Type of Policy
Administrative
Policy No
3.6
Effective Date
Last Revised
Review Date
Policy Owner
Office of Grants and Contracts Accounting
Contact Name
Joshua Rosenberg
Contact Title
Senior Director, Grants and Contracts Accounting
Contact Email
josh.rosenberg@business.gatech.edu
Reason for Policy

The matter of cost transfers is a sensitive issue in a university's operation of its sponsored programs and one which always receives careful scrutiny by sponsors. Accordingly, the following policy has been established pursuant to sound business practice and in order to ensure full compliance with federal regulations, contract and grant terms and other conditions concerning cost transfers for Resident Instruction (RI), Georgia Tech Professional Education (GTPE), and Enterprise Innovation Institute (EII) programs. The Georgia Tech Research Institute (GTRI) has a separate policy in place that is applicable to its projects.

Policy Statement

Cost Transfers that are required to correct errors or to achieve the proper, consistent, and equitable distribution of costs to sponsored projects will be allowed, provided adequate justification for the change is furnished by the requesting department and necessary approvals that certify the accuracy of the charges are received by Commitment Accounting and Grants and Contracts Accounting. Such Cost Transfers should be made as soon as possible after the necessity for the transfer is recognized. A Cost Transfer made within 90 days after the posting date of the transaction will be considered timely. In exceptional instances, Cost Transfers may be required after the 90-day period. In such situations, it is acceptable to process a Cost Transfer beyond the 90-day limit if the Cost Transfer request is properly supported and certified, and adequate documentation is provided (see Non-Personal Service Cost Transfers Requiring Special Approval Authorization below). This policy is applicable to Non-Personal Service Cost Transfers. See Policy 3.2 “Personal Services Reporting Using the Plan Confirmation System” for specific procedures related to retroactive salary distribution changes.

Non-Personal Service Cost Transfers
Georgia Tech authorizes the principal investigator (PI) and the unit designee (financial manager and staff) to have primary responsibility for the management of sponsored agreement funds.

All requests for a non-personal service Cost Transfer should originate with the department that originally approved the charge. The request will require adequate supporting statements that clearly indicate that the costs being moved to a project are directly related to the project scope, allowable by the project budget, and incurred in a timely manner such that they benefit project activities.  The designated financial administrator or other responsible party with firsthand knowledge, according to delegated authority within the department, must certify the accuracy of the Cost Transfer.  Submission of a Cost Transfer by an authorized unit designee is considered certification of the above.

Cost Transfer Request
A request for a non-personal service Cost Transfer involving sponsored projects must be submitted by the appropriate college and school personnel in accordance with Institute procedures.  All requests must be approved by at least two authorized employees.  Some requests will require additional approval based upon established validations. 

Non-Personal Service Cost Transfers Requiring Special Documentation
For every cost transfer, a valid and complete explanation is required that clearly indicates that the costs being moved to a project are directly related to the project scope, are allowable by the project budget, are allowable by the terms and conditions of the award, and are required to complete the objectives of the sponsored agreement. In addition, any available supporting documentation should be attached to the Cost Transfer Request so that it will be available for subsequent audit review.

Examples of Cost Transfer situations that require special documentation can be found on the Grants and Contracts website.

The matter of cost transfers is a sensitive issue in a university's operation of its sponsored programs and one which always receives careful scrutiny by sponsors. Accordingly, the following policy has been established pursuant to sound business practice and in order to ensure full compliance with federal regulations, contract and grant terms and other conditions concerning cost transfers for Resident Instruction (RI), Georgia Tech Profes The matter of cost transfers is a sensitive issue in a university's operation of its sponsored programs and one which always receives careful scrutiny by sponsors. Accordingly, the following policy has been established pursuant to sound business practice and in order to ensure full compliance with federal regulations, contract and grant terms and other conditions concerning cost transfers for Resident Instruction (RI), Georgia Tech Professional Education (GTPE), and Enterprise Innovation Institute (EII) programs. The Georgia Tech Research Institute (GTRI) has a separate policy in place that is applicable to its projects. sional Education (GTPE), and Enterprise Innovation Institute (EII) programs. The Georgia Tech Research Institute (GTRI) has a separate policy in place that is applicable to its projects.

At a minimum, supporting documentation means that a copy of some form of original documentation (such as a travel expense report, original invoice, etc.) will be provided.

Non-Personal Service Cost Transfers Requiring Special Approval Authorization
All Cost Transfers are to be processed in a timely manner and properly documented. Cost Transfers to externally-funded** sponsored awards beyond 90 days of the original expense posting will not be allowed under normal circumstances.

Provisions for exceptions to the 90 day limit will be considered in situations where initial or continuing sponsor funding is delayed beyond 90 days after the effective date of the award. Consideration for recognition of Cost Transfers beyond the limit will be addressed by the Grants & Contracts Accounting Office if the transfer is requested within the reporting period of the sponsored project (which typically ends 60-90 days after the expiration date of the project). If the terms and conditions of the sponsored agreement provide for acceptance and payment of the expenses covered by the proposed Cost Transfer and appropriate supporting documentation is provided, the Director or Senior Director of Grants & Contracts Accounting may approve the proposed transfer. Other exceptions will be considered on a case-by-case basis.

** Excludes sponsored projects funded by the Georgia Tech Foundation and Georgia Tech Research Corporation. Transfers between projects associated with the same sponsored fund (award) are not subject to the 90 day limitation.

Scope

All employees engaging in sponsored research activity.

Policy Terms

Cost Transfer

A Cost Transfer involves an action in which costs are moved from a non-sponsored project to a sponsored project or from a sponsored project to any other project. Excluded are initial transfers of charges for supplies or services from an inventory account, a cost center, or other similar operations in accordance with established accounting procedures. Also excluded are corrections of processing errors that occur within the Business Office of Finance and Planning accounting systems such that when the correction is made, the accounting records are in agreement with the documentation that authorized the change. Corrections of encumbrances are not considered Cost Transfers, and any such changes are to be processed according to Procurement and Business Services Office procedures.

Procedures

Forms

To obtain hard copy forms, please contact the Office of Grants & Contracts Accounting at gc.ask@business.gatech.edu or go to https://grants.gatech.edu/.

Frequently Asked Questions
Contact the Office of Grants and Contracts Accounting at gc.ask@business.gatech.edu for additional guidance related to Cost Transfer requests.

Responsibilities

Principal Investigator (PI) Responsibilities
Each Georgia Tech PI is responsible for effectively overseeing and managing their sponsored projects based upon their knowledge of the field of study and their capabilities to conduct the projects in an efficient and productive manner. PIs are to perform periodic reviews of charges to provide proper financial oversight as outlined in the PI Project Management Reference Manual.  

Authorized Unit Designee (financial manager, grant manager and staff) Responsibilities
Each Georgia Tech research administrator is responsible for effectively overseeing and managing sponsored award portfolios based upon their knowledge of award terms and conditions and applicable federal, state, and institutional policies and procedures.  Unit Designees are also responsible for the accuracy, allowability and allocability of charges authorized by the PI or their designee and providing adequate documentation in a timely manner.

Grants & Contracts Accounting Responsibilities
The Grants & Contracts Accounting Office approves Cost Transfers meeting approval criteria based on review of the proper authorization, accuracy of the accounting, and adequacy of the supporting documentation in accordance with federal, state, and institutional policies.  Reliance is placed upon the submitting unit, as the level with firsthand knowledge, regarding benefit to the award scope and compliance with award specific terms and conditions.

Policy History
Revision Date Author Description
02-24-2022 Office of Grants & Contracts Accounting

Updated timeline requirements for completing Cost Transfers and removed procedures.

10-01-2015 Office of Grants & Contracts Accounting Updated Non-Personal Service Cost Transfers Requiring Special Approval Authorization for externally-funded Sponsored Projects from 120 days beyond the original expense posting date to 90 days aligning with close-out requirements of OMB 2 CFR 200.
11-05-2014 Office of Grants & Contracts Accounting Align with requirements of 2 CFR 200
04-01-2014 Office of Grants & Contracts Accounting Administrative review