|Enforcement official||Associate Vice President for Research|
|Classification||Board of Trustees-delegated Policy|
|Category||17. Research and Intellectual Property|
Statement of policy
The purpose of this policy is to comply with 2 CFR 200 Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and federal agency policies and procedures for federally funded projects.
Summary of contents/major changes
Move policy to template. Technical changes.
1. Purpose of Policy
The purpose of this policy is to comply with 2 CFR 200 Office of Management and Budget (OMB) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”) and federal agency policies for federally funded projects.
2. Stakeholders Most Impacted by the Policy
This policy applies to all Principle Investigator(s) (PI) engaged in research, projects, or activities conducted under the auspices of Western Michigan University whether the activities are conducted on or off campus.
3. Key Definitions
3.1 Cost Transfer: a journal entry transferring an expense to a grant project that was previously charged and recorded in another account on the general ledger; could apply to grants or non-grants.
4. Full Policy Details
Cost transfers of charges to a grant project must be explained and justified with a written explanation and approval.
4.1. Cost Transfer Allowability. In order to transfer costs to a sponsored project, the cost must meet the criteria in 2 CFR 200.
4.2. Cost transfers, excluding payroll expenses, should be made within 90 days of the end of the month in which charges were initially posted.
4.3. All transfers are subject to prior approval by the Grants and Contracts Department.
4.4. Documentation for transfers must be maintained within the department for three years after the completion of the entire project. If the project has been selected for audit, all documentation must be maintained until after the final audit response is issued, plus three years.
5.1. The responsibility for compliance with University, Federal, and agency regulations and guidelines and for maintaining supporting documentation for transfers/adjustments resides in the originating department/unit. Deans, Directors and Chairs. Those who have authority to approve adjustments are also responsible and accountable for compliance with University and agency regulations.
5.2. Cost transfers are almost always reviewed when an account, department or university is audited. The burden of proof regarding allowability is on the department.
5.3. Any audit-derived disallowed cost will be borne by the department(s) that initiated them.
5.4. Additional consequences for non-compliance include possible individual discipline for failure to follow applicable University policies and requirements.
6. Related Procedures and Guidelines
7. Additional Information
|Effective date of current version||October 1, 2019|
|Date first adopted||November 3, 2003|
|Proposed date of next review||October 1, 2022|
|Certified by|| |
Director of Grants and Contracts, Office of Research and Innovation
|At the direction of|| |
Vice President for Research