Cost Transfers

Cost Transfers on Sponsored Awards

All sponsored award expenditures should be charged to the correct sponsored project at the time they are incurred. However, errors may occasionally occur. When an incorrect charge affects a sponsored project, the correction must be made in a timely manner and must include sufficient standalone justification to establish a clear audit trail back to the original posting.

Cost transfers must be allowable, allocable, reasonable, and consistent with Penn State policy and sponsor’s terms and regulations. Transfers made for reasons of convenience, such as covering overruns, avoiding sponsor restrictions, or spending down unobligated balances, are not allowable. Transfers lacking adequate documentation will not be processed and may result in the removal of charges from the sponsored award to ensure compliance.

Cost transfers that impact sponsored awards include costs being reallocated off-of, on-to, or in-between sponsored awards, which include associated cost share, salary cap, and program income Internal Orders (IOs).

A personnel cost transfer is the reallocation of salary, fringe benefit, or tuition expenses between sponsored awards, IOs, or other institutional accounts. These are typically processed via Labor Distribution plan and occasionally through journal entries (locked plans for previous fiscal, system limitations, etc).

There are two categories of Labor Cost Transfers (also referred to as Labor Adjustments): Realignment of Budget Estimates and Labor Transfers. Policy RA67 Cost Transfers

Realignment of Estimate​

  • Estimate realignments may occur frequently and are a normal, expected operational activity, as the initial labor distribution is established using the Plan Confirmation method which means effort is allocated in advance and can be adjusted afterward to reflect actual effort.
  • Must be completed within three (3) months of the month in which the pay period was paid when an estimate revision is needed.
  • Revisions for current and future pay periods for employees paid on the salary clearing cost center may be made at any time through the labor distribution plan ONLY

Labor Transfer

  • Adjustments that are requested more than three (3) months after the pay period in which the labor was paid. ​
  • Given that a timely review of salary charges is expected, labor transfers should occur infrequently.​
  1. An explanation of why the expense was charged to the wrong cost collector
    • Initiators must explain the “what happened” in answering this question. It is not enough to say, “correcting an error” or “to transfer cost to correct grant.” For instance, if there was miscommunication or a delay in setting up the award, this must be described.
  2. An explanation of why the expense should be allocated to a different cost collector
    • Initiators must explain how the expense will benefit the grant to which it is being transferred. If a cost is being reallocated off a grant and onto a non-sponsored award, it is acceptable to state that a cost was deemed unallowable after-the-fact or the award is overspent and therefore costs had to be removed from the grant.
  3. A description of the actions taken to diminish the likelihood of such errors occurring in the future
    • Initiators must describe what steps they will take to reduce cost transfers in the future. While there will always be some cost transfers, they should be considered exceptional, not the norm. Initiators may have to monitor budgets more regularly or review cost allowability standards, rules, or regulations more often in the future.

Why Compliance Matters
Proper documentation and timely processing of cost transfers are critical to maintaining Penn State’s integrity, accountability, and eligibility for future sponsored funding. Cost transfers are among the most closely scrutinized transactions in federal and institutional audits because they often occur after the original expense has been posted, making them inherently higher risk. When cost transfers are untimely, unsupported, or poorly justified, they raise red flags for auditors and sponsors. Failure to comply can lead to audit findings and repayment of disallowed costs, potential liability under the False Claims Act, and damage to Penn State’s reputation and sponsor confidence.

A non-personnel cost transfer is the reallocation of non-personnel costs such as supplies, travel or equipment. These are processed in SIMBA using the Grant Non-Personnel Cost Transfer Tile to capture the justification for the cost transfer, followed by a journal entry.

Grant Non-Personnel Cost Transfer Tile
Non-personnel cost transfers must be processed via SIMBA using the Grant Non-Personnel Cost Transfer Tile. This is an important compliance tool used to record and justify the transfer of non-personnel expenses onto or off sponsored programs. This process ensures that all expense adjustments on sponsored awards comply with University policy, sponsor requirements, and Uniform Guidance (2 CFR §200).

Purpose of the Tile
The tile captures key information to document why a cost transfer is necessary, how the expense benefits the new funding source, and what actions will be taken to prevent future errors. Using the tile promotes consistency, accuracy, and transparency across all sponsored award transactions.

When to Use the Tile
Use the tile to transfer any non-personnel expense on or off a sponsored program, such as:

  • Correcting travel or supply expenses charged to the wrong award
  • Moving expenses between grant years (e.g., Year 1 to Year 2)
  • Splitting shared costs (e.g., lab supplies or equipment)
  • Adjusting internal or external billing errors (expense-to-expense corrections)

When Not to Use the Tile
Do not use the tile for:

  • Personnel or salary expenses (handled via payroll adjustments or EC process)
  • Central billing (e.g., OPP, Fleet, IT)
  • Research Accounting or SIMBA corrections
  • Initial billing entries (credit to revenue/debit to expense)
  • Service center charges (Funds 113–116)
  • ARL transactions

Justification Requirements
Each transfer must include detailed, audit-ready explanations for:

  1. Why the expense was charged to the wrong cost collector.
  2. Why the expense should be allocated to a different cost collector.
  3. Actions taken to prevent recurrence.
  4. (If partial transfer) Basis or methodology for the transferred amount.

Unacceptable Reasons for Transfers

  • Spending down remaining balances
  • Shifting overruns between awards
  • Avoiding sponsor restrictions
  • Moving unrelated expenses for convenience

Why Compliance Matters
Proper documentation and timely processing of cost transfers are critical to maintaining Penn State’s integrity, accountability, and eligibility for future sponsored funding. Cost transfers are among the most closely scrutinized transactions in federal and institutional audits because they often occur after the original expense has been posted, making them inherently higher risk. When cost transfers are untimely, unsupported, or poorly justified, they raise red flags for auditors and sponsors. Failure to comply can lead to audit findings and repayment of disallowed costs, potential liability under the False Claims Act, and damage to Penn State’s reputation and sponsor confidence.