Sponsored Programs Administration
University Policy Number 4006
Related Law & Policy:
- Policy 2108: Direct and Indirect Cost Allocations Under OMB Circular A-21
- Policy 4001: Financial Conflicts of Interest in University Contracts with Businesses Under Virginia Law
- Policy 4005: Cost Transfer
- Policy 4010: Financial Conflicts of Interest in Federally-Funded Research
This policy applies to all George Mason University (Mason) employees at all University locations, owned or leased.
II. POLICY STATEMENT
All projects for research, training, and service undertaken by University employees using University resources and funded by external sources must be processed through and approved by the Office of Sponsored Programs. Faculty and staff are not authorized to commit the institution through proposal submission or contract or grant acceptance.
The Office of Sponsored Programs is charged with providing guidance and support to the University community in its research efforts by creating an administrative environment that ensures that the University’s financial and contractual obligations are protected.
1. Identification of Funding Sources: The Office of Sponsored Programs provides access to searchable research funding source databases to assist faculty and staff in identifying potential funding sources.
2. Preparation and Submission of the Proposal
a. Notifications: When planning to submit a proposal, a faculty member must notify the Chair, Dean/or Institute Director to discuss potential issues such as release time, space requirements, equipment purchases, etc. All proposed participants must be aware of and agree to their inclusion at the time of proposal submission. The submission process begins by contacting the Office of Sponsored Programs.
b. Development of the Proposal: The Principal Investigator (PI) is responsible for writing the proposal narrative and for assembly of the bibliography, relevant vitae, and appendix materials. The PI is also responsible for obtaining cost share commitment documentation and required sub-recipient proposal information. The Office of Sponsored Programs will assist in the preparation of the proposal budget, the summary of current awards and pending proposals, and will complete the sponsor’s forms which are applicable to the particular submission. Sufficient lead time for review, approval, and preparation of proposal package is essential to ensure completion by the submission deadline.
c. Proposal Review: All proposals must be reviewed and approved by the appropriate University officials and the Office of Sponsored Programs prior to submission to the sponsor.
d. Submission of the Proposal: All proposals submitted under the University name must be formally submitted by the Office of Sponsored Programs. This includes all proposal elements such as draft budgets, cost estimates, and preliminary proposals.
3. Proposal Budget: The sponsored project budget should reflect a realistic estimate of the total cost of the project. All costs included in proposals to federal funding sources must be allowable and allocable as required by OMB Circular A-21.
a. Personnel: Salaries are to be budgeted using actual salary rates with estimated increased increments for future years funding. Budgeted salaries are estimates. Fringe benefits are to be budgeted based on the employee classification. These rates are published by the Budget Office. Only actual salaries will be paid to personnel of the University. Note: The hiring of all new employees for positions on sponsored projects is subject to the policies and procedures established by Compliance, Diversity, and Ethics for affirmative action recruitment. (See University Policy 2224-Recruitment and Hiring of University Employees.) Inclusion of the name of a person in a proposal budget or in a proposal narrative does not guarantee that the named individual will be hired.
b. Equipment: All proposed computer equipment purchases must be reviewed and approved as part of the budget preparation process.
c. Subcontracts: All cost proposals that include an anticipated award of a subcontract to another entity must include a proposal from the subrecipient. Such proposal will include a budget signed by the subrecipient’s authorized institutional official, a statement of work, and, if applicable, a written statement supporting any cost share commitments.
d. Facilities and Administrative (F&A/Indirect) Costs: The policy of the Commonwealth of Virginia mandates the collection of full indirect costs. The off campus rate is applicable only in those cases where greater than fifty percent of the effort on the project will be conducted off the campus of George Mason University. For the purposes of indirect costs, the “campus” is defined as any property owned or leased by Mason or the George Mason University Foundation. If space is to be rented for the project, then the off campus rate will be applied and rental costs will be budgeted as a direct cost.
e. Internal Distribution of F&A Costs: F&A costs earned on sponsored projects are distributed as follows:
30% to Education and General (E&G) Funds
70% to Research Support Funds
F&A is distributed monthly in accordance with policy set by the Provost’s Office. Any deviation from the normal split must be agreed upon in writing by the persons involved, faculty, department chairs, deans and institute directors, prior to submission of the proposal. When the total recovered F&A exceeds the base amount established in 2004 (adjusted for annual inflation), any recovered F&A above that amount will be distributed to research support funds.
f. Cost Sharing: As a general rule, all project costs should be represented in the project budget. When the sponsor requires that a portion of the cost be supported by the applicant institution, such costs shall be budgeted separately as cost sharing. When cost sharing is not required by a sponsor, any voluntary committed cost share must be reviewed and approved by the Office of Sponsored Programs before including in the proposal.
1. Types of Awards: The University will accept grants, cooperative agreements and most contract types. The University also accepts a variety of unfunded agreements, such as Non-disclosure Agreements, Teaming Agreements, and Memorandums of Understanding, related to externally sponsored activities.
2. Negotiation and Acceptance: Award agreements are negotiated by the Office of Sponsored Programs and are accepted by the Director of the Office for all projects with a yearly value of up to $1,000,000 and by the Senior Vice President for all projects with a yearly value of $1,000,000 or more. Both the Director of the Office Sponsored Programs and the Senior Vice President are delegated signature authority for externally sponsored projects.
3. Notification of PI: Upon acceptance of an award, the Office of Sponsored Programs will notify the PI of the award and establish a sponsored project account (called a fund) for the project.
C. POST AWARD
1. Pre-Award Costs: Some sponsors will allow the institution to incur costs prior to the effective date of the award. In these cases, the Office of Sponsored Programs will approve spending of a portion of the award prior to receipt of the fully executed award document only if the responsible person or academic unit will guarantee covering the expenses. That guarantee must be in writing and must identify the source of funds providing the guarantee.
2. Fund Establishment: The Office of Sponsored Programs establishes sponsored project funds to be used for all project expenditures. PIs are notified by the Office of Sponsored Programs of the fund number and of other pertinent information necessary for the administration of the project.
3. Project Administration:
a. Expenditures: All expenditures on federally sponsored projects are governed by the cost principles detailed in the Federal Office of Management and Budget (OMB) Circular A-21, “Cost Principles for Institutions of Higher Education.” Costs must be allocable (incurred on behalf of the project), allowable (allowed by the terms of A-21), and reasonable. In addition, state and institutional policies governing cost must be consistently applied to all University funds – i.e., E&G funds, auxiliary funds, all sponsored program funds, etc. PIs are responsible for monitoring the costs on their projects on a regular basis and are held responsible for cost overruns. All expenditures in excess of $2,000, travel costs, food and beverage, MasterCard, subcontract expenses and journal vouchers that are to be charged against a grant/contract account must be approved for allowability, allocability, and consistency by the Office of Sponsored Programs. All mandated and voluntary committed cost shared expenditures must be identified by activity code and tracked in the university’s financial management system.
b. Project Management: All federal grants shall be administered in compliance with OMB Circular A-110 and specific funding agency policies. Circular A-110 includes, but is not limited to, cost sharing or matching, program income, financial reporting and retention and access requirement for records. The University shall ensure that appropriate policies and procedures are in place to meet audit standards implemented under OMB Circular A-133.
c. Subcontracts: The Office of Sponsored Programs will prepare and negotiate a subcontract with the subrecipient organization(s) included in the original proposal. The PI of the project is responsible for monitoring the work of the subcontractor organizations. The Office of Sponsored Programs will monitor the allocability of cost and ensure compliance with subrecipient monitoring policies and procedures.
d. Cost Transfers: A cost transfer or expenditure adjustment is defined as any cost/expenditure transfer transaction. The policies governing cost transfers apply to all sponsored programs accounts. All requests for cost transfers must be approved by the Office of Sponsored Programs to avoid cost disallowances. See University Policy Number 4005 – Cost Transfer Policy that addresses cost transfers to federally sponsored projects.
e. Changes to the Project: While some changes may be made to a project without the approval of the sponsoring agency, many require approval. Whenever a change in time period, deliverable schedules, scope of work, budget or personnel is contemplated, the Office of Sponsored Programs should be contacted to initiate formal communication with the sponsor and update University records.
f. Project Reporting
1) Technical Reports: The PI is responsible for submitting technical reports as specified within the grant, cooperative agreement or contract. When this requirement is not met, the agency may withhold further awards to the PI, and, to the University. It may withhold payment of invoices, or take legal action.
2) Financial Reports: The Office of Sponsored Programs will prepare or assist in the preparation of financial reports. All financial reports to the sponsoring agency must be submitted through the Office of Sponsored Programs.
g. Certification of Time (Effort Reporting): OMB Circular A-21, “Cost Principles for Educational Institutions” requires that faculty certify to the effort which they devote to sponsored projects. The Mason system to certify sponsored project effort uses a budgeted estimate of activities to make payroll charges and then documents, after the fact, the actual distribution of effort among activities among each sponsored agreement (plan confirmation). If there are changes from the earlier budgeted estimate, a labor distribution adjustment must be initiated by the PI. The certification to effort by a faculty member is a legal certification and must in all cases be defensible on audit.
h. Project Close Out: Beginning with three months prior to the end of the sponsored agreement, the Office of Sponsored Programs notifies the PI regarding the financial status of the funds and requests prompt clearing of all obligations.
D. SPECIAL ISSUES IN SPONSORED PROGRAMS
1. Human Subjects: All research activities involving human subjects (as defined in 45 CFR 46) that are directed by a Mason faculty member, staff member, or student or that involve Mason faculty, staff, or students as subjects, must be submitted to the Office of Research Subjects Protections for review and approval by the Human Subjects Review Board.
2. Research with Animals: All research with animals at Mason must be carried out under the supervision of a Mason faculty member qualified and experienced in the type of work being conducted, who assumes responsibility for the legal and ethical conduct of the work. All research involving vertebrate animals must be must be submitted to the Office of Research Subjects Protections for review and approval by the Institutional Animal Care and Use Committee.
3. Biosafety Compliance: All instructional and research projects involving biohazardous materials, recombinant DNA, and biologically-derived toxins must be reviewed by the Institutional Biosafety Committee for compliance with NIH guidelines, as well as George Mason University policies and procedures. This review is facilitated through the use of the Project Review Form available from the Office of Laboratory Safety.
4. Radiation Safety Compliance: All instructional and research projects involving sources of ionizing radiation or x-ray producing devices must be reviewed by the Radiation Safety Committee for compliance with NRC regulations, as well as George Mason University policies and procedures. This review is facilitated through the use of the Project Review Form available from the Office of Laboratory Safety.
5. Research & Scholarship Misconduct: Federal regulations stipulate that the University must comply with federal policy guiding misconduct. In its effort to prevent research fraud and ensure the proper conduct of research Mason has established the Policy on Misconduct in Research and Scholarship which details both the policy and procedures for dealing with an allegation of misconduct.
6. Conflict of Interest: Mason is bound by the State and Local Government Conflict of Interests Act (Sections 2.2-3100, /et seq., /of the Code of Virginia) as enacted by the Virginia General Assembly on August 1, 1987 and as subsequently amended. All Mason employees are subject to this law. See University Policy Number 4001 – Financial Conflicts of Interests in University Contracts with Businesses under Virginia Law.
Additionally, depending on the source of funding, federal conflict of interest rules and regulations may apply. See University Policy Number 62 – Policy for Financial Interests in Sponsored Programs for guidance and refer to sponsor award document for funding agency specific requirements.
7. Classified Research: All research activities involving the use of classified or proprietary information must be reviewed according to the Mason Statement of Policy and Procedures on Classified and Proprietary Research approved by the Board of Visitors on March 28, 1990.
8. Copyrights and Patents: All research activities supported by outside sponsors that involve copyrightable and/or patentable works must be reviewed according to the policies and procedures approved by the Board of Visitors.
E. REPORTING RESPONSIBILITIES
The Office of Sponsored Programs, the only official source of information regarding sponsored programs at Mason, maintains a database on all sponsored programs at Mason. A monthly report of proposal submissions and grant contract awards is made available to chairs, deans, and administrative staff. An annual report describing all sponsored project activity is issued following the end of the fiscal year and published in the University Fact Book. In addition, ad hoc reports are prepared upon request.
Description of the compliance review process and specific authority to impose penalties or other remedies when noncompliance occurs, if applicable.
V. EFFECTIVE DATE AND APPROVAL
The policies herein are effective June 1, 2007. This Administrative Policy shall be reviewed and revised, if necessary, annually. All amendments and additions to this Policy are to be reviewed and approved by the Office of the Provost and the Senior Vice President.
Maurice W. Scherrens
Senior Vice President
Peter N. Stearns
Date approved: June 7, 2007