As proven by Yale University’s recent $7.6 million settlement, cost transfers can have a devastating effect on an institution.  Beyond the initial cost of fines and settlements, the University’s ability to obtain future funding is negatively impacted along with its reputation.

University policy states that costs transferred to a sponsored project must be allocable, allowable and reasonable for the project and that errors must be corrected within 90 days of discovery, all of which must be documented.

Auditors recognize that cost transfers are necessary.  However, frequent, late, and poorly explained cost transfers raise questions about the appropriateness of expenditures and the effectiveness of the University’s internal controls.

Steps to reduce cost transfers:

• Follow the guidelines for Pre-award spending (if allowed by sponsor) to reduce the need to transfer expenses at a later date
• Routine project review to ensure appropriateness of costs charged
• Ensure personnel are trained and familiar with University policies and procedures regarding cost transfers

The key to successfully completing a cost transfer is to provide sufficient back up documentation explaining how the expense is allocable, allowable and reasonable for the receiving project and how the error will be prevented in the future.

Remember: Cost transfers cannot be used as a money management tool which includes transferring to or from a project for the sole purpose of spending down the funds or transferring costs between sponsored projects to remove a deficit balance.

Please contact SPFM for more information at rafm@llu.edu or 909-558-4589.

Helpful Links & Tools

• Information on Cost Transfers in the LLU Grants Guide
• LLUAHSC policy & procedure (H-5):  Cost Transfers on Sponsored Projects.
• Cost Transfer form

Those required to register a clinical trial with clinicaltrials.gov must also update the website every six months and upload results when the study is concluded. Starting March 2, 2012 the informed consent for new clinical trials may be required to include specific language about clinicaltrials.gov.

For more information, contact Research Integrity. 

The U.S. Department of Health and Human Services recently determined that a research project conducted by UCSD’s Antiviral Research Center violated the privacy and confidentiality rights of an unspecified number of human research subjects taking part in an HIV infection study.  The government’s investigation of a research subject’s privacy complaint revealed that the use of names and birthdates on lab specimens, common during the study, had violated federal laws. The practice also circumvented a confidentiality rule mandated by the university’s own institutional review board, which is supposed to monitor research projects involving human subjects.

For more details, see http://www.sandiegoreader.com/news/2011/jun/01/radar-HIV-UCSD-privacy/.