Cost Transfers which occur after 120 days (four general ledger cycles) from the original ledger month end date are considered excessively late. Transfers made after the 120 day period may be considered non-compliant with University policy and therefore deemed unallowable by federal auditors.

Departments must assume the risk for these transfers if found unallowable during an audit. The escalation process will be used strictly for rare and unusual circumstances. In these circumstances, the request will be evaluated based on set criteria and approved by: Principal Investigator, Department Head/Chair, Extramural Funds Accounting Manager, Controller, and Vice Chancellor of Research. Departments must correct any inappropriately recorded charges on federal funds regardless of timeliness.

 

Late Cost Transfer Escalation Procedure

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Criteria

Approval of requests for late cost transfers to a Federal or Federal-Flow-Through fund source will be rare and only granted in unusual and unique circumstances that result from actions outside the control of the originating department. If granted, this approval does not relieve the originating department from the financial responsibility for the untimely recognition of these expenses. If disallowed by the federal agency, the originating department will be held responsible for any disallowance, fine, or penalty resulting from negative audit findings relating to any cost transfers processed as a result of an escalation request.

In general, the following situation will be considered for an escalation:

  • Cost transfers resulting from late notification of award by the sponsor when a Request for Approval to Spend Funds (RAS) would not have been possible. A RAS should be used whenever possible.

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Escalation Procedure

To request an escalation to transfer to a Federal or Federal Flow-Through award after the 120 day (4 ledger cycle) period has passed, the originating department must complete the follow 3 steps:

  1. The originating department preparing the Escalation Memo form is responsible to have it signed by the form Preparer, Principal Investigator, and Department Head/Chair (must go through approval process indicated in Sequential Order Section).  Download the Escalation Memo
  2. For Non-payroll transfers the originating department completes the UFIN form. Download the UFIN form. The TOE system will not process any transfer past 120 days, so any non-payroll cost transfer must be done on a UFIN. For Payroll transfers...

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Sequential Order for Escalation Signature Form

All 120 Day Escalation Forms must be submitted in sequential order as indicated below (Steps 1-4). If the form is submitted out of sequence it will be returned to the originating department and denied. Resubmission will be required for consideration.

  1. Originating department prepares the Escalation Memo and obtains all necessary signatures, which include the form Preparer, Principal Investigator, and Department Head/Chair.
  2. Submit the 120 Day Escalation Form (along with relevant UFIN or Direct Retro) to the Extramural Funds Accounting Manager for review. If approved the escalation form will be routed to the Controller for review and approves or denies escalation requests. The Extramural Funds Accounting Manager is responsible for processing escalation requests which includes tracking the request, communicating the decision on the request, and processing cost transfers for approved requests.
  3. The Controller or designee reviews and approves or denies escalation requests prior to routing to the Vice Chancellor of Research.
  4. Vice Chancellor of Research reviews and endorses or denies escalation requests. The decision of the Vice Chancellor or designee is final.

Online Transfer of Expenses (TOE) Over 120 Days Due to Approval Process

If you have submitted a transfer of expense in the on-line TOE system, but it has been delayed in the approval process forcing the processing period past the 120 policy, use the following steps to complete the TOE:

  1. Do not submit the TOE electronically, it will be rejected.
  2. Access the original TOE submitted in the online system and print a copy which will reflect the audit trail.
  3. Prepare a paper UFIN120 and attach a copy of the TOE transfer.
  4. Submit the paper copy of the TOE to Extramural Fund Accounting for approval.

Note: If the original submission of a TOE is past the required 120 day time period, it is considered excessively delinquent and will NOW need to be escalated for review. Please refer to the procedures as noted in the Cost Transfer 120 Day Escalation Procedures section.