Award Specific Requirements

The award has a term allowing pre-award spending for the 90 days preceding the award start date.

The award has a future start date. You may not incur expenses prior to the award start date unless the sponsor has authorized pre-award spending. Please refer to the award document and/or sponsor guidelines to determine if pre-award costs are allowable.

The award was funded under a cost reimbursable mechanism. The University is “reimbursed” when actual costs are incurred in carrying out the project up to the sponsor authorized total amount. OSP will submit invoices according to the invoicing schedule specified in the sponsored award agreement.

The award was funded as a fixed price sponsored award agreement. Please review Mason’s policy on Fixed Price Agreements, University Policy Number 4013.

The award is under the authority of the Intergovernmental Personnel Act (IPA), which provides for the temporary assignment of personnel between the Federal Government and colleges and universities, among others. Please refer to your award agreement for additional provisions.

If the award includes cost share/matching funds, use the appropriate non-sponsored fund number with the appropriate cost share activity code provided by OSP to charge and track cost shared expenses for this award. Please review Mason’s policy on Cost Sharing University Policy Number 4016.

The award is subject to a sponsor-imposed salary cap. Individual salaries charged to the award may not exceed the approved salary cap at any time. Please refer to the agency specific guidelines for the current salary cap levels. The salary cap applies to 9-month academic and 12-month calendar year salary as well as shorter term appointments.

The sponsor does not authorize the carryover of funds between project years.

The sponsor requires prior approval for the carryover of funds between project years. You will need to contact the Post Award Research Administrator to request carryover approval prior to the anniversary date of the project.

The sponsor allows the automatic carryover of funds between project years. Unspent funds can automatically move to the next project year without sponsor approval.

Limitation of Funds (LOF) is when a cost reimbursable contract is incrementally funded and requires the university to notify the sponsor when GMU anticipates expending 75% of the funds currently awarded within the next 60 days. Please review the Limitation of Funds FAR clause 52.232-22.

The award is made under Expanded Authorities, which are the operating authorities provided to grantees under certain research grant mechanisms that waive the normally required sponsor prior approval for specific actions. Please refer to your notice of award for more information.

The sponsor imposes restrictions on charging expenditures in a manner inconsistent with the approved award budget. Please refer to your notice of award for more information.

The sponsor either prohibits foreign travel or requires prior approval for foreign travel. Please refer to your notice of award for more information.

The sponsor requires prior approval for travel or imposes additional restrictions on travel. Please refer to your notice of award for more information.

The sponsor requires prior approval for equipment purchases. Please refer to your notice of award for more information.

Title to any equipment purchased under the award vests with the sponsor, not GMU. Please refer to your notice of award for more information regarding purchasing and managing equipment acquired with the sponsored funds.

The fringe benefit rate is restricted under the award. Please refer to your notice of award for more information.

A separate fund has been set up specifically for the purpose of charging participant support costs associated with the sponsored award. Participant support costs are direct 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 costs are excluded from F&A and should be charged to specific participant support account codes. Many sponsors require prior approval to use funds budgeted for participant support costs for other purposes.

If you believe you need to request permission to rebudget, please initiate a modification request in RAMP. Please also review the Participant Support Guidelines and see Pay Participant Support – Fiscal Services.

The award has export control restrictions. You must follow the guidelines of the Technology Control Plan approved by the Associate Director of Export Compliance and Secure Research. Any activity, regardless of funding type, may be subject to export controls if it involves the actual export or deemed export of any item that is either “dual use” (commercial in nature with possible military application) or “inherently military.” Please see ORIA Export Controls.

The award has been identified as involving classified research for which a form DD254 is necessary. Coordination with the Associate Director of Export Compliance and Secure Research is required before any research may begin.

The award has been identified as containing Controlled Unclassified Information (CUI). CUI is federal non-classified information the U.S. Government creates or possesses, or that a non-federal entity (such as GMU) receives, possesses, or creates for, or on behalf of, the U.S Government, that requires information security controls to safeguard or disseminate. These controls must be compliant with the federal regulations specified in 32 CFR Part 2002 and NIST SP 800-171r1. You must follow the guidelines from the Associate Director of Export Compliance and Secure Research for all research conducted. Please see ORIA CUI.

It is anticipated that the award will, or may at a future phase, involve data that is subject to federal safeguarding controls. To ensure continued compliance throughout the life of the award, please keep the Associate Director of Export Compliance and Secure Research updated and follow all guidance provided.

The award is subject to the Small Business Subcontracting Plan FAR Clause 52.219-5. Please reference the SBSP completed at the proposal stage to ensure adherence to the plan when making purchases. All subcontractors will be required to submit an annual SBSP report through the eSRS system.

The award includes a revenue account for program income. The initial budget for the revenue account has been set up for $1.00. Revenue accounts are reviewed on a quarterly basis and budgets are increased based on the amount of revenue deposited. Revenue deposits should be made through the GMU Cash Office using the revenue fund number and appropriate account code (04201 for Federal awards, 04204 for private, 04203 for local, or 04202 for state). Please monitor expenses closely to ensure that expenditures on the revenue fund do not exceed the actual revenue collected.

Unless otherwise specified in the award, per federal regulations 2 CFR 200.307 Program Income requires the University to expend program income funds before spending sponsor funds. Program income must be expended during the period of performance for valid project expenses unless otherwise approved by the sponsor. Costs that would not be allowable under the guidelines of the federal award may not be charged to program income. Please refer to your notice of award for more information.

The sponsored award requires funds to be placed in an interest-bearing account. Please refer to your notice of award for more information.

The award will contain program income. Unless otherwise specified in the award, per federal regulations 2 CFR 200.307 Program Income requires the University to expend program income funds before spending sponsor funds. Program income must be expended during the period of performance for valid project expenses unless otherwise approved by the sponsor. Costs that would not be allowable under the guidelines of the federal award may not be charged to program income. Please refer to your notice of award for more information.

All NASA awards include a “China Restriction” clause which restricts NASA funding from being used to “participate, collaborate or coordinate bilaterally in any way with China or any Chinese-owned company.” Further guidance from NASA interprets “China” to include “Chinese nationals, businesses, and governmental entities (to include Chinese universities).” Therefore, if you have any Chinese researchers, student assistants, subcontractors, or non-Chinese persons with China business or governmental affiliations on the project at this time, or at any time in the future, please notify the Office of Sponsored Programs for additional guidance. See NASA Proposers Guidebook (section 2.2.1).

Effort:
NSF limits salary compensation for senior project personnel to no more than 2 months of their regular salary in any one year. GMU defines a year from the beginning of the academic year until the start of the next, beginning August 25th. This limit includes salary received from all NSF funded grants. Additional details are available at NSF’s Senior Project Personnel Salaries Policy.

The NSF decision to support or not to support a proposed project is based to a considerable extent upon its evaluation of the proposed PI/PD and any identified Co-PI/Co-PD’s knowledge of the field of study and his/her capabilities to conduct the project in an efficient and productive manner. The named PI/PD (and Co-PI/Co-PD) should be continuously responsible for the conduct of the project and be closely involved with the effort. If the PI/PD or Co-PI/Co-PD plans to or becomes aware that he/she will: (i) devote substantially less effort to the project than anticipated in the approved proposal; (ii) sever his/her connection with the grantee organization; or (iii) otherwise relinquish active direction of the project, please initiate a modification request in RAMP. More information can be obtained at PAPPG Chapter VII B2.

Notification Requirements Regarding Harassment and Sexual Assault:
NSF has an award term and condition regarding sexual harassment that requires the University to notify NSF promptly of findings of “sexual harassment, other forms of harassment, or sexual assault” against an NSF-funded principal investigator (PI) or Co-PI, as well as interim administrative actions imposed by the University (e.g., administrative leave or curtailment of certain University duties). More information can be obtained at: NSF, Term and Condition: Sexual Harassment, Other Forms of Harassment, or Sexual Assault or PAPPG Chapter XI – Other Post Award Requirements and Considerations. Please review Mason’s policy on Federal Awards Harassment University Policy Number 4020.

NSF-Sponsored Conferences:
Per NSF’s Proposal and Award Policies and Procedures Guide (PAPPG) effective October 4, 2021, NSF will require conference proposers to have a policy or code-of-conduct that addresses sexual harassment, other forms of harassment, and sexual assault, and that includes clear and accessible means of reporting violations of the policy or code-of-conduct. This policy or code-of-conduct must be disseminated to conference participants prior to attendance at the conference and made available at the conference itself. Please review Mason’s policy on Federal Awards Harassment University Policy Number 4020. Specific questions regarding the NSF term and condition can be directed to sexualharrassmenttandc@nsf.gov. Please also see NSF’s Frequently Asked Questions (FAQs).

Salary Cap:
The Consolidated Appropriations Act of 2022, Public Law 117-103, signed into law on March 15, 2022, restricts the amount of direct salary which may be paid to an individual under an HHS grant, cooperative agreement, or applicable contract to a rate no greater than Executive Level II of the Federal Executive Pay Scale. Effective January 1, 2023, the Executive Level II salary level is $212,100. More information can be found at NIH Notice NOT-OD-22-076.

NIH Other Support and Identifying Foreign Components:
NIH Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant. This includes but is not limited to:

• Resources and/or financial support from all foreign and domestic entities, that are available to the researcher. This includes but is not limited to, financial support for laboratory personnel, and provision of high-value materials that are not freely available (e.g., biologics, chemical, model systems, technology, etc.). Institutional resources, such as core facilities or shared equipment that are made broadly available, should not be included in Other Support, but rather listed under Facilities and Other Resources.
• Consulting agreements, when the PD/PI or other senior/key personnel will be conducting research as part of the consulting activities. Non-research consulting activities are not Other Support.
• In-kind contributions, e.g. office/laboratory space, equipment, supplies, or employees or students supported by an outside source. If the time commitment or dollar value of the in-kind contribution is not readily ascertainable, the recipient must provide reasonable estimates.

Other support does not include training awards, prizes, or gifts. Gifts are resources provided where there is no expectation of anything (e.g. time, services, specific research activities, money, etc.) in return. An item or service given with the expectation of an associated time commitment is not a gift and is instead an in-kind contribution and must be reported as such. Effective January 25, 2022, NIH requires the following:

• Supporting documentation, which includes copies of contracts/agreements specific to senior/key-personnel foreign appointments and/or employment with a foreign institution for all foreign activities and resources that are reported in Other Support. If the contracts/agreements are not in English, recipients must provide translated copies.
• Immediate notification of undisclosed Other Support. When a recipient organization discovers that a PI or other Senior/Key personnel on an active NIH grant failed to disclose Other Support information outside of Just-in-Time or the RPPR, as applicable, the recipient must submit updated Other Support to the Grants Management Specialist named in the Notice of Award as soon as it becomes known.

NIH Notice NOT-OD-21-073 informs the extramural community that NIH has updated its application forms and instructions to support the need for applicants and recipients to provide full transparency and disclosure of all research activities, foreign and domestic.

NIH Notice NOT-OD-21-110 describes implementation of the updated Other Support and Biosketch format pages and associated instructions. Please contact Chris DiTeresi or Mike Laskofski if you would like assistance in determining what relationships and support you must disclose, or should consider disclosing, and the best way to do so. ORIA has information concerning sponsors’ requirements, enforcement developments, congressional consideration of these issues, and similar topics.

NIH Grants Policy Statement:
All NIH grants and cooperative are subject to the NIH Grants Policy Statement (December 2021 version, see Summary of Significant Changes).

Annual Progress Reports:
NIH requires use of the RPPR module in eRA Commons to submit all annual progress reports. A Commons ID is required for all individuals with a postdoctoral, graduate, or undergraduate role. The Commons ID is also required for individuals supported by a Reentry or Diversity Supplement. For all other project personnel, the Commons ID is strongly encouraged but currently optional. AHRQ only requires a Commons ID for individuals in a postdoctoral role. If you are planning to hire a new employee on an NIH project and are not sure if they have a Commons ID, please contact the Manager of Billing & Reporting.

Good Clinical Practice training (GCP):
Since January 1, 2017, all investigators involved in the design, conduct, or reporting of clinical trials have been required to take GCP Training. The University offers training available to meet this need as part of the CITI Program online training. There are two different CITI GCP courses available: one that focuses on social behavioral research and one that focuses on clinical trials involving investigational drugs and medical devices (FDA focused). Researchers may choose the course that best meets their needs. Please contact ORIA for questions.

Travelers using DOD funds must use a U.S. flag air carrier, unless they qualify for an exemption as noted in Federal Travel Regulation Guidelines 41 CFR 301-10.135, sections (a), (d), (e), (f), and (g). Travelers using DOD funds are not permitted to take advantage of Open Sky Agreements. Use the GMU “Fly America Act” Decision Tree to determine eligibility prior to booking your flight. Appropriate documentation to substantiate exceptions must include either travel itineraries from travel agents or online travel planning services on the booking day.’

Food and Beverage Expenditures:
No OJP funding can be used to purchase food and/or beverages for any meeting, conference, training, or other event. Exceptions to this restriction may be made only in cases where such sustenance is not otherwise available (i.e., extremely remote areas), or where a special presentation at a conference requires a plenary address where there is no other time for sustenance to be attained. Such an exception would require prior approval from OJP.

Salary Cap:
You may not use DOJ grant funds to pay cash compensation (salary plus bonuses) to any employee at a rate that exceeds 110% of the annual salary payable to someone at the Federal Government’s Senior Executive Service (SES) level, the DOJ salary cap amount is $233,310.00 for 2023. A recipient may compensate an employee at a higher rate, provided the amount in excess of the limitation is paid with non-Federal funds.

DOJ requires recipients to submit a budget modification request if:

• The proposed cumulative change is greater than 10% of the total award amount (the 10% rule does not apply to awards less than $250,000.00)
• The budget modification changes the scope of the project (examples include adding a new subcontractor, changing the project site, contracting or transferring award-supported efforts, and altering the purpose of the project).
• The budget adjustment would add a new cost category that was not included in the original approved budget.
• Any dollar increase or decrease to the indirect cost category regardless of the amount.
• Moving funds from one subrecipient to another.

DOJ requires prior approvals for some other types of costs, including:

• Compensation for consultant services in excess of $650 per 8-hour day, or $81.25 per hour
• Sole source procurements in excess of $150,000
• Publication plans
• Purchase of Automatic Data Processing, or ADP, equipment and software
• Costs incurred prior to the date of the subaward period
• Foreign travel

Prior approval must be obtained before making of the above budget changes or purchases in the identified categories. For more information, refer to section 3.6 Costs Requiring Prior Approval of the OJP Financial Guide. If you need to request approval from DOJ, please initiate a modification request in RAMP.

Misconduct in Research and RCR:
All individuals, including program directors, faculty, undergraduate and graduate students, postdoctoral researchers, and staff, working on NIFA/USDA projects are required to receive appropriate training and oversight in the responsible and ethical conduct of research and that documentation of such training will be maintained. The PI is responsible for ensuring all individuals supported on the project have completed the exercise, which can be accessed at ORIA Research Misconduct. Additionally, the project is subject to the NSF Responsible Conduct of Research (RCR) Training requirement. More information can be obtained at ORIA Responsible Conduct of Research.

Salary Cap:
You may not use NIFA/USDA grant funds to pay cash compensation (salary plus bonuses) to any employee at a rate that exceeds the annual salary payable to someone at the Federal Government’s Executive Service Level IV salary range, $183,500 for 2023. A recipient may compensate an employee at a higher rate, provided the amount in excess of the limitation is paid with non-Federal funds.