What is a Retro Request (Retro)?
A request for permission to retroactively move (reallocate) charges from one PTAO to another. UVA defines retroactive as ≥ 90 days after the Transfer Date (the date the cost is initially posted in the Integrated System) for Other Than Personnel Services (OTPS) cost transfers or ≥ 90 days after the Check Date of the payroll period for Labor Distribution (LD) adjustments. At UVA such transactions are often referred to as a "Retro".
When do I need to submit a Retro Request?
UVA requires prior review and approval for all Retros moving charges between sponsored PTAOs (awards starting with G or Z) or on to a sponsored PTAO from a non-sponsored PTAO.
Submission of a Retro Request Form is NOT required in the following circumstances, even if they are ≥ 90 days past the Transfer Date (OTPS cost transfers) or ≥ 90 days past the Check Date (LD adjustments): ·
- The transfer involves ONLY non-sponsored PTAOs;
- You are clearing a deficit on a sponsored PTAO to a non-sponsored PTAO;
- You are moving an unallowable or unallocable cost off a sponsored PTAO to an non-sponsored PTAO*;
- You are moving charges between projects (P) or tasks (T) on a single award (A); or
- You are correcting an expenditure type to reflect supporting documentation.
*Labor/Payroll charges incurred on sponsored PTAOs that are not subsequently supported by effort certifications are NOT allocable to the sponsored program and must be removed immediately via an LD adjustment to a non-sponsored PTAO; notices are provided to the department Effort Reporting Coordinator to facilitate this process.
Retro Requests will only be approved in truly exceptional circumstances, for example, when a sponsor changes the financial reporting requirements after an award has been set-up and expenses have been incurred. Retro requests to correct administrative oversights or errors will not be approved without "timely" documentation of the need for the transfer, e.g., the allocation error being flagged as an issue in Recon@ prior to certification or an email (dated < 90 after the Transfer Date for OTPS or Check Date for LD) noting the allocation error and requesting correction.
How do I submit a Retro Request?
Complete the Retro Request Form, obtain the authorizing signatures, then email the form to firstname.lastname@example.org. A member of the post-award financial management staff in the Office of Sponsored Programs will review the form and then will do one of the following: 1) request additional information, 2) issue full or partial approval (with an approval number that must be noted when the transaction is processed in the integrated system), or 3) deny the request.
Why is prior approval from the Office of Sponsored Programs required for Retros?
The correct initial allocation of costs is critical to sound fiscal stewardship. Cost transfers or LD adjustments to correct allocation errors are viewed as indications of weak internal controls. When errors in initial allocation occur, they should be caught and corrected timely as part of the monthly reconciliation process. UVA considers corrections to be “timely” if they are completed within 90 days of the Transfer Date (OTPS cost transfers) or Check Date (LD adjustments) and does not require submission of a Retro Request for such corrections. Ninety days is allowed to insure there has been sufficient time for charges to have appeared on a monthly reconciliation and to provide additional time to implement the adjustment. It is important to remember that when monthly reconciliations are prepared the Preparer is attesting to the following:
"I have reviewed current month expenditures for accuracy and sufficient source documentation in accordance with University Financial Procedure 1-4."
The Approver is attestation reads as follows:
"After review of the period expenditure detail report and this summary report, to the best of my knowledge all costs charged to this project are appropriate and wages charged are in relation to work performed on this project. Where required, corrections have been or will be requested to be made in the Integrated System."
Based on these attestations, the post-award financial management staff in the Office of Sponsored Programs (and auditors) must assume that the initial allocation is correct.
When Retro Requests are approved, documentation supporting the change in allocation must be maintained by the initiating unit and must be provided to support compliance reviews, internal or external audits, or when requested by a Central office, e.g., Finance Outreach and Compliance (FOC), Sponsored Programs (OSP), or Internal Audit (IA).
Why might my Retro Request be denied?
The following are common reasons for denial:
- Failure to adequately document why the charges are allocable to the receiving sponsored PTAO.
- The request is to correct administrative oversights or errors but lacks “timely” documentation indicating the need for the transfer by the PTAO owner (Principal Investigator).
- Note: Preferably, "timely" documentation would be in the form of a comment associated with the incorrectly allocated salary/wage line item(s) in Recon@.
- The LD adjustment(s) would impact one or more certified effort reports.
- The Transfer Date/Check Date is outside the active period of the PTAO.
- The cost transfer or LD adjustment would put the receiving PTAO into deficit.
- The receiving PTAO is closed.
Questions about Retro Requests should be directed to the post-award financial management staff in the Office of Sponsored Programs.