Administrative Policy Statement
Research Costing Compliance

Policy Name: Non-Payroll Cost Transfers on Sponsored Projects

I.	Scope
II.	Policy
III.	Guideline
IV.	Additional Resources
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I. SCOPE

This policy covers the allowability, timeliness and approval of non-payroll cost transfers on federal sponsored programs.

II. POLICY

In accordance with OMB Circular A-110, Duke University’s practices and systems are designed to ensure expenditures are charged in a timely manner to the correct General Ledger account and sponsored program. However, if an erroneous entry is posted that impacts a federal sponsored program, all efforts should be made to have the correction completed on a timely basis (within 3 accounting periods) and provide sufficient information to allow for a clear audit trail back to the initially recorded expense.

Cost transfer documentation and timeliness of corrections involving federal sponsored projects are the responsibility of the department. When errors occur, departments are required to evaluate the charges and make the necessary corrections in accordance with applicable University policies and procedures. Specific guidance and documentation requirements are included in GAP 200.150, Cost Transfers On Federal Sponsored Projects.

Deadlines associated with the submission of cost transfers are as follows:

Timeframe Approval

< 3 months As defined by the department

> 3 months Department and Management Center (may require cost-sharing)

> 6 months Unallowable cost to federal sponsors (must be charged to institutional funds)

In all cases, an unallowable expenditure must be removed from a federally sponsored project regardless of timeframe.

III. GUIDELINE

The Office of Research Costing Compliance (RCC) will monitor compliance (allowability, timeliness and adequacy of documentation) of cost transfers covered by this policy. Non-compliance will be addressed by RCC with the support of the Management Centers.

During project closeout, the Office of Sponsored Programs reserves the right to move untimely and/or unallowable cost transfers to the department’s discretionary cost center.

Note: As of October 1, 2006, untimely cost transfers are no longer allowed on DHHS Non-NIH grants without prior DHHS approval. This includes, but is not limited to the following Grantors:

Administration for Children and Families
Agency for Health Care Policy and Research
Centers for Disease Control and Prevention
Substance Abuse and Mental Health Services Administration
Health Resources and Services Administration
Food and Drug Administration

Departments must coordinate exception requests through the appropriate Pre-award Office. The Pre-award Office will review and approve only those cost transfers with extraordinary circumstances and appropriate documentation.

Exceptions and clarification: the lack of documentation or untimeliness does not mean the transaction is unallowable from an external perspective. Departments should review all transactions and confirm allocability and allowability. Exceptions may be granted by the Vice Dean/Provost for Research or their designees.

IV. ADDITIONAL RESOURCES