Finding Text
2024-005: Timeliness of Cost Transfers
Grantor: Department of Health and Human Services, National Institute of Health (“NIH”), National Heart, Lung,
and Blood Institute, Eunice Kennedy Shriver National Institute of Child Health & Human Development
Cluster: Research & Development
Award Names: KidsDOTT-CCC, Pediatric Biospeciment Procure Center (BPC) supporting the Developmental
Gene (dGTEx) Project
Award Numbers: U01HL130048, U24HD106537
Assistance Listing Titles: Blood Diseases and Resources Research, and Child Health and Human
Development Extramural Research
Assistance Listing Numbers: 93.839 and 93.865
Award Years: September 15, 2016 – June 30, 2024 and September 9, 2021 – August 31, 2024
Passthrough Entity: Johns Hopkins University
Criteria
The National Institute of Health Grants Policy Statement requires cost transfers that represent corrections of
clerical or bookkeeping errors be made promptly after the error occurs but no later than 90 days of when the
error was discovered. Cost transfers must be appropriately justified, documented and completed in a timely
manner to support its allowability.
Condition
For 5 of 7 cost transfer selections tested, there were salary cost transfers which were over 90 days and without
formal supporting documentation justifying the reason for the cost transfer and approval of such supporting
documentation from the respective grant Principal Investigator (“PI”) as required within 90 days of the error
being discovered.
Cause
JHHS did not have a formal cost transfer policy and as such, there were inconsistent processes in place
regarding cost transfers, such as verbal discussions with grant PIs, lack of maintenance of documentation
explaining how the errors occurred and periods of time longer than 90 days between discovery of costs needing
to be moved onto the grant and actual transfer of costs.
Effect
The salary cost transfers made in FY24 were appropriate such that the costs were allowable and allocable to
the grants to which they were transferred, however, there was a lack of controls operating over the timeliness
and sufficiency of supporting documentation for cost transfers during the fiscal year.
Questioned Costs
There are no questioned costs associated with this finding.
Recommendation
We note management implemented a new control in FY25, which requires formal written documentation and
sign off on all cost transfers by grant PIs. JHHS should implement a formal written policy over cost transfer
processes that is in compliance with federal guidelines with respect to timeliness of approvals and maintaining
supporting evidence. Additionally, we recommend JHHS communicate, provide training and enforce the policy
to ensure cost transfers are executed and documented in accordance with policy.
Management’s Views and Corrective Action Plan
Refer to Management’s View’s and Corrective Action Plan at the end of the report.