Cost Transfers Moving salary, wage, and project expenditures, either from or to a sponsored award, is allowable if proper documentation is provided with the transfer request. Cost transfers fall into two categories: Labor Adjustments and Non-Personnel Costs. LABOR COSTS Labor estimates are posted to the University's pay and effort system by use of a properly completed Electronic Personnel Action Form (ePAF). LABOR REDISTRIBUTION If labor costs are charged to sponsored program accounts in error or if the labor costs are charged to another fund when it should have been a sponsored program cost, then a labor redistribution entry will be processed. Given that a timely review of monthly effort reporting is expected, labor transfers should occur infrequently and must include written documentation as to why the transfer is required. The University’s Budget Office will process all labor redistributions. For non-sponsored funds, written approval from the Budget Administrator or appropriate delegated authority is required. TRANSFERS OF NON-PERSONNEL COSTS Charging costs to the correct account initially demonstrates good administration of sponsored programs and helps ensure the University’s compliance with federal requirements. Cost transfers to or from sponsored programs should be processed when discovered, documented with appropriate justification, and approved by the PI and/or Budget Administrator (or authorized delegates). Costs must be allowable, allocable, and reasonable in accordance with the Office of Management and Budget, the funding agency, the state of South Carolina, and the University’s policies. GENERAL Expenditures made on sponsored awards require monitoring to make sure they are allowable, allocable, and reasonable to be charged to a project. Some costs are allowed under certain conditions, and others are not. Federal policies such as the Cost Accounting Standards, OMB Circulars, and Uniform Guidance are available to help us make these decisions. If a cost is determined to be an exception, documentation is required. Cost Sharing/Matching may be required of some sponsors; therefore, funding will need to be Winthrop University Sponsored Programs & Research 1 monitored and managed to make sure the Principal Investigator can demonstrate that he/she is meeting the award obligations. All sponsored award expenditures should be initially charged to the correct sponsored project. However, occasionally expenses are charged erroneously. When an erroneous entry affects a sponsored project, the correction must be made on a timely basis; and sufficient information must be provided to allow for a clear audit trail back to the initially recorded expense. Cost transfer documentation and timeliness of corrections involving sponsored projects are the department’s responsibility. A cost transfer from one sponsored project to another may not be processed in these instances: to cover cost overruns with funds in other sponsored projects to avoid restrictions imposed by the Sponsor or for convenience TIMELINESS A cost transfer should be processed promptly after the error is discovered. Untimely cost transfers may raise serious questions concerning the propriety of the cost transfer and may be subject to a cost disallowance. A cost transfer is considered “untimely” when it is not corrected within 30 days from discovery of error. Untimely transfers will require additional documentation providing an explanation as to why the transfer was not done on a timely basis. The justification must provide a full explanation of the reason for the delay in processing the correction. The justification should also identify steps taken to prevent the error from occurring again, if appropriate. Winthrop University Sponsored Programs & Research 2