which originally was charged to an NIH R01 fund on 3/14/2018, needs to be moved to NSF fund
$1, lab supply charge that initially hit GL in DEC-17 that needs to be moved from DEPT account to an NIH R01 fund
A PCARD transaction of $1,100 needs to be moved from DEPT default account to NIH R01 fund
Which Cost Transfer category(s) should be utilized and why?

12. Example #2
Upon reviewing MAR-18 fund reports, the PI indicates that the following transactions need to be move to a different project/award:
A stipend reallocation for post-doc was needed for Jan-18 pay period. The associated post-doc health insurance also needed to be transferred from DEPT acct to the appropriate fund (NSF ).
A $ wayward lab charge that initially hit but should have hit The charge initially cleared the GL in NOV-17
A $2,350 subcontract invoice cleared in Nov-17 on NIH R (Year 2), but it should have hit NIHR01 (Year 3) fund.
Which Cost Transfer category(s) should be utilized and why?