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 MyFD are reflected on the online FEC the next 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, a recertification might be necessary. If recertification is processed online, no supporting documentation is needed. All post certification salary transfers and post certification cost share commitment changes are captured with an online recertification.
Recertification of the FEC is only required if the level of effort on the sponsored award changes. Recertifications 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 Award 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 Award, or
- Transfers from a non-award budget to another non-award budget.
Supporting Documents for Paper Recertifications
Recertification of FECs prior to the 9/16/11-3/15/12 cycle for academic reporters and 7/1/11-12/31/11 cycle for the calendar reporters, or recertification of FECs previously recertified on paper is a manual process using departmental copies of previously certified (or recertified) paper FECs.
- 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.
Roles and Responsibilities
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 2, "Acceptance of Sponsored Program Awards and Fiscal Compliance on Sponsored Program Accounts (Budget Numbers)".
Salary Transfer Preparer
- 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
- 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.
- 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
- Reviews the salary transfer for accuracy and adherence to compliance requirements (e.g. GIM 14 “Delegation of Signature Authority for Sponsored Projects”and GIM 15 “Transfer of Expenditures between Grant or Contract Budgets.”)
- Ensures each salary transfer does not cross FEC cycle dates, i.e. create a separate salary transfer for each FEC cycle.
- Submits the salary transfer,
- 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.
- Notifies the FEC coordinator that an updated FEC is available in eFECS if the FEC has not yet been certified.
Departmental FEC Coordinator
- Verifies the salary transfer has been posted.
- Prepares a spreadsheet to identify charges transferred in each FEC cycle if the salary transfer crosses FEC cycle dates.
- Reviews the updated FEC in eFECS for FECs that have not been certified,.
- For FECs needing to be recertified online, follows the process. For FECs needing to be recertified on paper,
- Adjusts the printed paper copy of the FEC to reflect the salary changes made via the salary transfer,
- Staples the final posted salary transfer, and “Notes,” if applicable, to the paper FEC,
- 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.
- 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:
- 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.
- Avoid salary transfers where effort has previously been certified as correct.
- Establish advance budgets when sponsor notices of awards are delayed so salary charges begin on time.
- Do not use sponsored awards as a holding account. Doing so is a non-compliant practice per Federal regulations.
- Avoid salary transfers occurring at the end of an Award. 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.
- 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.