Cost Transfers

1
Cost Transfers
2
Learning Objectives

• At the end of this training, you should be able
  to
• - Define and understand cost transfers.
• - Know how to execute a proper cost transfer
  transaction.
• - Understand acceptable and unacceptable cost
  transfer practices.
• - Pass the certification exam.

3
Agenda

• Definition, Roles and Importance
• Federal Regulations
• Good Bad Practices
• Processing Non-Labor Cost Transfers
• Processing Labor Cost Transfers
• Monitoring
• Getting Help

4
Your Roles and Responsibilities

• As a Yale employee working with sponsored
  research, you play a key role in the financial
  administration of the University. You are
  responsible for ensuring that sponsored funds are
  managed according to Yale policies and procedures
  and sponsor terms and conditions.
• This overview will help you understand how to
  carry out these responsibilities using Yales new
  Cost Transfer Policy Guidelines.

5
What is a cost transfer?

• Any cost that is first charged to one award and
  later charged to another award, where one or both
  of the awards is a grant or contract, is referred
  to as a cost transfer for sponsored awards.
• Reclassification of charges within an award are
  not cost transfers.
• There are two types of cost transfers
• Non-Labor, achieved at Yale via a journal entry,
  and
• Labor, achieved at Yale via a labor distribution
  adjustment.

6
Non-Labor Costs

• These costs include all costs other than
  salaries, wages, and benefits.
• They are purchases of goods services
• Examples
• Reagents,
• Lab Supplies,
• Equipment,
• Travel,
• Internal Service Provider charges (stock room,
  YARC)

7
Labor Costs

• Labor costs are salaries, wages, and benefits.
• To justify labor costs paid by federal funds, the
  University must
• Maintain payroll records
• AND
• Confirm charges after the fact. At Yale we
  confirm charges using Activity or Effort
  reporting.
• Monthly for Clerical and Technical staff
• By term (fall, spring, summer) for 9-month
  faculty
• Semi-annually for 12-month faculty, professional
  employees, and graduate students.
• Timesheets for weekly and casual employees.

8
Why are cost transfers an important topic?

• Yale has a responsibility to use funds in
  accordance with applicable law and sponsor terms
  and conditions.
• The federal government scrutinizes cost transfers
  closely for indications of cost misallocation,
  and often disallows costs transferred into
  federal accounts on that basis, or because of
  non-compliance with timing, documentation, and
  procedural requirements.
• Improper, inadequately documented, and delayed
  cost transfers (beyond 90 days after discovery of
  error) violate Federal law or cost policy and are
  potentially costly and damaging to the
  University.
• Frequent cost transfers and cost transfers made
  long after the original cost is incurred (even if
  valid) raise questions about the reliability of
  the institutions accounting system and internal
  controls.

9
Mayo Clinic Story

• In May 2005, the Mayo Clinic paid approximately
  6.5 million to settle a fraud suit alleging that
  it improperly charged the government for work
  performed under federal grants from NIH.
• The government alleged that the Mayo Clinic had
  long-standing practices of
• Spending down grant accounts at the end of the
  year to avoid returning unused funds to NIH,
• Shifting costs from grant projects that were
  over-expended to grant projects that were
  under-expended without adequate documentation,
• Retroactively altering effort and financial
  progress reports to reflect the reassignment of
  charges to the grants with remaining funds,
• Not properly documenting transfers, and
• Not making transfers in a timely manner.
• While the Mayo Clinic did not admit wrongdoing in
  the settlement, the hefty settlement payment and
  adverse publicity were detrimental.

10
What do Federal Regulations require?

• OMB A-21 states
• Any costs allocable to a particular sponsored
  agreement under the standards provided in this
  Circular may not be shifted to other sponsored
  agreements in order to meet deficiencies caused
  by overruns or other fund considerations, to
  avoid restrictions imposed by law or by terms of
  the sponsored agreement, or for other reasons of
  convenience (U.S. OMB, Circular A-21 Revised,
  Section C4).

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OMB A-21 Continues

• If a cost benefits two or more projects or
  activities in proportions that can be determined
  without undue effort or cost, the cost should be
  allocated to the projects based on the
  proportional benefit. If a cost benefits two or
  more projects or activities in proportions that
  cannot be determined because of the
  interrelationship of the work involved, the
  costs may be allocated or transferred to
  benefited projects on any reasonable basis (OMB
  A-21 Revised, Section C.4.d(3)).

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NIH Grants Policy Statement

• Corrections of clerical or bookkeeping errors
  should be made within 90 days of the discovery of
  errors.
• Transfers must be supported by documentation
  fully explaining how the error occurred and
  certified by a responsible organizational
  representative that the new charge is correct.
• Explanations such as to correct error or to
  transfer to correct project are not sufficient.
• Delayed discovery of errors could be an
  indication of poor internal controls.

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NIH Grants Policy Statement (continued)

• Transfers of costs from one project to another or
  from one competitive segment to the next are not
  allowable if they are made solely to cover cost
  overruns or to spend down a grant.
• Grantees must maintain cost transfer
  documentation and make it available for audit and
  other reviews.
• Frequent errors in recording original costs may
  indicate the need for system or internal control
  improvements.
• NIH may require grantees to take corrective
  action by imposing additional terms and
  conditions on grants, for example, an
  organization could lose the privilege of
  expanded authority, which allows institutions
  some flexibility for managing grants without
  obtaining prior sponsor approval.

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Charges to Federal Grants must benefit the
project AND be
15
Good Practices GET IT RIGHT THE FIRST TIME!

• Plan expenditures to try to avoid cost transfers.
  Cost transfers should not be a standard means
  for managing grants.
• Charge costs to the correct award initially and
  ensure they are allowable and allocable to that
  award.
• Create labor schedules in advance to avoid making
  after-the-fact labor distribution adjustments.
• When costs are shared by more than one award, use
  split charging instructions. When this is not
  possible, allocate costs within 90 days.
• Set up non-sponsored program accounts to hold
  costs to be allocated.
• Change standing PTAEOs for items such as
  salaries and standing purchase orders in a timely
  manner when award numbers change.
• Request an At Risk fund to charge costs
  incurred prior to receipt of a notice of grant
  award.

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Good Practices (continued)

• Obtain no-cost extensions prior to the end of the
  original project to complete work after the
  original award period ends.
• Plan and monitor costs regularly.
• Provide PIs with monthly financial reports and
  help to review them, comparing costs with budgets
  investigating questionable charges.
• Make required cost transfers in a timely manner
  (within 120 days of original transaction or 90
  days of discovery whichever is earlier).
• Remember that each award as a separately financed
  project with separate technical and financial
  products.

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Red Flags

• Transfers to or between federal grants.
• Transfers older than 120 days after original
  transaction.
• Transfers in the last month of the award or after
  the award has expired.
• Large numbers of cost transfers.
• Grants or contracts with a zero balance at the
  end of the award.
• Round numbers (may be an indicator of a plugged
  number).
• Paying summer salary late (in December).
• Labor distribution adjustments to previously
  certified effort.

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Bad Practices

• Transfers with inadequate explanations.
• Explanations that raise more questions than
  answers.
• Incomplete documentation
• Using to correct an error or to transfer to
  correct project as an explanation.

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DO NOT

• Pool sponsored awards.
• Use any sponsored project as a holding account.
• Make cost transfers to other sponsored projects
  to spend down a grant.
• Transfer costs from one sponsored project to
  another to clear an overdraft.
• Transfer costs to avoid the 25 carryover
  approval requirement.

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When are cost transfers required?

• When one cost benefiting multiple projects needs
  to be allocated among them (for example service
  center charges).
• If a cost has been charged to the incorrect award
  (for example, data entry error, reallocation of
  effort, pre-award costs, late issuance of notice
  of award).

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If you must make a cost transfer

• Ensure the reason for the transfer is acceptable.
• Ensure the cost to be transferred is allowable,
  reasonable and allocable to the new account, and
  was incurred within the award period or is
  permissible as a pre-award charge.
• Process the transfer in a timely manner.
• Document the transfer properly
• Provide a detailed explanation of the error and
  how it occurred.
• Explain how the cost benefits the grant being
  charged.
• Obtain written authorization from the PI or other
  responsible departmental representative
  knowledgeable about the grant.

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Transferring Non-Labor Costs
THE PREPARER Step 1. Assemble information and
evaluate the cost transfer. Step 2. Make the
journal entry Step 3. Check your work Step 4.
Give transaction documentation to the
approver THE APPROVER Step 5. Review the
Transfer Step 6. File the Transfer Documents
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Transferring non-labor costs.Step 1.

• A. Assemble the paperwork, including
• A copy of the original transaction
• Original and new charging instructions (PTAEOs)
• A written authorization to make the transfer
  signed by the Principal Investigator or other
  responsible institutional representative
  knowledgeable about the grant (email or
  hand-written note is acceptable)
• If allocating costs between two or more projects,
  a description of how the allocation was done
• A written explanation of how the error occurred
• A written explanation of how the cost benefits
  the sponsored project to which the charge is
  being transferred.

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What documentation of the original transaction is
acceptable?

• Invoice
• Internal Service Provider bill or receipt.
• For VIP purchase Any document that identifies
  what was purchased, including invoices and
  packing slips.
• Purchasing card (Pcard) expenditures over 75
  receipts.
• Purchasing card purchases under 75 Signed
  monthly P- Card Statement with purchase listed.

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Transferring non-labor costs.Step 1 (continued).

• B. Evaluate the cost transfer
• Does the original transaction fall within the
  award period or is it allowable as a pre-award
  charge?
• Is the charge allowable (check OMB A21 and
  restrictions in the Notice of Award)?
• Is the cost reasonable?
• Is the cost allocable to this award?
• Is this cost being handled in a consistent
  manner?
• Is the justification complete, including a
  description of the allocation method or an
  explanation how the error occurred?
• If the answers to all these questions are yes,
  proceed to next set of questions. If the answer
  to any question is no, contact your supervisor
  or GCFA.

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Transferring non-labor costs.Step 1 (continued).

• B. Evaluate the cost transfer
• Is the transfer being made to cover a cost
  overrun?
• Is the transfer being made in the last months of
  the award or after the award has expired?
• Is the amount being transferred a round number?
• If the answers to any of these questions is
  yes, review with your supervisor or GCFA.
  Otherwise, proceed to the next question.
• Is the cost transfer being made more than 120
  days after the original transaction or more than
  90 days after discovery whichever is earlier?
• If the answer to this question is yes, you must
  provide a written explanation why it is late.

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Transferring non-labor costs.Step 2.

• Make the Journal Entry
• A. Prepare the journal entry choosing
  YGCIndNonLabTr as the Journal Staging Area (JSA)
  category in the Batch Header.

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Transferring non-labor costs.Step 2 (continued).

• B. In the Flexfield called Date of Original
  Transaction, enter the original transaction
  date of the transaction, not the date the error
  was discovered.
• C. Enter the reference number of the original
  transaction (invoice number, batch name, et
  al.) in the Reference ID of Original Trx
  field.

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Transferring non-labor costs. Step 2
(continued).
D. Justify the cost transfer
When justifying the transaction, be sure to
explain specifically 1) how the allocation was
made or how the error occurred, 2) how this
award benefits from this cost, and 3) who
authorized the transfer to be made.
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Where to justify the Transfer
If the same justification applies to all batch
lines, enter justification in the Description
field at the top of the first Journal entry
screen. It will copy down to all journal lines.
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Where to justify the Transfer

• If each journal line has a different
  justification, use the Description field at the
  Line level

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Where to justify the Transfer

• If more space is needed, use the Reason and
  User Defined fields on the Flexfield

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Good Descriptions Should State

• How the error occurred / Why JSA is needed
  (technician inadvertently used wrong PCard to
  purchase supplies)
• How the error was found / Who initiated JSA
  (noticed during PI review)
• Why the new PTAEO is correct (charging award
  originally intended)

34
Examples of Good JSA Reasons Descriptions

• Move cost incurred prior to the set-up of a new
  award from GA account per PI and Business
  Manager.
• Purchased bulk quantity of acetone from stock
  room, which cannot split charges to multiple
  awards. This entry splits the charges based on
  PIs anticipated use. Allocation method on file
  in department.
• Supplies were originally purchased for award
  A12345, but were actually used on award R23456.
  Lab manager informed business manager of change
  in plans in the month of occurrence.

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Examples of Good JSA Reasons Descriptions

• To correct YARC billing which charged the wrong
  award. YARC was told of this change, but we
  missed their cutoff for the month. Error
  discovered by PI during monthly review of award
  statement.
• We made two similar purchases from the same
  vendor, for two different awards. One award was
  incorrectly charged for both items. Error
  discovered by lab manager during monthly review
  of statements.
• Wrong P-Card was inadvertently used to purchase
  the supplies. Error discovered during the monthly
  review by the business office.

36
Examples of Bad JSA Reasons Descriptions

• To transfer items that were incorrectly charged.
• Per PI instructions, move charges to clear an
  overdraft.
• Transfer YARC charges from Dr. Xs special use
  account to Dr. Ys account for December to March
  2004 and 2005.
• Transfer airgas credit from Dr. Xs (Non-Federal)
  PTAEO to Dr. Ys (Federal) PTAEO to close
  account.

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Transferring non-labor costs.

• Step 3. Check your work.
• A. Do you have all supporting paperwork (copy of
  the JSA, written explanation and authorization,
  copy of the original charge, description of
  allocation method if appropriate)?
• B. Is the description complete?
• Step 4 Give transaction documentation to the
  approver.

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Approving the Transfer

• The preparer and approver of the transaction MUST
  be two different individuals.
• The approver takes ownership of the entry and
  must review supporting documentation before
  approving the transfer.

39
Before ApprovingStep 5.

• Review the Transfer
• Consider
• Is the charge allowable (check restrictions the
  Notice of Award)?
• Is the cost reasonable and allocable to this
  award?
• Is the justification complete? Could a stranger
  understand what happened?
• Is the transfer being made to cover a cost
  overrun?
• Is the transfer being made in the last months of
  the award or after the award has expired?
• Is the amount being transferred a round number?
• Is the cost transfer being made more than 120
  days after the original transaction or more than
  90 days after discovery, whichever is earlier?
  If so, is the reason for lateness documented?
• Is the supporting documentation complete? Does
  the documentation stand alone? (Original
  transaction, explanation, authorization)
• If you do not feel comfortable about the answers
  to these questions, speak with your supervisor or
  GCFA.

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Filing the Transfer DocumentsStep 6.

• Ensure all documents relating to the transaction
  are fastened together and filed with the award
  being charged. Put a note in the original
  awards file, referencing the award to which the
  charge was transferred.
• All documentation related to the cost transfer,
  including but not limited to email, a copy of the
  original transaction, written explanation, and
  signed authorization must be retained according
  to Yales record retention policy and made
  available for verification during the course of
  an audit or other review.

41
Scenarios
42
Examples of Cost Transfers (Scenario 1)

• A PI has not received a new award for a new
  competitive segment and the old award is about to
  expire. She/he does not want to stop the
  research, so the PI charge want to charge the old
  award for incurred costs that should be charged
  to the new award.
• Are the costs allowable, allocable, reasonable
  consistent?
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

43
Examples of Cost Transfers (Scenario 2)

• A PI uses his/her P-Card to travel for research
  purposes. The expenses from the P-Card are
  charged to the departmental budget. PI returns
  from traveling and forgets to submit paperwork
  for travel expenses that are associated with
  research on a certain award until 6 months after
  the trip. Now PI wants to move charges to the
  correct award.
• Are the costs allowable, allocable, reasonable
  consistent?
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

44
Examples of Cost Transfers (Scenario 3)

• Payroll charged relocation costs to the same
  account as salary. Relocation costs cannot be
  charged to the grant so we are transferring costs
  to a proper account. The transfer is late due to
  lack of administrative staff.
• Are the costs allowable, allocable, reasonable
  consistent?
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

45
Examples of Cost Transfers (Scenario 4)

• Equipment was charged in error to PIs American
  Heart Association award. Yales installment
  from AHA was late. Equipment charge was removed
  and replaced by an equal amount of supplies
  purchased by the PI from the stockroom.
• Are the costs allowable, allocable, reasonable
  consistent?
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

46
Transferring Labor Costs
THE PREPARER Step 1. Assemble information and
evaluate the cost transfer. Step 2. Make the
labor distribution adjustment Step 3. Check your
work Step 4. Give transaction documentation to
the approver THE APPROVER Step 5. Review the
Transfer Step 6. File the Transfer Documents
47
Transferring Labor CostsStep 1.

• A. Assemble the paperwork, including
• A record of the original charges (for example, a
  payroll or effort report)
• Original and new charging instructions (PTAEOs)
• A written authorization to make the transfer
  signed by the Principal Investigator or
  responsible institutional representative
  knowledgeable about the project (email or
  hand-written note is acceptable)
• A written explanation of why effort was
  reallocated or how the error occurred.

48
Transferring Labor CostsStep 1 (continued).

• B. Evaluate the cost transfer
• Does the transaction fall within the award
  period, or is it allowable as a pre-award charge?
• Is the charge allowable (check OMB A21 and
  restrictions in the Notice of Award)?
• Is the cost reasonable?
• Is the cost allocable to this award?
• Is this cost being handled in a consistent
  manner?
• Is the justification complete?
• If the answers to all these questions are yes,
  proceed to next set of questions. If any answer
  is no, contact your supervisor or GCFA.

49
Transferring Labor CostsStep 1 (continued).

• B. Evaluate the cost transfer
• Has the individuals activity (effort report) for
  this period already been certified?
• Is the transfer being made to cover a cost
  overrun?
• Is the transfer being made in the last months of
  the award or after the award has expired?
• Is the amount being transferred a round number?
• If the answers to any of these questions are
  yes, review with your supervisor or GCFA.
  Otherwise, proceed to the next question.
• Is the cost transfer being made more than 120
  days after the original transaction or more than
  90 days after discovery, whichever is earlier?
• If the answer to this question is yes, you
  must provide a written explanation why it is
  late.

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Transferring Labor CostsStep 2.

• Make the Labor Distribution Adjustment (LDA)
• Enter the Begin Date and End Date of the
  Payroll period for which the adjustment is being
  made.
• In the Comments field, explain
• Why the effort was reallocated or how the error
  occurred,
• Who authorized the transfer, and
• If the transfer is more than 120 days after the
  original charge or more than 90 days from
  discovery, whichever is earlier, an explanation
  why the adjustment is being made late.

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Transferring Labor CostsStep 2 (continued).
 

• Enter the justification for the labor cost
  transfer in the Comments field

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Transferring Labor CostsStep 2 (continued).

• Good Descriptions should state
• How the error occurred / Why the LDA is needed
  (employee record entered in HR system too late to
  create labor schedule before first payroll was
  run)
• How the error was found / Who initiated the LDA
  (noticed by Business Manager during payroll
  review).
• Why the new PTAEO is correct (employee is
  research assistant on project)

53
Good LDA Explanations

• During the monthly review of Aug 05 grant
  statements, PI determined distribution of salary
  charges for Dale Spade should be reallocated to
  better reflect the actual time worked on the
  grant. Originally A11111 charged 25 but actual
  time was 20 due to extra time spent on A22222
  grant. Authorization from PI on file in the
  department.
• Salary charged to A12345 as reflected on the
  effort report was based on anticipated time for
  Jan-Jun 05 time period. Actual time allocation
  differed due to unexpected progress on D45678.
  LDA needed to adjust salary charges to reflect
  actual effort worked on grant. PI authorization
  on file in dept.

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Good LDA Explanations

• Per PI authorization, redistribute salary of Matt
  Down to PIs new NSF award D22222. PI discovered
  charging error during grant review. Documentation
  and authorization on file in dept.
• During a review of Jane Does effort report for
  Jan-Jun 05, PI discovered salary charges for Jan
  and Feb should have been charged to D22222 rather
  than D44444. The PI did not notice the error in
  charging during his review of the Jan and Feb
  grant statements. PI authorization on file in
  dept.

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Good LDA Explanations

• During the review of Dr. Xs effort report, PI
  realized change in charging instructions given to
  Business Office in Jan. were not completed. Error
  was not detected until review of Jul to Dec
  effort report. Authorization from PI on file in
  dept.

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Transferring Labor Costs

• Step 3 Check your work
• Do you have all supporting paperwork (copy of
  report showing original charge, written
  explanation and authorization)?
• Is the description complete?
• Step 4 Give transaction documentation to
  the approver.

57
Approving Labor Cost Transfers

• The preparer and approver of the transaction MUST
  be two different individuals.
• The approver takes ownership of the entry and
  must review supporting documentation before
  approving the transfer.

58
Before ApprovingStep 5.

• Review the Transfer
• Consider
• Is the charge allowable (check restrictions in
  the Notice of Award)?
• Is the cost reasonable and allocable to this
  award?
• Is the justification complete? Could a stranger
  understand what happened?
• Is the transfer being made to cover a cost
  overrun?
• Is the transfer being made in the last months of
  the award or after the award has expired?
• Is the amount being transferred a round number?
• Is the cost transfer being made more than 120
  days after the original transaction or more than
  90 days after discovery whichever is earlier? If
  so, is the reason for lateness documented?
• Is the supporting documentation complete? Does
  the documentation stand alone? (Original
  transaction, explanation, authorization)
• If you do not feel comfortable about the answers
  to these questions, speak with your supervisor or
  GCFA.

59
Filing the Transfer DocumentsStep 6.

• Ensure all documents relating to the transaction
  are attached together and filed with the award
  being charged. Put a note in the original
  awards file, referencing the award(s) to which
  the charge was transferred.
• All documentation related to the cost transfer,
  including but not limited to email, a copy of the
  original transaction, written explanation, and
  signed authorization must be retained according
  to Yales record retention policy and made
  available for verification during the course of
  an audit or other review.

60
What if you are uncomfortable with the transfer?

• Speak with your supervisor or Business Manager.
• Check with your business support service center.
• If this does not resolve your concerns, speak
  with John Maloney or Lan Virasak in Grants and
  Contracts Financial Administration at 432-3060.
• Refer to http//www.yale.edu/resources/ for more
  information.
• Review the Standards of Business Conduct for
  guidance (http//www.yale.edu/provost/html/standar
  ds.html ).

61
Monitoring by GCFA

• GCFA monitors sponsored program cost transfers
  over 100.00 for compliance with sponsor
  requirements and university policies
  procedures.
• JSA Descriptions are reviewed.
• Labor Distribution Adjustment Descriptions are
  reviewed.
• When descriptions are insufficient, departments
  are required to email complete descriptions to
  GCFA, print a copy of the email and staple it to
  the transaction documentation, and retain it in
  the award file.

62
Monitoring by GCFA continued

• 2. GCFA reviews documentation of all sponsored
  program cost transfer lines greater than 10,000
  and a random sample of all other cost transfers
  to ensure supporting documentation is adequate.
• Departments will be provided feedback including
• Requests for improving documentation on
  individual transactions
• Retraining for individuals who do not adequately
  justify and document cost transfers.

63
Monitoring The Bottom Line

• If the transfer explanation and documentation is
  incomplete or unacceptable, GCFA will notify the
  department and require the cost transfer be
  reversed.
• Access to prepare and approve cost transfers will
  be terminated if repeated incomplete or
  unacceptable transfers are identified.

64
Scenarios
65
Examples of Cost Transfers (Scenario 5)

• A PI doesnt want to stop doing research but has
  not received a new award for a new competitive
  segment and the old award is about to expire.
  She/he is charging salary to the departmental
  General Appropriation budget.
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

66
Examples of Cost Transfers (Scenario 6)

• PIs research assistant is working on various
  grants. Incorrect amount of effort was charged
  to one particular grant. PI reviews labor
  charges after the fact.
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

67
Examples of Cost Transfers (Scenario 7)

• Student wages were charged to faculty setup funds
  and portion of effort should be charged to
  facultys research award PI found error upon
  review of his accounts.
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

68
Examples of Cost Transfers (Scenario 8)

• On review of award expenses for the first half of
  the annual installment, PI decides to shift labor
  costs to another closely related project. Effort
  has already been certified.
• Explain the issues raised in this scenario.
• Is this situation an appropriate justification
  for a cost transfer?
• What should you do?

69
If you need assistance with cost transfers

• Contact John.Maloney_at_yale.edu or
  Lan.Virasak_at_yale.edu in GCFA or call 432-3060.
• At the Yale School of Medicine, contact
  Mark.Prendergast_at_yale.edu in Financial Operations.

70
Questions Answers