The purpose of this policy is to provide guidelines for performing cost transfers that allow Creighton University (CU) to comply with the standards set forth in OMB Circular A-21, Cost Principles for Educational Institutions, and 48 Code of Federal Regulations Part 9905, Cost Accounting Standards for Educational Institutions. As a recipient of federal awards, Creighton University is obligated to comply with rules and regulations promulgated by various federal offices. These offices include sponsoring agencies such as the National Institutes of Health and National Science Foundation and regulatory agencies such as the Office of Management and Budget (OMB). The OMB has adopted regulations from the Cost Accounting Standards Board (CASB) and applies them to educational institutions.
Cost transfers are an area of concern to federal auditors and negotiators; therefore, it is important that this policy is understood and consistently followed.
Since costs must be charged to accounts accurately and according to applicable rules and regulations, original transactions should not need corrections. However, in certain circumstances, charges may have to be moved from one account to another. Therefore, cost transfers are allowable with adequate documentation and approval. An adequate explanation for all cost transfer actions must be clearly stated on the request.
Timely - Cost transfers must be made within 90 days of the original occurrence of the charges or within 45 days of the expiration of a grant or contract. No cost affecting operating (GCF and UDF) funds will be processed between fiscal years.
Adequate documentation - Documentation must include the date of the original charge, the reference number of the original document (invoice number, JE number), description of the charge being transferred and why the cost is being transferred. This explanation cannot merely state that the transfer was made 'to correct error' or 'to transfer to correct project.' If the transfer is necessary because of an error, the explanation must state how and why the error occurred. In addition, salary cost transfers must include the name of the individual whose salary is being transferred, the pay periods affected and modified Personnel Activity Reports (PARs), if applicable. If the cost transfer will affect more than one department, the department initiating the request is responsible for advising all impacted parties.
Approval - The principal investigator must sign cost transfer requests if a sponsored project is involved.
This policy should be known and understood by the following groups of individuals:
- Department Chairs
- Department Administrators
- Principal Investigators
- Other Accounting/Finance Personnel
- Grants Administration Personnel
- Controller's Office Personnel
- Internal Audit Personnel
Cost Transfers are the moving of costs from one accounting distribution (fund and/or organization) to another accounting distribution. Normally, the account code would be the same on both the debit side and the credit side of an entry.