Ninety (90) days has emerged as the standard used by government and business auditors to determine whether costs are reasonably assigned to their proper project and function. It is a standard established in federal circulars and grant policy.

Standard practice should be to post costs to the most appropriate project/grant. However, subsequent adjustments may be necessary, for example to account for unforeseen shifts of personnel between closely related sponsored projects, or to correct errors. These actions are reasonable if transferred within 90 days.

The 90 days begins at the end of the month in which the expense is posted.

For example, if a travel expense is posted September 15, the 90-day period begins September 30. Transfers initiated by December 31 would fall within the 90-day period. Transfers initiated after that date would be considered late cost transfers and require the additional justification. The transfer justification questions will automatically display in the Documentation tab. A transfer cannot be processed until all required responses are provided.

No, the 90-day standard is being applied only to sources of extramurally sponsored projects that are in fund 144 and sponsored projects in fund 133. Although this standard is not a requirement for other funds or gift accounts in fund 233, it should be considered useful guidance. It is important for the University as a whole to record its costs (and associated revenues) in a timely fashion. The accuracy and auditability of its records are improved when postings and corrections are made in a timely manner.

No, this standard is only applicable to all extramurally sponsored University projects and activities in fund 144 (Federal) and fund 133 (Non-Federal). If you have projects managed in other fund sources (101, 135, 136, etc), the 90 day-standard is not a requirement. It should be considered useful guidance.

Yes, this standard is applicable to salary expenditures. It is especially important that, to the extent possible, payroll expenditures are budgeted and recorded on the proper Project ID at the time of their occurrence.

Generally not. The intended use of effort reports is not as a check of where salary charges are made. Salary distributions should be reviewed on a regular basis so the effort reports are a reasonable reflection of the employee’s paid effort when first generated. There may be situations where changes are needed to the effort reported and the corresponding salary transfer is needed. The transfer may be appropriate, but because it is beyond 90 days the transfer would also need to meet the extenuating circumstances.

The College/School Dean’s Office can assist in establishing an Advance Award (requested in RAMP). It is not appropriate to use a generic discretionary account and move expenses to the funded award beyond 90 days.

Although rare, this circumstance can occur and may be an acceptable circumstance for a late transfer justification. The University cannot pay for services for which it has not been invoiced. Vendors should be contacted immediately and urged to submit outstanding invoices or risk the possibility of non-collection due to lapsing funds. If a vendor invoices later than 90 days after the provision of services, the University will pay upon receipt and note for the record that the invoice was late.

The dispute should be clearly documented between the program and the vendor. The University has an obligation to notify vendors in a timely manner if goods and services are not satisfactory and to timely pursue resolution of outstanding issues. Delays due to the normal course of other business intervening, change in personnel or other departmentally based factors are not acceptable reasons for delaying posting of expenditures.

Generally, Federal projects (Fund 144) should not be used as the default project ID for P-cards, MDS, or other service center costs. Discretionary funds should be used for default funding and then the charges moved to Federal projects using appropriate methods.

However, whenever possible costs should be charged to the appropriate sponsored project when first incurred.

Research and Sponsored Programs strongly recommends that all P-card purchases be allocated appropriately to the correct project ID during the biweekly P-card edit period. Cost transfers within 90 days of the transaction date would be allowable for missed biweekly P-card account rollups with proper justification.

It is the University of Wisconsin-Madison policy that costs be charged to the appropriate sponsored project when first incurred. Unless there are extenuating circumstances clearly explained in the cost transfer justification, a second transfer on a 144 transaction is unallowable. At no time should sponsored projects be used as back-up projects or as discretionary projects for expenses that will subsequently be transferred elsewhere.

Generic statements are not generally acceptable on extramural support cost transfers. For all charges on a project, you should be able to explain the allowability of those costs. As general guidance, acceptable justifications should be able to address the following:

1. An explanation as to why the expense was originally charged to coding from which it is now being transferred.
2. An explanation as to why the charge needs to be transferred to the proposed receiving project.
3. An explanation as to why the charge is allowable and allocable based on the terms and the conditions of the receiving award.

For cost transfers after 90 days of the accounting date, the justification must include the items above as well as two additional items:

4. Why the cost is being transferred more than 90 days after the accounting date.
5. What corrective action has been taken to eliminate the need for cost transfers of this type in the future at the departmental level.

If the cost transfer does not meet the standards for allowability, allocability and reasonableness, it will not be approved.

Staff shortages or lack of staff experience are unallowable circumstances for late cost transfers. Auditors typically view this explanation as a sign that the department does not provide adequate monitoring or maintain sufficient internal control over the use of extramural funds. The College/School and the PI have a responsibility to ensure the availability of qualified staff to administer and exercise stewardship over sponsored projects in accordance with the sponsor’s policies and regulations, including those relating to regular monitoring of expenditures and timely correction of errors and reallocation of expenses.

A five-month contract negotiation would be considered an allowable extenuating circumstance. The five-month salary transfer should be submitted as soon as the PI knows the new project ID. Supporting documentation/justification is required with the transfer. To avoid this extenuating circumstance, Research and Sponsored Programs recommends that an Advance Award be established, which is done at the request of the Principal Investigator or designee.

Yes. While no one likes to point fingers or blame others for mistakes, it is important to explain the reason for the transfer. Areas that consistently make errors need additional attention and training to help them understand the complications they create. Over the long-term, campus will be working with these units to improve their operations so fewer errors, and corresponding transfers, occur.