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

Cost transfers are 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 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 unit 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. Requests for a non-personal service Cost Transfer should originate with the unit that originally approved the charge. The request will require adequate supporting statements that clearly indicate that the costs being moved to sponsored worktag 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 unit, must review the Cost Transfer for accuracy and appropriateness.

Cost Transfer Request
A request for a non-personal service Cost Transfer involving sponsored awards must be submitted by the appropriate unit personnel in accordance with Institute procedures.  All requests must be approved by at least two authorized employees, unless the request involves moving costs from sponsored onto non-sponsored funds or the transfer is performed by central administration accounting staff. In these instances only one authorized approver is needed. The approval may also only require one approval if an authorized approver initiated the change, or the department has the same person serving in multiple roles in the workflow framework.  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. 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. Const transfers performed by central staff to move charges to a cost overrun worktag do not require an additional explanation. These transfers are based on reviews by central staff and are normally performed to eliminate budget overruns or charges outside the period of performance.

Cost Transfers onto sponsored worktags are not acceptable under the following circumstances:

  •  To correct deficiencies caused by overruns;

  • To avoid restrictions imposed by law or by the terms/conditions of the sponsored award;

  • To temporarily place charges which will subsequently be transferred elsewhere.  

In addition, costs may not be transferred to a sponsored project merely because there are unexpended funds available that would otherwise be returnable to the sponsor.

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 unless performed by central staff during closeout.

There are certain circumstances where exceptions to this policy may be warranted. Under these circumstances, consideration for recognition of Cost Transfers beyond 90 days will be addressed by the Grants & Contracts Accounting Office. Examples of Cost Transfer situations that represent allowable exception requests can be found on the Grants and Contracts website. 

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) and 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 Executive Director of Grants & Contracts Accounting or their designee 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 worktag to a sponsored award or from a sponsored award to another sponsored worktag. 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

Non-personal service cost transfers can be initiated in the units via a journal entry or accounting adjustment in Workday. To obtain hard copy forms for prior year salary cost transfers, 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
3-08-2024 Office of Grants & Contracts Accounting Editorial updates.
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