Printed on: 12/05/2024. Please go to policy.umn.edu for the most current version of the document.
University of Minnesota  FAQ

Frequently Asked Questions for Late Cost Transfers

Sidebar

Expand all

Sidebar

Table of Contents

TOC placeholder

Questions?

Please use the contact section in the governing policy.

Leave Feedback
  1. Why do I need central approval to process a late cost transfer?
    1. Late cost transfers signify that timely reviews of expenditures on sponsored projects are not occuring or that the results of the reviews are not being used to remedy any inadvertent errors that may have taken place. Federal regulations (used by the University as guidance for all sponsored funding) allow for awards to be initially established based on approved budgets, but with the explicit understanding that there are sufficient internal controls in place to verify that expenses charged (and billed) are reasonable, allocable and allowable, and that there is a comparison of expenditures with budgeting amounts (2 CFR 200.302). The period of 90 days allows sufficient time for monthly or even bi-monthly reviews and initiation of corrective action.
  2. How is the 90 day threshold calculated for retro distributions?
    1. The 90 day threshold is calculated based on when the payroll charges are recorded, which corresponds to the pay date. For example, the first pay period for FY25 is June 17, 2024 to June 30, 2024, with a pay date of July 10, 2024. The charges will be recorded on July 10, 2024 and retros can be processed until 90 days later on October 8, 2024 without the need for an exception. 
  3. What is the standard turnaround time for a project to be set up from the time of the request?
    1. There is no standard turnaround time at present, because setup is heavily dependent on concurrent activities - primarily major proposal deadlines occurring at the same time. However, for pre-award accounts, SPA’s goal is to set these up within one week of receipt of a fully approved and complete request. With MN-GEMS, it is expected that regular (full) award setup will be more rapid than in the past. SPA expects to set and publish expected turnaround times in the coming months after all parties are familiar with the system and some data averages can be calculated.
  4. When should a preaward be requested?
    1. Any time a department is concerned about the timing of an award being set up, a preaward should be requested if such spending is allowable. If a preaward account is not requested, costs should not be incurred until a NOGA is issued. If the department/PI knows the award has arrived but a NOGA hasn’t been issued, they should contact their SPA GCO to confirm when the NOGA will be issued. If they are not confident that a NOGA will arrive to allow for costs to be recorded within 90 days, they should request a preaward at that time.
  5. How long should it take for my late cost transfer exception request to be reviewed?
    1. Every effort will be made to ensure that exceptions will be reviewed within two weeks of receipt.
  6. What are some examples of extenuating circumstances?
    1. Awards from the State of Minnesota typically do not allow spending to begin until all signatures are complete. However, on occasion, units will begin spending with the expectation to cover expenses with other funds. If preaward spending is ultimately allowed on the final award, this would be considered an extenuating circumstance and a timely request (e.g, 1-2 months of the NOGA) for retroactively moving those expenses onto the State award would be considered.
    2. When an award is expected to be extended, units may continue to spend on the same project. However, when the extension is provided, the sponsor may provide updated information requiring a new project. If this occurs, it would be considered an extenuating circumstance.
    3. The PI is unavailable for financial review or approval of a cost transfer for an extended period due to medical or other reasons beyond their control.
    4. A sponsor fails to respond within 30 days to our timely request for a no-cost extension.
    5. Sponsor or pass-through entity fails to timely transfer an award to us after all paperwork was submitted by the University of Minnesota and the relinquishing institution.
    6. A sponsor or pass-through entity issued a continuation award or subaward that unexpectedly required a new award number (CON#).
    7. SPA set up of a preaward or new award was delayed by more than 60 days after the preaward account request was received or the award was accepted by the University.
    8. Preaward or advance account was not requested because preaward/advance spending is typically not allowed by the sponsor but the award ultimately allowed such spending.
  7. What do I do if my late cost transfer exception request is denied?
    1. The exception request is the final appeal process. While each transaction is reviewed on its own merits, exceptions are only granted for extenuating circumstances. If the exception request is denied, the cost transfer should be deleted and departments should work with their financial leadership to determine how to handle any related budget implications.
  8. Pre award account requests - if multiple chart strings are needed, please use the guidance found on the MN-GEMS website to process your request. 
  9. How do I get central approval for a nonpayroll late cost transfer?
    1. The Late Cost Transfer Exception Request form should be completed and attached as backup documentation to the journal entry. If the journal entry is greater than $50,000, it will route to Accounting Services for review.