Award Requirements

A COI disclosure is mandatory for all faculty positions. All named faculty on the project (tenure track, term, research, affiliates, and post docs) should have completed a COI disclosure at the time of proposal. Anyone budgeted as TBD at proposal submission, or individuals added to the project during the period of performance who meet this criterion or who have been identified by the PI as fulfilling an investigator role (independently responsible for the design, conduct, or reporting of research), must submit a COI disclosure before working on the project. Academic units should confirm appropriate COI disclosures have been submitted prior to submitting a request to charge salary to the award. Please see GMU COI and review Mason’s policy on Conflict of Interests University Policy Number 4001.

Misconduct in Research and Scholarship University Policy Number 4007 applies to all full-time and part-time employees of the University, to all persons holding any position affiliated with the university, to all graduate students engaged in research or scholarship activities leading to the generation of reports, conference papers, publications, or creative works in which the university affiliation is indicated, to undergraduate students who are involved in sponsored research, and to all individuals at the university engaged in teaching, research, or scholarship, or under the control of, or affiliated with, the university. Additional information can be found at ORIA Research Misconduct.

Sponsored awards follow Virginia state rules regarding competition. Most purchases are subject to competition. Most purchases under $5,000 can be completed within ten days of submission to the GMU Purchasing Office. Purchases over $5,000 must first be approved by the GMU Purchasing Office. A vendor providing goods, services, or consulting may only begin work after they have received the purchase order and/or contract authorized by the GMU Purchasing Office.

Please review the Purchase, Use, and Disposition of Equipment on Sponsored Awards for information on purchasing and managing equipment acquired with sponsored funds.

FCOI training is mandatory for all named faculty (tenure track, term, research, affiliates, and post docs) on PHS awards. Anyone budgeted as TBD at proposal submission, or individuals added to the project during the period of performance who meet this criterion must complete the FCOI training before working on the project. Academic units should confirm appropriate FCOI training has been completed prior to submitting a request to charge salary to the award. Regulations require all personnel on grants from PHS or PHS pass-through funding sources to complete the CITI Program online training mini-course. Please contact ORIA for questions.

Payroll Certification is a project-based method of certifying effort on federally sponsored projects to certify that salary charges are reasonable in relation to work performed. Payroll Expense Reports will be generated 60 days after the last day of the month for the project anniversary date or project end date, whichever is earlier. The PI is responsible for reviewing charges and committed cost sharing for personal services annually, certifying that all individuals worked on the project, and salary charges were reasonable in relation to work performed. Wages are verified by the approval of submitted timesheets. Please review Mason’s Policy on Payroll Certification on Federally Sponsored Projects University Policy Number 4015.

For federal grants, a reduction of PI effort, generally by 25% of proposed effort, constitutes a change of scope for the project and requires sponsor approval. Please refer to your notice of award for more information.

Cost transfers must comply with the University Cost Transfer Policy. Transfers 120 days or greater will only be approved if there are extenuating circumstances. Please review Mason’s Cost Transfer Policy University Policy Number 4005.

Inventions resulting from federally funded research need to be timely reported to your funding agency. Therefore, researchers need to file invention disclosures with the Office of Technology Transfer (OTT) as early as possible. See OTT for additional information.

Travel on sponsored projects to foreign countries supported by federal grants and contracts is subject to the “Fly America Act” (49 U.S.C. 40118; https://www.gsa.gov/policy-regulations/policy/travel-management-policy-overview/fly-america-act). The “Fly America Act” provides that federal domestic grantees should use U.S. flag air carriers to the maximum extent possible when commercial air transportation is the means of domestic travel or travel between the U.S. and a foreign country or between foreign countries. This requirement shall not be influenced by factors of cost, convenience, or personal travel preference. 

A U.S. flag air carrier service may include service provided under a Code Share Agreement with a foreign air carrier when the ticket, or documentation for an electronic ticket, identifies the U.S. flag air carrier’s designator code and flight number.  This requirement applies to all GMU personnel, students, trainees, consultants, and collaborators that are reimbursed for air travel on federally sponsored awards. The Fly America Act Certification of Exception should be submitted in Mason Finance Gateway with the request for reimbursement if there is an allowable exception for use of a foreign carrier. If any segment of the trip is on a foreign carrier, appropriate documentation to support an exception must be provided (these may include travel itineraries from travel agents or results from online travel booking services from the booking day listing the available flights). The Fly America Act Decision Tree can be utilized to determine when exceptions may be allowable.

The Office of Management and Budget (OMB) mandated awarding agencies adopt recent revisions to 2 CFR 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (“Uniform Guidance”). This became effective December 26, 2014 for all federal agencies and applies to federal award recipient organizations including institutions of higher education.

Agency implementation statements provide specific details on how participating agencies are implementing the revised Research Terms and Conditions (RTCs). In accordance with this requirement, the updated RTCs, which implement the changes to 2 CFR 200, will be fully effective beginning November 12, 2020. This includes all supplemental appendices (Appendix A Prior Approval Matrix, Appendix B Subaward Requirements, and Appendix C National Policy Requirements).

Uniform Administrative Requirements establishes the rules on which most sponsor and university policies and procedures are based including rebudgeting, prior approvals, extensions, equipment procurement, and reporting requirements. For more information, please see 2 CFR 200 Subpart D.

Under Cost Principals, costs generally considered F&A costs (administrative salaries, local phone, office supplies such as pens, paper, toner cartridges, etc.) are generally unallowable unless there are clear exceptional circumstances and prior approval was granted by the University and the sponsor. For more information, please see 2 CFR 200.56.

Research Terms and Conditions Appendix A Prior Approval Matrix provides a listing of the prior approval requirements in the Uniform Guidance and which federal agencies require or waive prior approval.