Transaction Controls

I. Overview

What are transaction controls?

Transaction controls are "locks" on certain expenditure types in the Integrated System that prevent those types of expenses from being charged to federally sponsored award PTAEOs, including federal flow-down sponsored projects. They are established at the PROJECT level at the time the PTAEO is created by OSP.

Why do we need transaction controls?

  • To assist with institutional costing consistency and decisions
  • To restrict specific expenditure type from charging to sponsored projects. These select expenditure types carry risks with allowability as direct costs and/or carry risk in their allocation

Federal Regulations require diligence on the part of the institution when it comes to making determinations of what items are considered direct costs vs. costs recovered as part of the facilities and administrative (F&A) rate. UVA uses transaction controls as PART of the process for managing these tricky or risky costs. (Visit our Costing Principles and Guidance page for tools and information to assist you with your costing decisions).

Keep in mind that just because something is NOT transaction controlled does NOT mean that costing principles don't apply! All costs to sponsored programs should be assessed for allowability, allocation, reasonableness, and consistency of charging (direct vs. indirect).

How are transaction controls applied?

When your federal or federal flow-down sponsored PTAEO is created, based on the type of funding source a PTAEO template is applied.

There are 2 types of templates:
Exclusive - this means that the expenditure types you see in the Integrated System/Discoverer are NOT allowed to be directly charged to the PTAEO. If an expenditure type isn't present that means it's not transaction-controlled, but remember - controls alone do not determine final costing decisions! Examples include the Federal and Training Grant/Fellowship templates.

Inclusive - this means that the expenditure types you see in the Integrated System/Discoverer are the ONLY ones allowed to be directly charged to the PTAEO. All other expenditure types are NOT permitted. Examples include the Subawrd/Subcontracts Patient Care Costs templates.

How do I know if there are transaction controls on my PTAEO?

1) Check out our "How to Look Up Transaction Controls" guide for information on how to identify transaction controls on your PTAEO, using either the Integrated System or Discoverer.

2) Use the Transaction Controls Templates to help you interpret the information in #1.

What is the process for lifting transaction controls on my PTAEO?

Under certain exceptional circumstances, items that are normally considered F&A costs can be directly charged to federally sponsored / federal flow-down awards. If you think your cost meets criteria for direct charging, you will need to submit a Federal Costing Exception request form. (Information about the criteria required for direct charging of F&A costs, as well as additional guidance on completing an FCE form can be found in the brief online module How Do I Fill Out a Federal Costing Exception Request Form?, as well as the Annotated FCE Form.)

Note: The following items do NOT have transaction controls but still require an FCE form for direct charging
:

General Use Software (Adobe Acrobat, Endnote, Office, etc)
Clerical/Administrative Salaries

Do Federal Costing Exception form approvals "carry forward" from year to year, on projects that are set up with a new PTAEO each year?
No - a new FCE is required each time a new Project is created.

Do transaction controls change?

Yes - occasionally transaction controls may be added/modified on various templates, so it's good to check this page for updates.

Once the transaction control is unlocked for a specific expenditure type, can I charge any costs to the project?

No - With the "unlocking" of a transaction control for a specific expenditure type, you have the authority to charge what has been disclosed/approved on the related Federal Costing Exception form. If other/additional costs need to be considered, a new FCE form needs to be submitted for review.

I need to charge some items quickly - can you expedite my FCE review?

We recommend that departments with time-sensitive purchasing issues buy the needed items and charge them to non-sponsored funds, while the FCE is under review.

If my FCE form is approved, is that a guarantee that the charge will stand?

Despite everyone's best efforts, it is always possible that auditors can disallow costs. Departments will be required to absorb any costs that are denied by reviewers.

II. References:

OSP Costing Principles and Guidance
Federal Costing Exception form
Annotated FCE Form
How Do I Fill Out a Federal Costing Exception Request Form? (online reference guide)
Costing Classes

Still have questions? Email Camilla Curnow or Sharon Brooks at OSP!