What are the roles and responsibilities PI, dean, and department have toward externally sponsored projects?
PI’s identify opportunities for sponsored research and work with their department chairs and deans to ensure they are able to support the proposed research. OSP assists with proposal preparation, compliance, and award management. Details on responsibilities throughout the sponsored lifecycle can be found in the Guide to Roles and Responsibilities for Externally Sponsored Projects.
I anticipate receiving a new award but we have not yet received the fully executed agreement. Can OSP set-up a sponsored fund in anticipation of this fully executed agreement?
An at-risk fund is an option in cases where we are confident funding will be received, and the PI requires a fund number to process personnel paperwork and initiate spending. In these cases, if the PI or unit official can provide a non-sponsored funding source as a guarantee, OSP will establish a sponsored fund with an At-Risk status. The proposal must complete the routing process and any required approvals (i.e. human subjects) must be in place before setting up an at-risk fund. Only 25% or less of the funds can be budgeted at this stage and for no more than 3 months.
I have been awarded a sponsored project that starts in the future, but I need to acquire a major piece of equipment for the project now. Is this allowable?
Some projects allow for pre-award expenses. However, any costs incurred prior to the award are incurred at the PI’s risk and may not be reimbursed if the sponsor does not allow pre-award spending. A request will need to be made to the sponsor, if the award terms do not specify pre-award expenses are allowable.
When the sponsor asks for the submitting institution's address, do I provide my departmental address?
The address for the Office of Sponsored Programs should be supplied as the applicant address. The address is:
Office of Sponsored Programs
4400 University Drive MS 4C6
Fairfax, VA 22030
Can a PI sign an agreement between an outside party and Mason?
No. The University has delegated signature authority only to certain individuals. The Associate Vice President of Research Operations of the Office of Sponsored Programs has been duly authorized to sign and legally bind the University for agreements up to $1,000,000. Agreements in excess of $1,000,000 must be signed by the Senior Vice President.
Any agreement signed by a PI may be deemed void by the University and the PI may be personally liable for its contents.
What do I need to do to submit a proposal through OSP?
First, the Principal Investigator (PI) or designee should fill out and submit the online Request for Proposal Assignment.
After submitting the request, an OSP grants administrator will be assigned within two business days. The grants administrator will work with the PI during the proposal preparation and submission process.
Can a Principal Investigator (PI) or departmental administrator send a proposal or quote directly to an external sponsor?
All outgoing proposals or quotes must be submitted through OSP for review and approval. OSP is responsible for ensuring contractual arrangements are in compliance with federal, state and university guidelines. Review and involvement at the proposal stage helps to avoid complications at the award stage that may delay award set-up such as using the correct rates (fringe benefits, F&A), and avoiding provisions that cannot be accepted under Commonwealth of Virginia State Law.
My proposal includes foreign visitors. Are there any special considerations for foreign visitors on sponsored projects?
If you or others in your unit are considering inviting an individual or group of individuals from another country to visit Mason in any capacity, in which payment to them or on their behalf is expected, consult with Elena Cirmizi, International Tax Manager, or call 703-993-5223 during the planning stage before any commitment is made or offer is extended. In situations where non U.S. citizens receive any money or benefit in kind, Mason is required to be in compliance with complex tax regulations or risk incurring significant penalties. In some cases (depending on visa type), Mason is not permitted to reimburse or pay expenses for the visitor. The International Tax Office endeavors to work with departments and operating units to make the experience as smooth as possible and to ensure that Mason’s international visitors receive the payments they expect.
Is it possible to submit proposals that exceed the amount of effort a faculty member has available?
Yes. However, if a proposal is awarded that would exceed the amount of effort a faculty member has available; the PI would need to make adjustments to his/her effort commitments to ensure there are not over-commitments and the commitments made to external sponsors are met. Sponsor approval of effort reductions may be required.
Can Emeritus Faculty serve as a PI on a sponsored project?
Yes, an Emeritus faculty member may serve as the PI of a sponsored project; however there will need to be a “PI-of-record” (i.e., department chair or dean) designated on all internal administrative documents.
What is cost sharing?
Cost sharing is the portion of project expenses related to a sponsored agreement that is contributed by parties other than the sponsor and not directly charged to the sponsored project account(s). This may include equipment grants, construction projects, or Interagency Personnel Agreements.
When is cost sharing appropriate?
Cost sharing is appropriate when it is required by the sponsor as a condition for submitting an application and receiving an award.
What are direct costs?
Direct Costs or direct expenses are costs that can be identified specifically with a particular sponsored project, an instructional activity, or any other institutional activity or that can be directly assigned to such activities relatively easily with a high degree of accuracy.
What are the current fringe benefit rates?
Find fringe rates at the Office of Budget and Planning. Refer to Budget Data for current year rates.
What are subject payments and are these payments assessed F&A costs?
Subject payments are payments made to research subjects for purposes of recruitment or encouragement for participation in the project study. Subject payments are direct costs and assessed full F&A.
What are participant support costs?
Participant support are costs for items such as stipends, per diem, travel costs, and/or fees paid to or on behalf of participants or trainees in connection with meetings, conferences, symposia, or training projects. Participant support must be included in the award budget. Participant support may be included or excluded from F&A depending on the award. A separate fund will be set up for participant support costs on an award for accounting purposes. The appropriate account codes must be used for participant support.
What are facilities & administrative (F&A) costs?
The Facilities and Administrative (F&A) rate agreement for FY16 and FY17 has been finalized with the Office of Naval Research, our cognizant agency. Existing sponsored research agreements will not change, but the new rates will be used on awards received beginning July 1, 2014.
What items are excluded from F&A costs in a proposal budget/project?
In accordance with Mason’s negotiated F&A cost structure, the following costs are excluded from the F&A calculation: tuition, graduate health insurance, fellowships, the portion of any subcontract or subgrant in excess of $25,000, equipment over $5,000, space rental and capital expenditures. Here are the current F&A rates.
How do I know when to use the off-campus F&A rate?
The off-campus rate is used if more than 50% of the project effort is carried out off-campus. During the proposal preparation process the determination will be made through communications between the PI and OSP. Here are the current F&A rates.
Do I have to budget the full F&A rate that the University is authorized to include?
F&A costs are real costs and the reimbursement received by the University is used to pay for actual expenses such as buildings, utilities and other research support expenses. Unless the sponsor has a written policy that limits the amount or percentage of F&A costs that can recovered, the University will propose its applicable federally-negotiated rate. If there is a need to request a waiver or reduction in F&A, the PI should follow the F&A waiver process during the proposal preparation process.
What is the proposal routing form?
The proposal routing form is a document that summarizes the main project information for the Principal Investigator, Department Chair/Center Director, and Dean. The PI and appropriate departmental authorities electronically approve the form, indicating approval of the project objectives, budget, faculty time commitments, distribution of recovered F&A costs and authorization of any committed cost-share.
My proposal has been submitted, what are the next steps?
- Carefully review the proposal routing form for accuracy before you approve. If the sponsor funds the proposal, the OSP Award Management team uses information from the routing form for award setup.
- If the proposed project involves human subjects, animal subjects, or hazardous substances, approval by the relevant committee is required prior to award setup. More information is provided on the committee websites:
- — Human Subjects in Research
- — Animal Care and Use (IACUC)
- — Institutional Biosafety
- — Radiation Safety
I received a notice of award from the sponsor, what are the next steps?
- Most sponsors contact OSP with award letters, but on occasion the PI is contacted directly. Forward award notices from the sponsor to your Award Management Team, who will initiate the award setup process.
- Before an award can be accepted on behalf of the university, OSP will review all terms and conditions of the award agreement. Award notices require approval by the university’s authorized organizational representative.
- If the project involves human subjects, animal subjects, or hazardous substances, approval by the relevant committee is required prior to award setup. More information is provided on the committee websites:
- — Human Subjects in Research
- — Animal Care and Use (IACUC)
- — Institutional Biosafety
- — Radiation Safety
Can a PI sign an agreement between an outside party and Mason?
No. The University has delegated signature authority only to certain individuals. The Director of the Office of Sponsored Programs has been duly authorized to sign and legally bind the University for agreements up to $1,000,000. Agreements in excess of $1,000,000 must be signed by the Senior Vice President.Any agreement signed by a PI may be deemed void by the University and the PI may be personally liable for its contents.
How do I hire an hourly employee?
A temporary employee is hired on a full-time or part-time basis and has no continuous status; employed at will.
Use Banner Electronic Personnel Action Form (EPAF) to hire temporary employees.
Can I reallocate the salary for an employee after he/she has already spent time working on a sponsored project?
If the salary is included in the project budget, allowable according to the terms of the award and reflects the actual effort performed by the individual, the salary can be reallocated to the sponsored fund.However, if the transfer is to a federally sponsored fund, the transfer must comply with the cost transfer policy and be made within 120 days from the pay period start date. Over 120 day cost transfers are only approved in extenuating circumstances. Please see the Cost Transfer Policy and additional information on reallocation.
I have received a Payroll Certification Report to verify. What am I signing?
Charges or cost sharing for personal services on all federal projects for research, training, and service must produce an equitable distribution of charges for an employee’s activities and be documented in a method acceptable under OMB Uniform Guidance, Cost Principles for Educational Institutions.
The payroll distribution system reflects salary and wage costs of sponsored project accounts and cost sharing expressed as a percentage of total activities not to exceed 100%. The apportionment of employees’ salaries and wages which are chargeable to sponsored agreements or identified as committed cost sharing is initiated by the principal investigator or designee using the appropriate University personnel services authorization format.
All charges and cost sharing for personal services are based on actual salary charges posted in the accounting system and are supported by documentation such as employment contracts, supplemental appointment letters, and other written guidance.
The PI is responsible for reviewing charges and committed cost sharing for personal services annually (except for hourly employees) and certifying that all individuals worked on the project, salary or wage charges were reasonable in relation to work performed, and special costing requirements were met. Certifications will be distributed annually based on the project budget anniversary or project end date. PIs must return certifications to the Office of Sponsored Programs within 45 days of distribution.
Can separating Mason faculty or staff receive leave payouts from a sponsored project?
The appointment letter will determine if the employee is eligible for a leave payout. If the employee is eligible, it is generally not appropriate to charge the leave payout to a sponsored fund unless the employee has worked on one project during his/her employment at Mason. A sponsored fund should not be charged for a leave payout in excess to the proportion of leave accrued by the employee on that project.
How do I determine my GRA's salary?
Under what circumstances can I charge administrative and clerical salaries to a sponsored project?
On federally sponsored projects, the salaries of administrative and clerical staff should normally be treated as F&A costs according to OMB Uniform Guidance. Direct charging of these costs may be appropriate where a major project explicitly budgets for administrative or clerical services, and individuals can be specifically identified with the project or activity with a high degree of accuracy (OMB Uniform Guidance section §200.413(c).
Exceptional cases that meet the criteria for direct charging should be identified during the proposal process and CAS Form A must be included in the proposal file.
Administrative salaries can be charged to a non-federal sponsored project if approved by the sponsor. Uniformed Guidance does not apply to non-federal sponsored projects.
How do I get Banner Access?
Each local unit is responsible for obtaining Banner access for new employees. Details regarding this process can be found at the Financial Administrative Systems Team (FAST) webpage. As new awards are set-up, OSP requests Banner Access for the PI, Co-PI and Administrator for the newly established sponsored fund to ensure the PI, Co-PI and administrative staff have the ability to access the appropriate sponsored funds.
What are the PI Reports?
The PI Report in MicroStrategy displays Banner financial data for sponsored projects. The PI Report provides a summary for sponsored project funds with the ability to view details for all charges including personnel and direct expenditures. Fund by Month.
How do I purchase goods/services on a sponsored project?
Sponsored projects often have budget restrictions. The project budget and award terms and conditions will determine cost allowability. If there are questions whether an expense is allowable under a specific sponsored project, please contact the Research Administrator. You will need to submit the proper paperwork to OSP for approval if it meets the criteria listed below. OSP will check the sponsored fund for available funds and cost allowability. If it is not a transaction OSP needs to approve it should be sent to Accounts Payable or Purchasing to process. OSP provides a review for the following transactions to sponsored funds prior to going to HR, AP or Purchasing:
- All Personnel Paperwork
- Petty Cash – Initial Paperwork to set up the account
OSP has additional information and procedures for purchasing goods and services.
What is the Fly-America Act? Does it apply to all sponsored projects?
The Fly America Act requires that airfare charged to federally sponsored projects use a US air carrier for international travel unless extenuating circumstances apply. Contact Pat Sperry, Associate Director, Outreach & Systems Administration, prior to booking your flight to discuss exceptions and to provide supporting documentation if needed.
What is an Activity Code and how is it used to keep track of Cost Share?
An activity code is used to track Cost Share on a sponsored project. When OSP receives a project where cost share is budgeted, it is given a unique activity code which is used to track all the cost share expenses correctly in Banner.
A funding change form is used to record University-paid salary expense committed as cost sharing. The activity code, org. number and percentage of effort is recorded along with their other funding sources (there always needs to be 100% effort).
For non-personnel charges, the activity code should be added to paperwork submitted for processing. If for some reason a charge is processed incorrectly without the required activity code, a journal voucher must be submitted to correct.
OSP distributes a monthly cost share report to the appropriate unit administrator. Each unit is responsible for reviewing and ensuring that appropriate cost share charges are being accounted for and that required cost share is met by the end of the project period of performance.
Please contact Heather Scruggs if you have questions.
If I will not be able to complete the project within the period of performance what do I need to do to request a no cost extension?
The PI works with the unit’s Research Administration Manager to process this request. The PI should provide a justification as to why additional time is required.A no-cost extension is not meant to simply “spend out” the remainder of the award, but it should be used if you need more time to work on the project and you have not reached all your goals and original scope of work for the project. Sponsor requirements may vary as to what is required for a no-cost extension request but OSP is available to assist in this process.
How are recovered F&A (indirect) funds used and what types of costs are allowable?
Allocations of recovered F&A (indirect) costs are required to be spent in support of research activities. This includes salaries and wages paid to those directly engaged in activities specifically undertaken to produce research.
There are other costs that may be incurred in support of research.
How is the Provost portion of the F&A (Indirect) recovery used?
Office of the Provost Indirect Budget Review presentation summarizes the amount of Provost F&A (Indirect) recovery and describes how the funds are used.
How do I register for training?
- Click on “Register for Workshops” in the top right corner of the webpage. You will be asked to login with your Mason NetID and Password in order to access the system and register for any of the OSP trainings offered.
Can I request a training session for a group, i.e., department PIs, unit administrators?
Yes, please email Patricia Sperry or call 993-8929 to schedule a customized workshop for your group.
What is the difference between cost-reimbursable and fixed price agreements?
Cost Reimbursable agreements are reimbursed based on actual costs incurred in the performance of the contract. A Fixed-Price agreement provides for a price that is not subject to any adjustment on the basis of the costs incurred in performing the contract. The fixed price amount is associated with a deliverable or deliverables.
Are there provisions that Mason cannot accept in its contracts?
Unfortunately, yes. Because of our unique status as a public educational institution and an agency of the Commonwealth of Virginia, we are bound by limitations and restrictions placed on us by the Virginia General Assembly and Virginia Attorney General. The Contracts Officers are aware of and able to discuss and negotiate these issues with a sponsor on behalf of a PI. Please review Mason’s position on a number of standard contract terms and conditions.
How long does it take to finalize a contract with a sponsor?
Contract negotiations depend on a variety of factors many of which are outside the control of the Contracts Officers performing the negotiation. Some factors that contribute to the time involved are: receipt of information from the PI and/or local unit administrator, responsiveness of sponsors, complexity of legal issues involved, type of sponsor, and whether the sponsor is located in Virginia or not. Often there are multiple versions of the contract exchanged between Mason and the other party. Some negotiations can be protracted, but OSP attempts to provide timely updates to PI and/or administrators.
What responsibilities does a PI have to monitor Subrecipient?
University Policy No. 4009 sets forth the requirements of a PI to monitor their Subrecipient’s technical and programmatic activities. It states that throughout the duration of the subaward, the PI should maintain regular contact, perform site visits, review all technical reports, and review financial and programmatic records to ensure appropriate progress and ensure compliance with subaward terms and conditions.The PI is also responsible for reviewing and approving all Subrecipient invoices. The PI verifies that invoice amounts are consistent with technical progress and that the costs are allowable according to federal, state, university and sponsor requirements.
What determines if an entity is a vendor or subrecipient?
What is a purchase of services agreement?
Purchased Services are payments to vendors for goods or services that do not provide any intellectual contribution to the project or directly participate or collaborate in the research. Examples are: lab analysis, consulting, translation, animal care, computer and media services). Purchased service arrangements should be made through Purchasing and not as a subcontract.
What if a contract involves work with an export controlled technology, a foreign researcher or a foreign sponsor?
If a contract involves work with an export controlled technology, a foreign researcher or a foreign sponsor, please visit the Office of Research Integrity and Assurance web site for additional guidance. OSP works closely with this office to ensure researchers are in compliance with all federal export control laws.”Compliance with these laws is essential as the criminal penalties for a violation are severe.” PIs should familiarize themselves with these requirements to the greatest extent possible and the OSP website is a good place to start.
What is payroll certification?
Payroll certification is an alternative to effort reporting. Payroll certification uses a project-based methodology to certify that charges are reasonable in relation to work performed on federally sponsored projects.
What is the payroll certification process?
- Reports are generated by OSP 60 days after the last day of the month for either the anniversary date or project end date, whichever is sooner.
- Reports are distributed to the payroll certification liaison within each department.
- The payroll certification liaison works with principal investigators to obtain approval, then submits the approved reports to OSP.
- The reports must be returned to OSP within 45 days of distribution.
What is the NSF RCR training, and when should it be taken?
As outlined in the Federal Register, effective January 4, 2010, NSF will require the Authorized Organizational Representative to certify the institution has a plan to provide appropriate training and oversight in the responsible and ethical conduct of research. In order to meet the NSF regulations, all undergraduates, graduate students and postdoctoral researchers involved in NSF funded projects or using resources funded by NSF projects must successfully complete the CITI RCR course prior to working on the NSF funded project.
While this certification is required at the time of proposal submission, the specific plans do not need to be submitted at that time. Still, plans must be in place as they are subject to review upon request by NSF.
How is a subcontract created and setup?
Once it is known that a subcontract needs to be created the contracts team gathers that documentation and negotiates the details with the subcontractor. Once everything is approved and signed off, the subcontract is then created in Banner as an encumbrance number, always starting with an “E” followed by the fund number and then a specific number to follow the sequence of subcontracts already in that particular fund.
I received a subcontract invoice from OSP, what do I do?
The PI is responsible for reviewing invoices submitted by the subrecipient prior to payment. Subcontractors to Mason send invoices to the accounts payable department where they log the invoices and submit them to OSP. OSP follows a process for subrecipient monitoring that ensures compliance with federal, sponsor and university guidelines and regulations. OSP reviews proposal submissions to assure subaward arrangements are appropriately budgeted in the prime award budget and the appropriate representations, certifications and assurances are in place. The invoices are then sent to the PI for approval. The PI should verify that invoice amounts are consistent with technical progress and that costs are allowable according to federal, state, university and sponsor requirements. The PI review should take place within 15 days of receipt, and Accounts Payable should be contacted to hold payment if any discrepancies are identified.
What responsibilities does a PI have to monitor Subrecipient?
University Policy No. 4009 sets forth the requirements of a PI to monitor their Subrecipient’s technical and programmatic activities. It states that throughout the duration of the subaward, the PI should maintain regular contact, perform site visits, review all technical reports, and review financial and programmatic records to ensure appropriate progress and ensure compliance with subaward terms and conditions. The PI is also responsible for reviewing and approving all Subrecipient invoices. The PI verifies that invoice amounts are consistent with technical progress and that the costs are allowable according to federal, state, university and sponsor requirements.
Can a faculty member serve as a consultant or subcontractor on a grant held by another faculty member?
No. A Mason faculty member cannot serve as a consultant on a sponsored project awarded to Mason, but may serve as a faculty associate or co-principal investigator on the sponsored project of another Mason faculty member. Funding change forms should be submitted to accurately reflect effort expended.
What is required to include a subcontractor on a proposal?
A subcontractor will need to provide a statement of work, letter of commitment, budget, budget justification and complete a Federal Demonstration Project subrecipient data form. There may also be cases in which the subcontractor will also need to provide biosketches and current and pending support documentation.