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.

Transfers with the following situations that do not fall under the escalation requirement:

  • Cost transfers between Accounts (as long as award # is the same) and Subs within the same Fund.
  • Cost transfer correcting Object Codes within the same Fund.
  • Transfers from a Fund to a NON-Federal Fund source will be processed even after the 120 day limitation. The reason for the excessive tardiness should be documented, but an Escalation Memo is not required for transfers to a Non-Federal fund source.
  • Cost transfers resulting from an unanticipated change to the Fund number on a multiple year award. In this case, an Escalation Memo would not be required in order to help reduce the administrative burden of already having to perform numerous cost transfers if a fund number change was necessary during the mid-life of the award.
  • Transfers labeled as High Risk in the UCPath system because they are beyond 90 days from the End Date of the award are not subject to the Escalation procedures required for transfers over 120 days. These transfers will be evaluated on a case-by-case basis by the EMF Manager.

Escalations will not be granted in the following situations:

  • Failure of staff to prepare cost transfers in a timely manner.  A department being short-staffed is not a valid reason to grant exception to UC policy.
  • Failure of Principal Investigators to timely inform department administration of needed cost transfers.

As part of normal departmental responsibilities, Principal Investigators and departments are responsible for actively managing awards, which includes reconciling their awards on a monthly basis, identifying transactions that require correction, executing required cost transfers in a timely manner, and assembling the late cost transfer escalation request when necessary. Questions about this process can be addressed to Tyler Clark, Extramural Fund Manager at or call extension 3068.