1. Policy
Issued: 11/4/2025
Last Revised: New
Last Reviewed: New
Applies to: Faculty (including part-time and visiting faculty), postdoctoral scholars, staff and students (including graduate/undergraduate student workers and graduate assistants) employed by University of Southern California and its subsidiaries including Keck Medicine of USC (“USC employees”). This policy continues to apply to individuals on sabbatical, other leaves or while visiting other institutions.
2. Policy Purpose
USC is committed to ensuring responsible expenditure of sponsored research funds in a manner that complies with applicable federal regulations, including those that require all grant charges to be allowable, allocable, consistent, reasonable, and timely. Cost transfers (also known as expense transfers) are designed to correct expenses related to sponsored activities initially charged erroneously. When requested in a timely fashion, the expenses may be reallocated to other funding sources. All cost transfers must adhere to this policy and any related procedures issued by the university.
This policy reflects the requirements of the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR Part 200, otherwise referred to as the Uniform Guidance (UG). It is important to verify the applicable regulations for an individual award, which may be found in the Award Notice issued by the funding agency. This policy may be updated as necessary based on revisions to the Uniform Guidance and/or sponsor-specific or other governmental mandates and expectations.
3. Scope
This policy applies to all sponsored projects unless specifically addressed in a non-federal sponsor’s policies, procedures, or award.
4. Definitions
| Term | Definition |
|---|---|
| Cost transfer | A cost transfer is an after-the-fact reallocation of the cost associated with a transaction from and/or to a sponsored project or within a single sponsored project from one type of cost to another. To be allowable, cost transfers must be timely, fully documented, conform to university and sponsor allowability standards (that is, allowable under the terms of the sponsored agreement), and be appropriately authorized. There are two types of expenditures that may give rise to the need for a cost transfer, salary and non-salary. |
| Salary expense transfers | A salary expense transfer entails a reallocation of salary expenses from and/or to a sponsored project |
| Non-salary cost transfers | Cost transfers to a sponsored project made after the charge is posted must be accompanied by appropriate transfer documentation. |
5. Policy Details
Permitted cost transfers
Typically, cost transfers are appropriate when the transfer will result in a more accurate accounting of costs, and the resulting charges are in compliance with all applicable standards and directives. Their purpose is to:
- Correct errors in processing the original charges
- Move costs between funds for closely related work as defined by the project scope that is supported by more than one funding source
- Reallocate shared purchases/services
- Transfer pre-award costs in accordance with provisions of applicable federal regulations
- Incur pre-award costs 90 calendar days prior to award or more than 90 calendar days with prior approval of the Federal awarding agency.
Any salary cost transfer on a sponsored project must be accompanied by appropriate written documentation that provides justification explaining how the error occurred as well as a certification that the new charge is correct. The written documentation must be maintained by the department and must be available for audit or review upon request, subject to the university’s Record Retention policy.
Documentation for non-salary costs must include:
- A description of each specific expense being transferred, including why and when the original cost(s) were incurred
- An explanation as to why the sponsored project to which the transfer is being made was not originally charged; and
- An explanation of why it is appropriate to now charge that sponsored project.
If you are unclear whether the cost transfer you would like to effectuate is permitted, please consult with the Office of Financial Analysis (OFA).
Prohibited cost transfers
Typically, cost transfers are inappropriate in the following circumstances:
- Transfers solely for the purpose of utilizing an unexpended balance
- Transfers for the purpose of avoiding a cost overrun by charging another, unrelated sponsored project
- Transfers that circumvent pre- and/or post-award restrictions
- Transfers to avoid restrictions imposed by law or by the terms of the sponsored agreement
- Transfers of expenses related to activities sponsored by industry, foreign governments, or other non-federal sponsors to federally sponsored agreements:
- Transfers where an effort certification period is now closed and the effort document does not provide evidence of future activities as required by the effort certification policy.
- Other transfers for reasons of convenience.
Exceptions
In rare cases, there may be compelling circumstances where exceptions to this policy are warranted. All cost transfer exception requests will be reviewed on a case-by-case basis and must include a detailed justification (including any pertinent backup of information (e.g., emails, related documents) to assist the reviewer in evaluating the request.
All exception requests must be in writing, signed by the school’s Director of Research Administration, Financial Dean, or equivalent position, and submitted to the Office of Financial Analysis (OFA) for review and approval. Exception requests should also describe any steps that have been taken to minimize the likelihood of future recurrence.
Timing
Cost transfers must be completed as soon as possible after the mistaken expense is initially charged, but no later than within 90 days (or less, depending on the agreement with the sponsor) of the discovery of the error and no later than 15 days after budget termination. Failure to sufficiently establish that the expense to be transferred is allowable, allocable, and reasonable may delay the timeliness of invoices and expenditures reports, impeding reimbursement and jeopardizing future sponsored project funding.
For erroneous costs initially discovered 90 days after the occurrence of the charge, the requesting party must establish the reasonableness of the request and address why it was not discovered earlier. Reasonableness will be assessed using the following criteria:
- Whether the expense could or should have been discovered closer in time to the occurrence
- The general measures implemented by the requesting unit to detect erroneous charges in a timely way.
- The frequency with which cost transfers have been requested by the researcher and/or unit greater than 90 days from their occurrence.
- Whether the cost transfer entails the transfer of an expense to an account with significantly more available unobligated funds.
Individuals must address reasonableness by providing the following information:
- Explain why the expense was not discovered sooner.
- Describe measures in place to prevent similar occurrences.
- Address patterns or recurring issues with late transfers.
- Justify transfers to sponsored awards with unused funds.
If it is determined that a request for a cost transfer is not timely or otherwise ineligible for transfer to another sponsored account, the erroneous expense still must be transferred off the award, but it must be transferred to a non-sponsored account (e.g., discretionary or gift account).
6. Procedures
N/A
7. Forms
N/A
8. Responsibilities
| POSITION or OFFICE | |
|---|---|
| Principal Investigators (PI’s) | PI’s assume primary responsibility for ensuring compliance with applicable terms and conditions related to the expenditure of grant funds, including monitoring of expenditures, timely correction of errors, and proper allocation of expenses, regardless of source of funds.  |
| Grant Managers and Departmental Administrators | Assist PIs in the timely review and reconciliation of expenditures Prepare and ensure timely submission of cost transfer requests Maintain adequate documentation of costs Ensure that all personnel engaged in the financial administration of federally sponsored awards are familiar with this policy Ensure that the costs transferred are allocable, allowable, and reasonable |
| Authorized approvers | Payroll Cost Transfers (PAA) Department approver (could be multiple within their department/school) Financial Aid (if related to financial aid transactions) OFA (if related to overload pay) SPA Non-payroll Cost Transfers Department approver (could be multiple within their department/school) SPA Comptroller’s Office |
| Office of Financial Analysis (OFA) | OFA is responsible for: Addressing questions regarding the policy and/or its application to specific cost transfer requests Review and approval of overload pay Review of payroll cost transfers required as a byproduct of necessary changes to previously certified effort Exception requests, both salary and non-salary |
| Sponsored Projects Accounting (SPA) | SPA is responsible for: Maintaining this policy and accompanying procedures Review and approve/deny cost transfer submitted by department/school If a cost transfer into a grant Driver Worktag is denied, SPA will redirect it to the designated non-grant Driver Worktag (gift, project, or program) Ensure timely processing of the cost transfer and that the cost is included in any sponsored required invoicing/drawdown, and/or financial reporting |
9. Related Information
Sponsored Projects Accounting
Office of Financial Analysis
10. Contacts
Please direct any questions regarding this policy to:
| OFFICE | PHONE | |
|---|---|---|
| Office of Financial Analysis (OFA) | 213-821-1937 | ofa@usc.edu |
| Sponsored Project Accounting (SPA) | 213-740-5381 | spaacct@usc.edu |