I suspect that issues related to cost transfers affect us all.
However, this matter like many others is not a problem until it becomes a
problem.  Therefore, it seems to be a management decision of when the issue
becomes significant.

 Errors can be made in charging and should be corrected as soon as
possible after they are identified.  I believe that 90 days is the time
allowed to make these corrections.  The only way to prevent excessive,
arbitrary transfers is to simply not allow them.  Education is necessary,
but a clearly written and consistently enforced policy helps immensely.

 One related factor is to consider when and how your time and effort
reporting is done.  If T/E sheets are already signed by the PI, then it
raises questions of whether or not the charge was truly an error if a
transfer is subsequently proposed.  Good planning and monitoring of all
accounts is clearly needed in all cases.

Terry A. May, Ph.D.                       Voice:    520-523-6788
  Director of Research Administration     FAX:      520-523-1075
  Office of Grant & Contract Services     INTERNET: xxxxxx@nau.edu
  100 Babbitt Admin. Ctr., Box 4130
  Northern Arizona University
  Flagstaff, AZ  86011-4130