10.08 Cost Transfers on Sponsored Programs

---

I. POLICY STATEMENT

---

The University of Texas at San Antonio (UTSA) is committed to ensuring that all costs are directly charged to the appropriate Sponsored Program when such costs are incurred. When circumstances necessitate the transfer of any Sponsored Program cost after such cost is initially recorded in UTSA’s financial accounting system, the cost transfer must be supported by an acceptable justification and written documentation. It must also be accomplished in a timely manner that complies with applicable federal, state, The University of Texas System (UT System), and UTSA policies and procedures.

---

II. RATIONALE

---

1. Cost Transfers are allowed to ensure that costs associated with a Sponsored Program are appropriately charged. Cost Transfers are closely monitored by the Office of Research Finance and Operations (ORFO) through its Office of Post Award Administration (OPAA). Proper award management throughout a sponsored program is essential. The following are examples of poor award management: 1) high volume of Cost Transfers, 2) high volume of Cost Transfers that occur several months after the initial accounting transaction, 3) Cost Transfers that occur after payroll confirmation has been certified, and/or 4) a pattern of Cost Transfers from a Sponsored Program.
2. Cost Transfers associated with Sponsored Programs must conform to the applicable requirements found in the Office of Management and Budget (OMB) Uniform Guidance (UG) 2 CFR 200 at https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200 , which requires the most efficient and effective administration of sponsored projects through the application of sound management practices with a high degree of accuracy and consistency. For this reason, Cost Transfers on all extramurally funded grants, contracts, and other agreements associated with a Sponsored Program must be identified, properly justified and processed, and completed in a timely manner with sufficient documentation to support the transfer. 
3. This policy provides the mandatory criteria and requirements that must be met regarding Cost Transfers on Sponsored Programs.

---

III. SCOPE

---

This policy applies to all UTSA employees involved in or responsible for the fiscal administration of a Sponsored Program.

---

IV. WEBSITE ADDRESS FOR THIS POLICY

http://www.utsa.edu/hop/chapter10/10.08.html

---

V. RELATED STATUTES, POLICIES, REQUIREMENTS OR STANDARDS

---

---

UTSA or UT System Policies or the Board of Regents' Rules & Regulations

1. HOP 10.06, Institutional Base Salary and Payroll Confirmation on Sponsored Programs
2. UTSA HOP 10.07 Cost Sharing on Sponsored Programs
3. Office of Management and Budget (OMB) Uniform Guidance (UG) 2 CFR 200: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200
   

---

VI. CONTACTS

---

If you have any questions about HOP policy 10.08, Cost Transfers on Sponsored Programs, please contact the following office:

Office of Research Finance and Operations (ORFO):
postaward@utsa.edu
1-210-458-5956
1-210-458-8144

---

VII. DEFINITIONS

---

1. Award:
   1. Depending on its context, either: (a) the terms and conditions associated with a Sponsor’s decision to select a UTSA Sponsored Program proposal or application for funding, or (b) the Notice of Award or other documentation reflecting such a decision by the Sponsor.
2. Allowable:
   1. A cost is allowable if it is necessary and reasonable for the performance of the award and be allocable to the Sponsored Program during the approved budget period. An allowable cost conforms to limitations and exclusions set forth by the sponsor (OMB UG 2 CFR 200.403).
3. Reasonable
   1. A cost is reasonable if, in its nature and amount, it does not exceed that which would be incurred by a prudent person under the circumstances prevailing at the time the decision was made to incur the cost (OMB UG 2 CFR 200.404).
4. Allocable
   1. A cost is allocable to a particular award or other cost objective if the goods or services involved are specifically for the award and they are chargeable or assignable to that award or cost objective in accordance with relative benefits received. (OMB UG 2 CFR 200.405).
5. Cost
   1. Equivalent to an expense that has been recorded to the university’s financial system.
6. Cost Transfer
   1. Transfer of a cost (an expense such as salary or non-salary) to or from a Sponsored Program.
7. Individual: An Individual is any UTSA employee who is paid (whether paid by the Sponsor or Cost Shared) on a Sponsored Program. Where appropriate in this policy, the following subcategories will be utilized:
   1. A Primary Individual has responsibility for the overall conduct and management of the research or activity as described in the proposal/application or as identified in the Notice of Award of a Sponsored Program. A Primary Individual is typically identified in the Sponsored Program Award as the principal investigator (PI) or project director (PD).
   2. A Collaborating Individual is a UTSA employee who is paid on a Sponsored Program but does not serve as a Primary Individual on such Sponsored Program. A Collaborating Individual is typically identified in the Sponsored Program Award as the co-investigator (Co-PI).
   3. A Supporting Individual is an employee other than a Primary or Collaborating Individual, who does not have a faculty appointment and is paid on a Sponsored Program.
8. Sponsors
   1. Entities, including federal, state, local, or private entities that provide Awards to fund Sponsored Programs at UTSA.
9. Sponsored Programs
   1. Activities conducted in research, instruction, training, or public service as a result of a formal written agreement (such as a grant, contract, or cooperative agreement), which agreement is typically obtained as a result of a formal application and approval process. These activities can be funded either externally by government, industry, or private sponsors; or, internally by UTSA. Sponsored Programs are separately budgeted and accounted for, meaning there is a defined scope of work, a budget that identifies the costs to be incurred in the performance of the work, and the accumulation of costs actually incurred in support of the project. Sponsored Programs involve a specific commitment of time for each individual involved in achieving the aims of the project.

---

VIII. RESPONSIBILITIES

---

1. The PI/PD
   1. Reviews expenditures on a monthly basis (through UTSA’s Monthly Reconciliation process) to determine if all charges to the Sponsored Program are allowable, reasonable, and allocable;
   2. Reviews the payroll expenses twice a year through the Payroll Confirmation process to determine if all salary charges have been applied correctly;
   3. Ensures that any Cost Transfers are necessary, allowable, reasonable, allocable, and comply with applicable federal, state, local, UT System, and UTSA rules, regulations, policies and procedures;
   4. Coordinates the request for a Cost Transfer through the Business Service Center of their unit;
2. Office of Research Finance and Operations (ORFO)
   1. Reviews and approves all Cost Transfer transactions ensuring the requested cost adjustments or changes comply with appropriate policies, rules and regulations;
   2. Reviews and approves payroll Cost Transfers prior to seeking the approval of the Office of the Senior Associate Vice President for Research Administration; and
   3. Submits Cost Transfers for execution/posting.
   4. Reviews and posts all Cost Transfers to the official accounting records found in UTSA’s financial accounting system.

---

IX. PROCEDURES

---

1. Except in rare circumstances, requests for a Cost Transfer will be made within ninety (90) days after the Cost was initially posted into official accounting records found in UTSA’s financial accounting system. Any request for a Cost Transfer made after the ninety (90) day period will only be allowed if approved by the PI/PD and ORFO, and only if the transfer benefits the Sponsored Program.
   1. All requests for Cost Transfer must have a written justification and adequate supporting documentation showing why the transfer is necessary and that it complies with applicable rules, regulations, policies, and procedures. To indicate “to correct an error” or “to transfer to correct project” are insufficient reasons.
2. All Cost Transfers associated with payroll must be approved by ORFO. A Cost Transfer for salaries is not permitted after Payroll Confirmation certifications are completed and signed by the Individual or after the Sponsored Program closeout date unless it benefits the Sponsor.
3. As reflected above and in the Responsibilities Section, this policy has segregated the duties relating to Cost Transfers to ensure no one person or academic department has the sole authority to initiate, approve, and post a Cost Transfer into the official accounting records.

---

X. SPECIAL INSTRUCTIONS FOR IMPLEMENTATION

---

None

---

XI. FORMS AND TOOLS/ONLINE PROCESSES

---

None

---

XII. APPENDIX

---

None

---

XIII. DATES APPROVED/AMENDED

---

04-29-2022
04-17-2012