Columbia has a responsibility to use funds in accordance with applicable law and sponsor terms and conditions.
The federal government scrutinizes cost transfers closely for indications of cost misallocation, and often disallows costs transferred into federal accounts on that basis, or because of non-compliance with timing, documentation, and procedural requirements.
Improper, inadequately documented, and delayed cost transfers (beyond 90 days of the date the expense was originally incurred) violate Federal law or cost policy and are potentially costly and damaging to the University.
Frequent cost transfers and cost transfers made long after the original cost is incurred (even if valid) raise questions about the reliability of the institution’s accounting system and internal controls.
OMB Circular A-21 Revised, Section C4, states:
Any costs allocable to a particular sponsored agreement under the standards provided in this Circular may not be shifted to other sponsored agreements in order to meet deficiencies caused by overruns or other fund considerations, to avoid restrictions imposed by law or by terms of the sponsored agreement, or for other reasons of convenience.
OMB Circular A-21 Revised, Section C.4.d(3), states:
If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost should be allocated to the projects based on the proportional benefit. If a cost benefits two or more projects or activities in proportions that cannot be determined because of the interrelationship of the work involved, … the costs may be allocated or transferred to benefited projects on any reasonable basis.
Corrections of clerical or bookkeeping errors should be made within 90 days of the discovery of errors.
Transfers must be supported by documentation fully explaining how the error occurred and certified by a responsible organizational representative that the new charge is correct.
Explanations such as “to correct error” or “to transfer to correct project” are not sufficient.
Delayed discovery of errors could be an indication of poor internal controls.