Docstoc

Responsibilities

Document Sample
Responsibilities Powered By Docstoc
					Cost Transfers



                 1
Learning Objectives
•   At the end of this training, you should be able to:

        - Define and understand cost transfers.

        - Know how to execute a proper cost transfer
               transaction.

        - Understand acceptable and unacceptable cost
               transfer practices.

        - Pass the certification exam.
                                                          2
Agenda

   Definition, Roles and Importance
   Federal Regulations
   Good & Bad Practices
   Processing Non-Labor Cost Transfers
   Processing Labor Cost Transfers
   Monitoring
   Getting Help
                                          3
Your Roles and Responsibilities

•   As a Yale employee working with sponsored
    research, you play a key role in the financial
    administration of the University. You are
    responsible for ensuring that sponsored funds are
    managed according to Yale policies and procedures
    and sponsor terms and conditions.

    This overview will help you understand how to
    carry out these responsibilities using Yale’s new
    Cost Transfer Policy Guidelines.

                                                        4
    What is a cost transfer?
•   Any cost that is first charged to one award and later
    charged to another award, where one or both of the
    awards is a grant or contract, is referred to as a cost
    transfer for sponsored awards.

•   Reclassification of charges within an award are not cost
    transfers.

•   There are two types of cost transfers…
     • Non-Labor, achieved at Yale via a journal entry, and
     • Labor, achieved at Yale via a labor distribution adjustment.
                                                                      5
Non-Labor Costs
•   These costs include all costs other than salaries,
    wages, and benefits.
•   They are purchases of goods & services
•   Examples:
    •   Reagents,
    •   Lab Supplies,
    •   Equipment,
    •   Travel,
    •   Internal Service Provider charges (stock room, YARC)


                                                               6
Labor Costs
•   Labor costs are salaries, wages, and benefits.

•   To justify labor costs paid by federal funds, the
    University must

    • Maintain payroll records
                  AND
    • Confirm charges after the fact. At Yale we confirm
      charges using Activity or Effort reporting.
        •   Monthly for Clerical and Technical staff
        •   By term (fall, spring, summer) for 9-month faculty
        •   Semi-annually for 12-month faculty, professional employees,
            and graduate students.
        •   Timesheets for weekly and casual employees.                 7
Why are cost transfers an
important topic?
•   Yale 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 after discovery of error) 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.

                                                                                8
    Mayo Clinic Story

•   In May 2005, the Mayo Clinic paid approximately $ 6.5 million to settle a
    fraud suit alleging that it improperly charged the government for work
    performed under federal grants from NIH.

•   The government alleged that the Mayo Clinic had long-standing practices
    of
     • Spending down grant accounts at the end of the year to avoid
       returning unused funds to NIH,
     • Shifting costs from grant projects that were over-expended to grant
       projects that were under-expended without adequate documentation,
     • Retroactively altering effort and financial progress reports to reflect
       the reassignment of charges to the grants with remaining funds,
     • Not properly documenting transfers, and
     • Not making transfers in a timely manner.

•   While the Mayo Clinic did not admit wrongdoing in the settlement,
    the hefty settlement payment and adverse publicity were
    detrimental.                                                  9
What do Federal Regulations
require?
OMB A-21 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” (U.S. OMB, Circular A-21 Revised,
Section C4).


                                                     10
OMB A-21 Continues:

  “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” (OMB A-21 Revised, Section
  C.4.d(3)).
                                                    11
    NIH Grants Policy Statement

•   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.
                                                         12
    NIH Grants Policy Statement
    (continued)
•   Transfers of costs from one project to another or from one
    competitive segment to the next are not allowable if they
    are made solely to cover cost overruns or to spend
    down a grant.

•   Grantees must maintain cost transfer documentation and make
    it available for audit and other reviews.

•   Frequent errors in recording original costs may indicate the
    need for system or internal control improvements.

•   NIH may require grantees to take corrective action by imposing
    additional terms and conditions on grants, for example, an
    organization could lose the privilege of “expanded authority,”
    which allows institutions some flexibility for managing grants
    without obtaining prior sponsor approval.
                                                                   13
Charges to Federal Grants must
benefit the project AND be
Allowable      Items not restricted by OMB A21 or
               the specific grant.
Reasonable     Goods or services acquired and
               amount involved reflect an action a
               prudent person would have taken
               (Prudent Person Rule).
Allocable      Chargeable based on the relative
               benefits received by the project.
Treated        Like costs in similar instances need
Consistently   to be treated consistently
               throughout the University.           14
Good Practices:
GET IT RIGHT THE FIRST TIME!
•   Plan expenditures to try to avoid cost transfers. Cost transfers should
    not be a standard means for managing grants.
•   Charge costs to the correct award initially and ensure they are
    allowable and allocable to that award.
•   Create labor schedules in advance to avoid making after-the-fact
    labor distribution adjustments.
•   When costs are shared by more than one award, use split charging
    instructions. When this is not possible, allocate costs within 90 days.
•   Set up non-sponsored program accounts to hold costs to be allocated.
•   Change standing PTAEO’s for items such as salaries and standing
    purchase orders in a timely manner when award numbers change.
•   Request an “At Risk fund” to charge costs incurred prior to receipt of
    a notice of grant award.
                                                                          15
Good Practices
(continued)
•   Obtain no-cost extensions prior to the end of the original
    project to complete work after the original award period ends.
•   Plan and monitor costs regularly.
•   Provide PI’s with monthly financial reports and help to review
    them, comparing costs with budgets & investigating
    questionable charges.
•   Make required cost transfers in a timely manner (within 120
    days of original transaction or 90 days of discovery whichever
    is earlier).
•   Remember that each award as a separately financed project
    with separate technical and financial products.
                                                                 16
Red Flags
•   Transfers to or between federal grants.
•   Transfers older than 120 days after original
    transaction.
•   Transfers in the last month of the award or after
    the award has expired.
•   Large numbers of cost transfers.
•   Grants or contracts with a zero balance at the end
    of the award.
•   Round numbers (may be an indicator of a plugged
    number).
•   Paying summer salary late (in December).
•   Labor distribution adjustments to previously
    certified effort.                                    17
Bad Practices

•   Transfers with inadequate
    explanations.
•   Explanations that raise more questions
    than answers.
•   Incomplete documentation
•   Using “to correct an error” or “to
    transfer to correct project” as an
    explanation.
                                         18
DO NOT
•   Pool sponsored awards.
•   Use any sponsored project as a holding
    account.
•   Make cost transfers to other sponsored
    projects to spend down a grant.
•   Transfer costs from one sponsored project
    to another to clear an overdraft.
•   Transfer costs to avoid the 25% carryover
    approval requirement.
                                                19
When are cost transfers
required?
•   When one cost benefiting multiple projects
    needs to be allocated among them (for
    example service center charges).

•   If a cost has been charged to the incorrect
    award (for example, data entry error,
    reallocation of effort, pre-award costs, late
    issuance of notice of award).

                                                    20
If you must make a cost
transfer…
•   Ensure the reason for the transfer is acceptable.

•   Ensure the cost to be transferred is allowable, reasonable and
    allocable to the new account, and was incurred within the award
    period or is permissible as a pre-award charge.

•   Process the transfer in a timely manner.

•   Document the transfer properly:

     • Provide a detailed explanation of the error and how it occurred.

     • Explain how the cost benefits the grant being charged.

     • Obtain written authorization from the PI or other responsible
        departmental representative knowledgeable about the grant.

                                                                          21
Transferring Non-Labor Costs

THE PREPARER:
   Step 1. Assemble information and evaluate the cost transfer.
   Step 2. Make the journal entry
   Step 3. Check your work
   Step 4. Give transaction documentation to the approver
THE APPROVER:
   Step 5. Review the Transfer
   Step 6. File the Transfer Documents


                                                              22
Transferring non-labor costs.
Step 1.
 A. Assemble the paperwork, including
       A copy of the original transaction;
       Original and new charging instructions (PTAEOs);
       A written authorization to make the transfer signed by
        the Principal Investigator or other responsible
        institutional representative knowledgeable about the
        grant (email or hand-written note is acceptable);
       If allocating costs between two or more projects, a
        description of how the allocation was done;
       A written explanation of how the error occurred;
       A written explanation of how the cost benefits the
        sponsored project to which the charge is being
        transferred.
                                                             23
What documentation of the
original transaction is
acceptable?
 • Invoice
 • Internal Service Provider bill or receipt.
 • For VIP purchase: Any document that identifies what was
     purchased, including invoices and packing slips.
 • Purchasing card (Pcard) expenditures over $75 – receipts.
 • Purchasing card purchases under $75 – Signed monthly P-
     Card Statement with purchase listed.




                                                               24
Transferring non-labor costs.
Step 1 (continued).

B.Evaluate the cost transfer
        – Does the original transaction fall within the award period
          or is it allowable as a pre-award charge?
        – Is the charge allowable (check OMB A21 and restrictions
          in the Notice of Award)?
        – Is the cost reasonable?
        – Is the cost allocable to this award?
        – Is this cost being handled in a consistent manner?
        – Is the justification complete, including a description of
          the allocation method or an explanation how the error
          occurred?
  If the answers to all these questions are “yes,”
     proceed to next set of questions. If the answer
     to any question is “no,” contact your supervisor
     or GCFA.
                                                                  25
Transferring non-labor costs.
Step 1 (continued).

B.      Evaluate the cost transfer
           – Is the transfer being made to cover a cost overrun?
           – Is the transfer being made in the last months of the
             award or after the award has expired?
           – Is the amount being transferred a round number?
     If the answers to any of these questions is “yes,”
        review with your supervisor or GCFA.
        Otherwise, proceed to the next question.

           – Is the cost transfer being made more than 120 days
             after the original transaction or more than 90 days after
             discovery whichever is earlier?
     If the answer to this question is “yes,” you must
        provide a written explanation why it is late.
                                                                     26
Transferring non-labor costs.
Step 2.

Make the Journal Entry

  A.   Prepare the journal entry choosing YGCIndNonLabTr as
       the Journal Staging Area (JSA) category in the Batch
       Header.




                                                              27
Transferring non-labor costs.
Step 2 (continued).

 B.   In the Flexfield called “Date of Original Transaction,”
      enter the original transaction date of the transaction, not
      the date the error was discovered.
 C.   Enter the reference number of the original
      transaction (invoice number, batch name, et al.) in the
      “Reference ID of Original Trx” field.




                                                                28
Transferring non-labor costs.
Step 2 (continued).
D.        Justify the cost transfer:

If                                          Where to record the justification
The same justification applies to all       In the “Description” at the top of the
lines of the batch                          first Journal entry screen
A different justification applies to each   In the “Description” at the “Line” level
line of the batch
More space is needed                        Use the “Reason” and “User Defined”
                                            fields on the Flexfield

When justifying the transaction, be sure to explain specifically
        1) how the allocation was made or how the error occurred,
        2) how this award benefits from this cost, and
        3) who authorized the transfer to be made.
                                                                                       29
Where to justify the Transfer

If the same justification applies to all batch lines, enter justification in
the “Description” field at the top of the first Journal entry screen. It will
copy down to all journal lines.




                                                                            30
Where to justify the Transfer

If each journal line has a different justification, use the “Description”
    field at the “Line” level:




                                                                            31
  Where to justify the Transfer

If more space is needed, use the “Reason” and “User Defined” fields on
the Flexfield




                                                                         32
Good Descriptions Should
State
•   How the error occurred / Why JSA is needed (technician
    inadvertently used wrong PCard to purchase supplies)



•   How the error was found / Who initiated JSA (noticed during
    PI review)



•   Why the new PTAEO is correct     (charging award originally
    intended)

                                                                  33
Examples of Good JSA
Reasons & Descriptions
•   Move cost incurred prior to the set-up of a new award from
    GA account per PI and Business Manager.

•   Purchased bulk quantity of acetone from stock room, which
    cannot split charges to multiple awards. This entry splits the
    charges based on PI’s anticipated use. Allocation method on
    file in department.

•   Supplies were originally purchased for award A12345, but
    were actually used on award R23456. Lab manager informed
    business manager of change in plans in the month of
    occurrence.


                                                                     34
Examples of Good JSA
Reasons & Descriptions
•   To correct YARC billing which charged the wrong award. YARC
    was told of this change, but we missed their cutoff for the
    month. Error discovered by PI during monthly review of
    award statement.

•   We made two similar purchases from the same vendor, for
    two different awards. One award was incorrectly charged for
    both items. Error discovered by lab manager during monthly
    review of statements.

•   Wrong P-Card was inadvertently used to purchase the
    supplies. Error discovered during the monthly review by the
    business office.


                                                                  35
Examples of Bad JSA
Reasons & Descriptions
•   To transfer items that were incorrectly charged.

•   Per PI instructions, move charges to clear an overdraft.

•   Transfer YARC charges from Dr. X’s special use account to Dr.
    Y’s account for December to March 2004 and 2005.

•   Transfer airgas credit from Dr. X’s (Non-Federal) PTAEO to Dr.
    Y’s (Federal) PTAEO to close account.


                                                                36
Transferring non-labor costs.

Step 3. Check your work.
 A. Do you have all supporting paperwork (copy of
 the JSA, written explanation and authorization,
 copy of the original charge, description of allocation
 method if appropriate)?

 B. Is the description complete?


Step 4: Give transaction documentation
  to the approver.
                                                      37
Approving the Transfer

•   The preparer and approver of the transaction MUST
    be two different individuals.

•   The approver takes ownership of the entry and
    must review supporting documentation before
    approving the transfer.




                                                    38
Before Approving…
Step 5.
Review the Transfer
   Consider
            Is the charge allowable (check restrictions & the Notice of Award)?
            Is the cost reasonable and allocable to this award?
            Is the justification complete? Could a stranger understand what
             happened?
            Is the transfer being made to cover a cost overrun?
            Is the transfer being made in the last months of the award or after
             the award has expired?
            Is the amount being transferred a round number?
            Is the cost transfer being made more than 120 days after the
             original transaction or more than 90 days after discovery, whichever
             is earlier? If so, is the reason for lateness documented?
            Is the supporting documentation complete? Does the
             documentation stand alone? (Original transaction, explanation,
             authorization)

    If you do not feel comfortable about the answers to these
    questions, speak with your supervisor or GCFA.                              39
Filing the Transfer Documents
Step 6.
 Ensure all documents relating to the transaction are
 fastened together and filed with the award being
 charged. Put a note in the original award’s file,
 referencing the award to which the charge was
 transferred.

 All documentation related to the cost transfer,
 including but not limited to email, a copy of the
 original transaction, written explanation, and signed
 authorization must be retained according to Yale’s
 record retention policy and made available for
 verification during the course of an audit or other
 review.
                                                     40
Scenarios




            41
Examples of Cost
Transfers (Scenario 1)
•   A PI has not received a new award for a new competitive
    segment and the old award is about to expire. She/he does
    not want to stop the research, so the PI charge want to
    charge the old award for incurred costs that should be
    charged to the new award.

•   Are the costs allowable, allocable, reasonable & consistent?
•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?

                                                                     42
Examples of Cost
Transfers (Scenario 2)
•   A PI uses his/her P-Card to travel for research purposes. The
    expenses from the P-Card are charged to the departmental
    budget. PI returns from traveling and forgets to submit
    paperwork for travel expenses that are associated with
    research on a certain award until 6 months after the trip.
    Now PI wants to move charges to the correct award.

•   Are the costs allowable, allocable, reasonable & consistent?
•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?
                                                                     43
Examples of Cost
Transfers (Scenario 3)
•   Payroll charged relocation costs to the same account as
    salary. Relocation costs cannot be charged to the grant so we
    are transferring costs to a proper account. The transfer is
    late due to lack of administrative staff.



•   Are the costs allowable, allocable, reasonable & consistent?
•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?

                                                                     44
Examples of Cost
Transfers (Scenario 4)

•   Equipment was charged in error to PI’s American Heart
    Association award. Yale’s installment from AHA was late.
    Equipment charge was removed and replaced by an equal
    amount of supplies purchased by the PI from the stockroom.

•   Are the costs allowable, allocable, reasonable & consistent?
•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?


                                                                     45
 Transferring Labor Costs
THE PREPARER:

                         Step 1. Assemble information and
                evaluate the cost transfer.
                         Step 2. Make the labor distribution
                adjustment
                         Step 3. Check your work
                         Step 4. Give transaction documentation to
                the approver

THE APPROVER:

       Step 5. Review the Transfer
       Step 6. File the Transfer Documents

                                                                     46
Transferring Labor Costs
Step 1.
 A. Assemble the paperwork, including

    •   A record of the original charges (for example, a payroll
        or effort report);
    •   Original and new charging instructions (PTAEOs);
    •   A written authorization to make the transfer signed by
        the Principal Investigator or responsible institutional
        representative knowledgeable about the project (email
        or hand-written note is acceptable);
    •   A written explanation of why effort was reallocated or
        how the error occurred.

                                                               47
Transferring Labor Costs
Step 1 (continued).
B. Evaluate the cost transfer
         – Does the transaction fall within the award period,
           or is it allowable as a pre-award charge?
         – Is the charge allowable (check OMB A21 and
           restrictions in the Notice of Award)?
         – Is the cost reasonable?
         – Is the cost allocable to this award?
         – Is this cost being handled in a consistent manner?
         – Is the justification complete?
   If the answers to all these questions are “yes,”
      proceed to next set of questions. If any answer
      is “no,” contact your supervisor or GCFA.
                                                            48
Transferring Labor Costs
Step 1 (continued).
B.    Evaluate the cost transfer
          – Has the individual’s activity (effort report) for this period
            already been certified?
          – Is the transfer being made to cover a cost overrun?
          – Is the transfer being made in the last months of the
            award or after the award has expired?
          – Is the amount being transferred a round number?
     If the answers to any of these questions are “yes,” review
     with your supervisor or GCFA. Otherwise, proceed to the
     next question.

          – Is the cost transfer being made more than 120 days
            after the original transaction or more than 90 days after
            discovery, whichever is earlier?

      If the answer to this question is “yes,” you must provide
      a written explanation why it is late.                     49
Transferring Labor Costs
Step 2.
Make the Labor Distribution Adjustment (LDA)

A.   Enter the “Begin Date” and “End Date” of the Payroll period
     for which the adjustment is being made.

B.   In the “Comments” field, explain
        •   Why the effort was reallocated or how the error
            occurred,
        •   Who authorized the transfer, and
        •   If the transfer is more than 120 days after the
            original charge or more than 90 days from discovery,
            whichever is earlier, an explanation why the
            adjustment is being made late.
                                                               50
Transferring Labor Costs
Step 2 (continued).
•   Enter the justification for the labor cost transfer in
    the “Comments” field:




                                                             51
Transferring Labor Costs
Step 2 (continued).
•   Good Descriptions should state

    • How the error occurred / Why the LDA is needed
      (employee record entered in HR system too late to create
      labor schedule before first payroll was run)

    • How the error was found / Who initiated the LDA (noticed
      by Business Manager during payroll review).

    • Why the new PTAEO is correct (employee is research
      assistant on project)


                                                                 52
Good LDA Explanations

•   During the monthly review of Aug 05 grant statements, PI
    determined distribution of salary charges for Dale Spade
    should be reallocated to better reflect the actual time
    worked on the grant. Originally A11111 charged 25% but
    actual time was 20% due to extra time spent on A22222
    grant. Authorization from PI on file in the department.

•   Salary % charged to A12345 as reflected on the effort
    report was based on anticipated time for Jan-Jun 05 time
    period. Actual time allocation differed due to unexpected
    progress on D45678. LDA needed to adjust salary charges
    to reflect actual effort worked on grant. PI authorization on
    file in dept.

                                                                53
    Good LDA Explanations

•    Per PI authorization, redistribute salary of Matt Down
     to PI’s new NSF award D22222. PI discovered
     charging error during grant review. Documentation
     and authorization on file in dept.

•    During a review of Jane Doe’s effort report for Jan-
     Jun 05, PI discovered salary charges for Jan and Feb
     should have been charged to D22222 rather than
     D44444. The PI did not notice the error in charging
     during his review of the Jan and Feb grant
     statements. PI authorization on file in dept.

                                                        54
Good LDA Explanations


•   During the review of Dr. X’s effort report, PI
    realized change in charging instructions given to
    Business Office in Jan. were not completed. Error
    was not detected until review of Jul to Dec effort
    report. Authorization from PI on file in dept.




                                                     55
Transferring Labor Costs

Step 3: Check your work

A.   Do you have all supporting paperwork (copy of
     report showing original charge, written
     explanation and authorization)?
B.   Is the description complete?


Step 4: Give transaction documentation to
             the approver.

                                                     56
Approving Labor Cost Transfers


•   The preparer and approver of the transaction
    MUST be two different individuals.

•   The approver takes ownership of the entry and
    must review supporting documentation before
    approving the transfer.




                                                    57
Before Approving…
Step 5.
Review the Transfer
   Consider
            Is the charge allowable (check restrictions in the Notice of Award)?
            Is the cost reasonable and allocable to this award?
            Is the justification complete? Could a stranger understand what
             happened?
            Is the transfer being made to cover a cost overrun?
            Is the transfer being made in the last months of the award or after
             the award has expired?
            Is the amount being transferred a round number?
            Is the cost transfer being made more than 120 days after the
             original transaction or more than 90 days after discovery whichever
             is earlier? If so, is the reason for lateness documented?
            Is the supporting documentation complete? Does the
             documentation stand alone? (Original transaction, explanation,
             authorization)

    If you do not feel comfortable about the answers to these questions,
    speak with your supervisor or GCFA.                                58
Filing the Transfer Documents
Step 6.
•   Ensure all documents relating to the transaction are
    attached together and filed with the award being
    charged. Put a note in the original award’s file,
    referencing the award(s) to which the charge was
    transferred.

•   All documentation related to the cost transfer,
    including but not limited to email, a copy of the
    original transaction, written explanation, and signed
    authorization must be retained according to Yale’s
    record retention policy and made available for
    verification during the course of an audit or other
    review.
                                                        59
What if you are uncomfortable
with the transfer?
•   Speak with your supervisor or Business Manager.
•   Check with your business support service center.
•   If this does not resolve your concerns, speak with
    John Maloney or Lan Virasak in Grants and Contracts
    Financial Administration at 432-3060.
•   Refer to http://www.yale.edu/resources/ for more
    information.
•   Review the Standards of Business Conduct for
    guidance (http://www.yale.edu/provost/html/standards.html ).


                                                             60
Monitoring by GCFA

1.   GCFA monitors sponsored program cost transfers
     over $100.00 for compliance with sponsor
     requirements and university policies & procedures.

     • JSA Descriptions are reviewed.
     • Labor Distribution Adjustment Descriptions are reviewed.

        When descriptions are insufficient, departments are
        required to email complete descriptions to GCFA, print a
        copy of the email and staple it to the transaction
        documentation, and retain it in the award file.




                                                                   61
 Monitoring by GCFA
 continued…

2.   GCFA reviews documentation of all sponsored
     program cost transfer lines greater than $10,000 and
     a random sample of all other cost transfers to ensure
     supporting documentation is adequate.

     Departments will be provided feedback including…

          •   Requests for improving documentation on individual
              transactions
          •   Retraining for individuals who do not adequately justify and
              document cost transfers.

                                                                             62
Monitoring: The Bottom Line

•   If the transfer explanation and
    documentation is incomplete or
    unacceptable, GCFA will notify the
    department and require the cost transfer be
    reversed.
•   Access to prepare and approve cost
    transfers will be terminated if repeated
    incomplete or unacceptable transfers are
    identified.
                                              63
Scenarios




            64
Examples of Cost
Transfers (Scenario 5)
•   A PI doesn’t want to stop doing research but has not received
    a new award for a new competitive segment and the old
    award is about to expire. She/he is charging salary to the
    departmental General Appropriation budget.



•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?




                                                                     65
Examples of Cost
Transfers (Scenario 6)
•   PI’s research assistant is working on various grants. Incorrect
    amount of effort was charged to one particular grant. PI
    reviews labor charges after the fact.


•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?




                                                                     66
Examples of Cost
Transfers (Scenario 7)
•   Student wages were charged to faculty setup funds and
    portion of effort should be charged to faculty’s research
    award: PI found error upon review of his accounts.



•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?




                                                                     67
Examples of Cost
Transfers (Scenario 8)
•   On review of award expenses for the first half of
    the annual installment, PI decides to shift labor
    costs to another closely related project. Effort has
    already been certified.



•   Explain the issues raised in this scenario.
•   Is this situation an appropriate justification for a cost transfer?
•   What should you do?


                                                                     68
If you need assistance
with cost transfers
•   Contact John.Maloney@yale.edu or
    Lan.Virasak@yale.edu in GCFA or call 432-3060.

•   At the Yale School of Medicine, contact
    Mark.Prendergast@yale.edu in Financial
    Operations.




                                                     69
Questions & Answers




                      70