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Dear Business and Grant Administrators,

It is the policy of the University of Vermont that costs shall be charged to the appropriate sponsored agreements when first incurred.  At the same time, costs may be transferred after they are initially recorded as long as this is accomplished in compliance with the University Operating Procedure for Cost Transfer on Sponsored Agreements. UVM's Vice President for Finance and Treasured is the Responsible Official and the effective date of the latest version is March 2017.

All University employees with responsibilities for sponsored agreements are expected to be aware of and comply with this UOP and the principles and requirements listed in it. The March 2017 UOP and related cost transfer information can be found on SPA's webpage Cost Transfers Involving Sponsored Agreements<http://www.uvm.edu/spa/?Page=costtransfersonsponsoredagreements.html>.

Timeliness of identifying and correcting costing errors via cost transfers are key provisions of the UOP.  A cost transfer is the assignment of an expense or expenditure (charge) to a sponsored agreement that was initially recorded elsewhere in the University's general ledger.

SPA guidance on cost transfers:


*         Minimize cost transfers: take every effort to classify cost correctly initially

*         Avoid cost transfers in the last 90 day period of a grant and the appearance of trying to 'spend down'

*         PIs and PI designees are responsible to ensure that verification of financial transactions occurs on a timely basis, at least monthly

*         Justify and document: explain why the cost was not put in the correct place initially and why the change is being made.

*         90-day rule: cost transfers must be prepared and submitted no later than 90 calendar days from the accounting date of the original posting

o    NIH* has very strict guidelines about cost transfers; UVM's UOP for Cost Transfers on Sponsored Agreements holds all federal grants to that same standard

*         > 90 days: transfers will only be approved by SPA in extenuating circumstances

o   Absence of the Principal Investigator, or cognizant administrator, or lack of experience of the staff administering the awards are generally NOT considered extenuating circumstances

*         Unallowable expenses: departments must promptly remove all such expenditures once they are identified, regardless of timeframe
*NIH Policy Statement<https://grants.nih.gov/grants/policy/nihgps/HTML5/section_7/7.5_cost_transfers__overruns__and_accelerated_and_delayed_expenditures.htm?tocpath=7%20Cost%20Consideration%7C_____5>:
Cost transfers to NIH grants by recipients, 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. The 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 of the recipient, consortium participant, or contractor. An explanation merely stating that the transfer was made "to correct error" or "to transfer to correct project" is not sufficient. Transfers of costs from one project to another or from one competitive segment to the next solely to cover cost overruns are not allowable.

Sonya Stern, MBA

Director
Sponsored Project Administration
University of Vermont
217 Waterman Building
85 S. Prospect Street
Burlington, VT 05405-0160
P: 802 656 1986


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