Salary Transfers

 Online Salary Expense Transfers

Online Salary  Expense Transfers (sometimes referred to as OSETs) serve to both initiate and document adjustments and corrections to salary expenditures. As a best practice, these transfers should be completed prior to certification of the FEC to prevent the need for effort recertification. A salary transfer should be prepared whenever the percent of effort performed is materially less than or greater than  the percent of salary charged to a sponsored project.

Online Salary Expense Transfers processed via MyFinancial.Desktop (MyFD) are reflected on the online FEC the nest business day after posting in MyFD. This allows departments the ability to process the salary transfer and then have the faculty member certify the faculty effort certification (FEC) form online.

However, when the faculty member has  certified the FEC prior to the salary transfer being processed:

  • The department must print the certified FEC and attach the posted electronic salary transfer.
  • To print a salary transfer initiated by another department see MyFD's Transaction Summary Report and Copies of Salary Transfers.
  • The salary transfer should be the version that indicates "Transaction has been Posted."
  • The adjustments resulting from the salary transfer must be manually recorded on the paper FEC.

Recertification of the FEC in only required if the level of effort on the sponsored project changes. Recertification are not required when:

  • Documenting the transfer of salaries to a sub-budget number as long as it does not change the percent effort on the project for the respective FEC cycle.,
  • The salary transfer is from a parent budget to a sub budget or a sub budget to another sub budget within the same project,
  • Transfers from on non-grant budget to another non-grant budget

Roles and Responsibilities

Department Administrator

The Department Administrator should confirm that the salary transfer for sponsored agreements (grants and contracts) conforms to the internal departmental approval process for salary transfers as documented in GIM 14 “Attachment, ‘Delegation of Signature Authority for Sponsored Projects’”

Salary Transfer Preparer

  1. Completes the salary transfer. If the begin and end dates of the salary transfer cross one or more  FEC cycle periods, prepare a separate salary transfer for EACH FEC cycle
    Academic reporting, use the following dates:
    9/16 to 3/15
    3/16 to 9/15
     
    Calendar reporting, use the following dates:
    1/1 to 6/30
    7/1 to 12/31
  2. Ensures  the justification(s) provided to document the reasons for the transfer on the salary transfer conforms to the requirements of GIM 15, “Transfer of Expenditures between Grant or Contract Budgets.
  3. Use the "Notes" section if the justification exceeds the number of characters available in the justification text boxes, use the “Notes” section to document the reasons for the transfer and recertification.

Salary Transfer Submitter

  1. Reviews the salary transfer for accuracy and adherence to compliance requirements (e.g. GIM14 “Delegation of Signature Authority for Sponsored Projects”and GIM 15 “Transfer of Expenditures between Grant or Contract Budgets.”)
  2. Ensures each salary transfer does not cross FEC cycle dates, i.e. create a separate salary transfer for each FEC cycle.
  3. Submits the salary transfer,
  4. If the OSET is being processed after the faculty member has certified the FEC,
  • Make a paper copy of the final POSTED salary transfer and the "Notes" section, if applicable.
  • Send the salary transfer and "Notes," if applicable, to the departmental FEC Coordinator.
    •  The coordinator may be in another department if the department processing the salary  is not the faculty member's home department.
  • If the FEC has not yet been certified, notify the FEC Coordinator that an updated FEC is available in eFECS.
  1. Notifies the FEC coordinator that an updated FEC is available in eFECS if the FEC has not yet been certified.

Departmental FEC Coordinator

  1. Verifies the salary transfer has been posted.
  2. Prepares a spreadsheet to identify charges transferred in each FEC cycle if the salary transfer crosses FEC cycle dates.
  3.  Reviews the updated FEC in eFECS for FECs that have not been certified,.
  4. For FECs needing to be recertified,
    1. Adjusts the printed paper copy of the FEC to reflect the salary changes made via the salary transfer,
    2. Staples the final posted salary transfer, and “Notes,” if applicable, to the paper FEC,
    3. Sends a paper copy of the posted salary transfer to the faculty member's home department administrator or FEC coordinator if the faculty member is in another  department.
    4. The second department includes the salary transfer as documentation with the faculty member’s FEC.

Compliance Considerations and Justifications

Salary transfers are a key indicator of the quality and effectiveness of internal controls. Salary transfers should not be used as a management tool nor used for convenience to move funds between budgets. Salary transfers can become a significant compliance risk.

The department should take the following actions to avoid as many transfers and/or compliance implications as possible:

  1. Review and reconcile salary charges on a monthly basis to determine required salary distribution changes, detect errors and/or make payroll adjustments to reflect appropriate effort levels.
  2. Avoid salary transfers where effort has previously been certified as correct.
  3. Establish advance budgets when sponsor notices of awards are delayed so salary charges begin on time.
  4. Do not use sponsored budgets as a holding account. Doing so is a non-compliant practice per Federal regulations.
  5. Avoid salary transfers occurring at the end of a grant period. In the few cases where these late transfers might be necessary, complete justifications for the change should be carefully documented in the salary transfer justification section as auditors perceive these as "spending down" remaining grant balances.
Salary transfers are to be completed promptly, i.e. within 90 days of discovery. Transfers made over 120 days from the original transaction date require additional justifications.
To provide adequate justifications answer all of the following questions in the justification sections of the online salary transfer:
  • Why was the expenditure transferred?
  • Is the transfer within approved guidelines of the budget? Explain.
  • Is the transfer in direct support of the project? How?
  • Why the expenditure was originally charged to the incorrect budget?

For transfers completed over 120 days from the original transaction date, answer the next three questions in addition to questions above:      

  • Why is the transfer late?
  • Explain why this error was not identified during the monthly budget review by the PI.
  • If it was identified during the monthly budget review, why it was not transferred in a timely manner?

For transfers processed after the FEC has been certified

  • Provide a complete, detailed description of what circumstances have changed between now and when the faculty member last certified his/her FEC that prompt the change.
  • Describe why, when the faculty member originally certified the FEC, the payroll distribution was a reasonable reflection of effort then and now is not.
  • Explain why there was a significant time lapse between completion of the salary transfer and the FEC revision.

 

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