As a recipient of federal funds, SIBCR is obligated to uphold standards that are consistent with Office of Management and Budget (OMB) and Agency specific guidance. Thus, it is necessary to explain and justify transfers of charges into federal and non-federal awards from other federal accounts and non-federal accounts. Timeliness and completeness of explanation of transfers are important factors in supporting allowability and allocability in accordance with federal cost principles in accordance with OMB Circulars 2 CFR Part 230 and 2 CRF 200.405.
2 CFR 230: “…any costs allocable to a particular award or other cost objective under these principles may not be shifted to other federal awards to overcome funding deficiencies, or to avoid restrictions imposed by law or by the terms of the award.”
In addition to complying with federal cost principles, SIBCR must also comply with the requirements of the National Institutes of Health (NIH), our largest source of federal research funding. Specific language on cost transfers can be found in the NIH Grants Policy Statement.
In accordance with federal cost principles and SIBCR policy, charges to awards for salaries and wages, whether treated as direct costs or indirect costs, are based on monthly time and effort reports stated on the SIBCR time sheet.
Time and effort reports are signed by the individual employee and by a responsible supervisory official having firsthand knowledge of the activities performed by the employee, certifying that the distribution of activity represents a reasonable estimate of the actual work performed by the employee during the periods covered by the reports.
Reallocation of effort on previously certified time sheets is allowable only under extenuating circumstances and must be approved by the Grant Manager and SIBCR accounting department.
Please contact your Grant Manager or the SIBCR Chief Financial Officer for additional information regarding reallocation of effort.