Transfer Policy

Types of accounts impact types of transfers, transfer activity, and also transfer allowability.

For sponsored awards, it is not allowable to move funds out of an account. And moving additional funds into a sponsored award is always attached to a modification of a contract of some type. Behind each sponsored award there is a fully executed, legally binding contract.

• This includes funds designated for subawards - they too have a contract, so again, we are required to follow specific guidelines when it comes to moving those funds. When a PI wants to move funds previously obligated for a subcontract, we have to seek what's called a formalized de-obligation (de-ob) confirmation from the subrecipient's contracting or billing team, or we have to receive a final invoice clearly marked as final for de-ob purposes.
   
• Any subaccounts with subcontract funds in them are required to have a zero or positive balance to move forward with a de-obligation request, which typicaly happens when the PI wants to move funds back out of that subcontract subaccount and into one or more of the others, often when an award is wrapping up and subaccounts need to be 'swept' together to clear out final expenses. 

Note: Sponsored funds belong to the sponsor until we (UT) spend them on project-allowable costs <-- They aren't our funds to re-direct to another purpose or to move around without permission, if sponsor has requested to be notified or to give approval prior to such requests. 

Sponsors give the university funds for PIs to conduct research. Some sponsors make mandatory that the costs (and types of costs) of the proposed research remain exactly as described in the budget. Others recognize it's tough to keep funds allocated exactly as first described - priorities change in the course of a project and they allow some flexibility. We need to determine what, if any, restrictions exist before we start moving funds around.

Anything that would change the scope of the project and/or statement of the work is subject to sponsor approval. These changes can impact the deliverables or goals of the work. In those cases, sponsor approval is always required. You can read OSP's wording on that here. 

Here are types of transfer restrictions often encountered in sponsored agreements:

• Not allowable
• Allowable only with sponsor approval
• Allowable, but limited to a certain percentage of the entire award
• Only allowable in certain costing categories (subaccounts)
• Allowable, but Limited to a percentage within particular costing categories

Check the CA3 screen in *Define where transfer restrictions are usually documented.
Review the award's executed agreement, accessed via RMS or UT-RMS.
Contact your SPAA Analyst in OSP (your accountant).

Many federal sponsors do allow what we refer to as transfers between subaccounts (aka rebudgeting costing categories): As long as the transfer doesn't represent a change to the Statement of Work (SOW) of the project, and you're not trying to transfer funds in the typically non-transferrable categories (subawards, participant support, more on this below).

The eCFR) which contains the set of regulations that govern federal funds at universities, has a section devoted to what is and isn't allowable, § 200.308. One important detail when taking in the eCFR details is to keep straight that they group sponsored awards 2 ways: Construction-related projects (infrastructure related, buildings, capital expenditures)  and non-construction Projects. 

• The Principal Investigator determines whether or not the requested budget transfer represents a change to the SOW and the SPAA Analyst (Accountant) has final approval on that determination.
   
  • The subaccounts that aren't available for transfers are the ones that are for subawards (the 60+ series of subs) - there's a contract behind those amounts, so to change them, a modification to the contact is needed. Also, funds categorized for participant support costs, typically in the 37 sub (and sometimes in the 70 series of subs) are unable to be transferred.
    
    Here's how the Code of Federal Regulations defines participant support costs:
    'Direct costs for items such as stipends or subsistence allowances, travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) in connection with conferences, or training projects.'
    
    You can find it within a list of CFR definitions here (a helpful list to get to know).

The National Science Foundation (NSF), a federal agency that funds many projects in COLA, maintains a published matrix of actions that require pre-approval, including transfers. The matrix is in play with many of the main federal agencies that sponsor reseach at UT as outlined on the document.

• NOTE: The Reference column indicates the applicable Code of Federal Regulations (eCFR)
• The RTC Overlay column references this document, which is designed to consolidate applicable rules

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