Grant Management Policies

Definition

A cost transfer is the reassignment of an expense to a sponsored project after the charge was initially charged to another sponsored or non-sponsored project or department. Cost transfers include reassignments of salary, wage and other direct costs.

Restrictions on Cost Transfers

All charges to projects must be:

• Allowable (the cost is allowed by federal regulations, sponsor terms and conditions, including program specific requirements)
• Reasonable (this reflects whether the individual acted with due prudence)
• Allocable (the cost has a direct benefit to the account being charged)
• Treated consistently (like costs in similar instances are treated consistently throughout the university)

Transfers of costs to the project are allowable only where there is a direct benefit to the project being charged. Overdrafts of direct cost items incurred in the conduct of a sponsored project may not be transferred to another sponsored project to resolve a deficit. Cost transfers may not be used as a means of managing awards.

Timing of Transfers

Any cost transfer must be prepared on a timely basis but no later than 90 days form the end of the month in which the transaction appears on the project (except where the sponsor's terms and conditions are stricter than stated here). To meet financial reporting requirements, at year end all entries must be posted to projects by the statutory close.

Compliance

The university expects that costs directly charge to federally sponsored awards be compliant with the cost principles outlined in the Uniform Guidance, Subpart E–Cost Principles, §200.400-§200.476.

Procedure

All cost transfers should contain an explanation as to why the cost transfer is necessary. The explanation must fully explain how the error occurred along with sufficient documentation and justification that would stand the test of a formal audit.

All cost transfers are completed via journal entry by authorized grant personnel. Once cost are posted by TU financial services, grants administrators will review and confirm the transaction.

To initiate a cost transfer, please contact your grant administrator.

Definition

A deficit is the amount by which expenditures exceed a sponsored agreement, budget allocation or revenue collected from a sponsor.

Purpose

The purpose of this statement is to set procedures to ensure timely resolution of deficits on completed sponsored agreements.

Procedure

OSPR will work with the Department to reconcile deficits. Ordinarily, the Department is expected to cover the deficit.

In the event a deficit is the result from non-payment by the sponsor, OSPR will notify the department. After all efforts to collect the funds have been exhausted, OSPR will work directly with the department to reconcile the balance.

All financial records, supporting documents, statistical records and other records pertinent to an award shall be retained for five years from the date the project is closed.

Definition

Allowable costs for a grant are defined under the Uniform Guidance (PDF) (effective December 26th, 2014) sections §200.403 Factors affecting allowability of costs, §200.404 Reasonable costs, and §200.405 Allocable costs.

Procedure

Unless otherwise stated or clarified in a specific funding opportunity's guidelines, Towson University will adhere to the definition of allowable costs as listed above.

Definition

The Uniform Guidance (PDF) which took effect December 26th, 2014 defines indirect costs in section §200.56:

"Indirect (F&A) costs means those costs incurred for a common or joint purpose benefiting more than one cost objective, and not readily assignable to the cost objectives specifically benefited, without effort disproportionate to the results achieved. To facilitate equitable distribution of indirect expenses to the cost objectives served, it may be necessary to establish a number of pools of indirect (F&A) costs. Indirect (F&A) cost pools should be distributed to benefited cost objectives on bases that will produce an equitable result in consideration of relative benefits derived."

An F&A rate is formally negotiated with the federal government for use on grants and contracts and other agreements with the Federal Government.

Procedure

To see the current F&A rates that Towson University uses, please refer to the Institutional Data page.

For an explanation on how MTDC costs are calculated, please see the Develop Your Proposal page.

F&A cost recovery is distributed monthly as follows:

Group / Division	Percentage
Principal Investigator	5%
Principal Investigator's Department	10%
Principal Investigator's College	15%
Academic Affairs/Provost Office	20%
Office of Sponsored Programs & Research	25%
Division of Administration and Finance	25%

Participant incentive payments are managed by Accounts Payable. When an external grant is used to fund the incentives, use the grant account code when processing payments for the incentives. 

There are two exceptions when purchasing gift cards as human subjects' incentives do not go through Accounts Payable:

• Gift cards can be purchased from the University Store (UStore) for bookstore purchases using a department account. Investigators must collect and maintain information required by the UStore. Contact the UStore for details.
• For OSPR managed funds (external grants and internal awards) only, human subject participant electronic gift cards may be purchased through Tango in accordance with the Procedures for Human Subjects' Incentives (PDF). 

Purpose

The purpose of this statement is to set procedures to ensure timely closure of completed fixed price contracts/agreements and the proper disposition of any unexpended balances.

Definitions/Applicability

• "Fixed price contracts" referred to here are characterized by payments of predetermined amounts by a sponsor to support a project. The payments are either lump sum or periodic and may or may not require a payment request from Towson University. The payments are not made on an expense reimbursement basis but on a predetermined lump sum project cost, without further accounting.
• If the actual documented project costs are less than the award, the excess revenue is retained by Towson University. Cost overruns exceeding $50 will be assumed by the department (if the sponsor does not provide the needed additional funding).
• Following positive indications of contract completion (such as copies of final technical reports or deliverables), unexpended funds on fixed price contracts will be shared equally by the Office of Sponsored Programs and Research and the department of the principal investigator if (1) there was no voluntary waiver of facilities and administrative (F&A) costs, and (2) the unexpended balance is greater than $100. If there were F&A cost waivers, funds will first be used to reimburse the campus for unrecovered F&A costs, according to the normal distribution policy.

Purpose

The purpose of this statement is to set procedures to ensure timely closure of completed cost reimbursable contracts/agreements.

Definitions/Applicability

• "Cost reimbursable contracts" referred to here are characterized by payments based on actual project expenditures. Towson University receives payments based on an invoice or payment request sent to the sponsor.
• In the rare instance that the actual documented project costs are less than the amount invoiced, the excess revenue is returned to the sponsor.