Research, Sponsored Program, Technology Transfer and Intellectual Property

Sponsored Project Cost Transfer Policy

Section: Research, Sponsored Program, Technology Transfer and Intellectual Property Policies
Policy Name: Sponsored Project Cost Transfer Policy
Policy Owner: Provost
Responsible University Office: Vice Provost for Research
Origination Date: July 8, 2009
Revisions:  July 21, 2015
Legacy Policy Number: 6-18

    This policy addresses the requirements at the University of Delaware (“UD” or “University”) to ensure compliance with applicable federal regulations (Office of Management and Budget (OMB) Circular A-21 “Cost Principles for Educational Institutions” or Uniform Guidance 2 CFR 200) which establish principles for determining costs applicable to grants, contracts and other agreements with educational institutions as well as the proper documentation required to explain and justify transfers of costs from or to a Sponsored Project.   This policy applies to all University departments, units, faculty, staff and students.
    1. A “Cost Transfer” is an after-the-fact reallocation of a cost from or to a Sponsored Project. Cost transfers must meet conditions for allocability, allowability, reasonableness and consistency established under federal guidelines.
    2. The term “Allowable”, for purposes of this Policy, shall refer to costs that must be consistent with the terms and condition of the specific award, University and federal regulations.
    3. The term “Allocable”, for purposes of this Policy, shall refer to costs that must provide a sole benefit to the project or provide proportionately assignable benefits to the project and other work.
    4. The term “Reasonable”, for purposes of this Policy, shall refer to costs that are reasonable when the cost is necessary for the performance of the Sponsored Project, when an individual would normally purchase the item at that price given the circumstances, and when the cost is incurred consistent with established University policies.
    5. “Consistency” shall be defined as the invariable application of accounting principles from one accounting period to another.
    6. A Principal Investigator (“PI”) is defined as the individual designated in a grant or contract to be responsible for ensuring compliance with the academic, scientific, technical, financial and administrative aspects and for day-to-day management of the Sponsored Project (grant or contract) including programmatic reporting.
    7. “Sponsored Projects” are defined as externally-funded activities in which a formal written agreement, i.e., a grant, contract, or cooperative agreement, is entered into by the University and by the sponsor. A Sponsored Project may be thought of as a transaction in which there is a specified statement of work with a related, reciprocal transfer of something of value.
    1. It is the primary responsibility of a PI, with support of the department research administrator and the department chair, to determine if all Cost Transfers are allowable, allocable, reasonable, and applied consistently.
    2. This policy applies to University of Delaware (UD or University) federally funded primary or sub-contractual agreements.
    3. Cost Transfers should be made within ninety (90) days of the incurred expenditure and must be timely, fully documented and must have appropriate authorization.
    4. The for processing Cost Transfers must be followed as presented on the Research Office website.
    1. Timing
      1. Cost Transfers occurring within 90 days of the end of the month in which a charge is incurred are calculated from the last day of the month in which the charge first posted in the general ledger. For example: A charge first posted in the general ledger on May 2nd would begin its 90 day period on May 31 and end its 90 day period on August 28.
      2. Cost Transfers occurring after 90 days of the end of the month in which a charge is incurred are required to answer a series of questions to provide additional information regarding the appropriateness of the transfer. These questions are:
        1. What is the reason for original account charge;
        2. What is the reason for transfer of account charge;
        3. What is the reason for delay of account charge Cost Transfer request; and
        4. What is the plan to prevent future account charge Cost Transfer requests after 90 days?
    2. Documentation
      1. Cost Transfer documentation must indicate that the PI has approved or directed the transaction.
      2. Documentation related to a Cost Transfer should be kept on file within the department until notified by Research Office that the record retention requirement has been satisfied.
    3. Approval
      All Cost Transfer approvals will be routed electronically for approval and the PI will be copied.

Link:  Cost Transfer Procedure