Sponsored Programs Administration

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University Policy Number 4006

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I. SCOPE

This policy applies to all George Mason University (University) employees. .

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 (OSP).  Faculty and staff are not authorized to commit the institution through proposal submission or contract or grant acceptance.

III. RESPONSIBILITIES

OSP is charged with providing guidance and support to the University community in its research efforts by creating an administrative environment that ensures the University’s financial and contractual obligations are protected.

A. PRE-AWARD

1. Identification of Funding Sources: The Office of Research 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 and 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 OSP.

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 subrecipient proposal information.  OSP 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.  Proposals must be submitted to OSP four days prior to the sponsor deadline to ensure sufficient lead time for review, approval, and preparation of the proposal package.

c. Proposal Review: All proposals must be reviewed and approved by the appropriate University officials and OSP prior to submission to the sponsor.

d. Submission of the Proposal: All proposals submitted under the University name must be formally submitted by OSP.  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, Cost Principles for Educational Institutions.

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 federally negotiated fringe benefit rates.   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 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 F&A rate approved by the University’s federal cognizant agency, Office of Naval Research, is charged on all sponsored projects.  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 the University 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 twice each month in accordance with policy set by the Provost’s Office.  Any deviation from the normal allocation must be agreed upon in writing by the persons involved, including 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, 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 OSP before including in the proposal.

B. AWARD

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 OSP and are accepted by the Associate Vice President for Research Operations for all projects with a yearly value of up to $1,000,000 and by the Senior Vice President for Administration and Finance for all projects with a yearly value of $1,000,000 or more.  Both the Associate Vice President of Research Operations and the Senior Vice President for Administration and Finance are delegated signature authority for externally sponsored projects.

3. Notification of PI: Upon acceptance of an award, OSP will notify the PI of the award and establish a sponsored project fund.

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, OSP 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 guarantees covering the expenses.  That guarantee must be in writing and must identify the source of funds providing the guarantee.

2. Fund Establishment: OSP establishes sponsored project funds to be used for all project expenditures.  PIs are notified by OSP 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 $5,000, personnel transactions, food and beverage , subcontract expenses and journal vouchers over $200 that are to be charged against a sponsored fund must be approved for allowability  and consistency by OSP.  All mandatory 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, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations, 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, Audits of States, Local Governments, and Non-Profit Organizations.

c. Subcontracts: OSP 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 as described in Policy 4009 – Subrecipient Monitoring Policy.

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 OSP to avoid cost disallowances.  See Policy 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, OSP 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: OSP will prepare or assist in the preparation of financial reports.  All financial reports to the sponsoring agency must be submitted through OSP.

g. Certification of Time (Payroll Certification): OMB Circular A-21 requires that faculty certify to the effort which they devote to sponsored projects.  Policy 4015 – Payroll Certification on Federally Sponsored Projects describes the system used by the University to certify salary expenses charged to federally sponsored projects.    If there are personnel changes from the earlier budgeted estimate, a labor distribution adjustment must be initiated by the PI.  The certification to labor charges by a PI is a legal certification and must in all cases be defensible on audit.

h. Project Close Out: Beginning three months prior to the end of the sponsored agreement, OSP 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) in which a University faculty member, staff member, or student is engaged as a researcher  must be submitted to the Office of Research Integrity and Assurance for review and approval by the Institutional Review Board.  All human subjects projects must be carried out under the supervision of a University faculty member qualified and experienced in the type of work being conducted, who assumes responsibility for the legal and ethical conduct of the work.

2. Research with Animals: All research with animals conducted by a University faculty member, staff member, or student must be carried out under the supervision of a University 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 Integrity and Assurance for review and approval by the Institutional Animal Care and Use Committee.

3. Biosafety Compliance: All instructional and research projects involving biohazardous materials, recombinant or synthetic nucleic acid molecules, and biologically-derived toxins must be reviewed by the Institutional Biosafety Committee for compliance with NIH guidelines, as well as University policies and procedures.  This review is facilitated through the use of the Project Review Form available from the Environmental Health and Safety Office.

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 University policies and procedures.  This review is facilitated through the use of the Project Review Form available from the Environmental Health and Safety Office.

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, the University has established Policy 4007 – Misconduct in Research and Scholarship, which addresses both the policy and procedures for dealing with an allegation of misconduct.

6. Conflict of Interest: The University 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 University employees are subject to this law.  See Policy 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 Policy 4010 – Financial Conflicts of Interest in Federally Funded Research 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 University 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 external sponsors that involve copyrightable and/or patentable works must be reviewed according to Policies 4002 – Copyright in University Works and 4003 – Patenting University Inventions.

E. REPORTING RESPONSIBILITIES

OSP, the only official source of information regarding sponsored programs at the University, maintains a database on all sponsored projects at the University.  A quarterly report of proposal submissions and sponsored awards is distributed to chairs, deans, and administrative staff.  Sponsored proposal, award and expenditure data also is available to academic units from the Sponsored Programs Data Mart.  An annual report describing all sponsored project activity is issued following the end of the fiscal year and published in the University Fact Book.

IV. EFFECTIVE DATE AND APPROVAL

The policies herein are effective March 1, 2014.  This Administrative Policy shall be reviewed and revised annually, if necessary.  All amendments and additions to this Policy are to be reviewed and approved by the Office of the Provost and the Senior Vice President for Administration and Finance.

Approved:

__/S_____________________
Maurice W. Scherrens
Senior Vice President

__/S______________________
Peter N. Stearns
Provost

Date approved: June 7, 2007

Reviewed: February 21, 2014