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.
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 I serve as Principal Investigator on a project I am proposing?
In order to serve as PI, an individual must hold one of the following types of appointments: (1) a tenured appointment, (2) a tenure-track appointment, or (3) a full-time fixed term appointment as a member of the instructional, research, or clinical faculty, or (4) an administrative or professional faculty appointment. There are exceptions where a dean or director may assume responsibility for the project and you should contact your team’s assigned Research Administration Manager for additional details in these cases. See University Policy Number 4012 for more information.
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 Services in the Office of Sponsored Programs has been duly authorized to sign and legally bind the University for agreements up to $1,500,000. Agreements in excess of this amount must be signed by the Senior Vice President for Administration and Finance.
Any agreement signed by a PI may be deemed void by the University and the PI may be personally liable for its contents. See the Grant and Contract Fact Sheet under Additional Proposal Resources for more information.
Where can I find the information related to DUNS, Tax ID Number or Congressional District?
This information can be found on the Grant and Contract Proposal Fact Sheet.
Where can I find information on Laboratory Safety policies?
The Office of Environmental Health and Safety (EHS) provides guidance and support on laboratory safety policies, training, and compliance with regulations and industry standards.
What do I need to do to submit a proposal through OSP?
As soon as the Principal Investigator (PI) or designee knows a proposal will be submitted, they must complete 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 to review the solicitation, and assist with the proposal preparation and submission process.
How can I ensure I meet Mason's 4-day internal deadline?
Mason’s internal deadline policy ensures all proposals receive a full compliance review prior to submission. Your internal deadline date is COB 4 business days prior to the submission day, e.g. if the proposal is due 5pm on a Friday, you must submit all documents to OSP by 5pm on Tuesday.
The proposal must be ‘final,’ meaning all required proposal components, as specified by the sponsor, are in ready to submit format. Best practice is to communicate early and finish key pieces, in particular the budget and justification, prior to the 4-day deadline.
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. Some proposals, depending on sponsor requirements may bind the university to terms early on. Review and involvement at the proposal stage helps to avoid complications at the award stage that may delay or prevent award set-up and acceptance, such as using the correct rates (fringe benefits, F&A, etc.) 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.
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.
Can affiliate or adjunct faculty serve as a PI or co-PI on a sponsored project?
Yes, per University Policy 4012, adjunct faculty may serve as PIs or co-PIs if with the approval of the dean of their respective department. Please work with your dean to secure email approval and forward this to your Grants Administrator at OSP as you work on the proposal.
Can graduate students serve as a PI or co-PI on a sponsored project?
University Policy 4012 defines who may serve as a PI, which generally excludes graduate students. However, in limited circumstances a graduate student may be listed as the external PI, e.g. NIH F31/32 proposals. In such cases, an eligible faculty member will be named internal PI of record, typically an advisor.
What is cost sharing?
Cost sharing is the portion of project expenses related to a sponsored agreement 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.
What items can be used as cost share?
Cost shared funds should come from non-sponsored research funding and must be incurred during the period of performance and be directly related to the project. (i.e. A graduate assistant cannot be fully supported as cost share to one project, but working on another).
If it is an unallowable cost on the sponsor budget, it is generally unallowable as cost share. The main exception to this is indirect costs. Some sponsors will not allow indirect expenses to be direct charged to the sponsor budget, but will allow the unrecovered indirect costs to be used to fulfill the required cost share commitment. This requires prior sponsor approval, if not outlined as allowable in the program solicitation.
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 is a Limited Submission Opportunity?
Limited submissions refers to funding opportunities that have a limit to the number of applications an organization can submit. These opportunities require internal selection through an internal review process to determine which proposals can move forward with an application. For more information, on the limited submission process, please contact the Office of Research Development, Integrity and Assurance.
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 adjust his/her effort commitments to ensure there are not over-commitments and the commitments made to external sponsors are met. Effort is tracked at the department level and in some cases, sponsor approval of effort reductions may be required.
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 participant support costs?
Participant support costs provide 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. These expenses do not incur overhead and employees are not able to be designated as participant support.
Mason is required by federal regulations to track these funds separately. It will be assigned a separate fund for accounting purposes, if an award is received that includes this line item.
What is the difference between participant support and human subject payments?
Researchers may often refer to ‘human subjects’ as ‘participants’, however these are not the same kind of costs and must be treated differently. Human 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.
Participant support costs provide for 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, if applicable. These expenses do not incur overhead and Mason employees are not able to be designated as participants.
Mason is required by federal regulations to track these funds separately. It will be assigned a separate fund for accounting purposes, if an award is received that includes this line item.
What is a Conflict of Interest?
A conflict of interest occurs when an individual’s personal interests, such as family, friendships, and financial have the potential to compromise his or her judgment, decisions, or actions in the workplace. For more information on the university’s policy, please see University Policy 4001.
What are indirect/facilities & administrative (F&A) costs?
Indirect costs are expenses not able to be directly allocated to a specific project (i.e. general office supplies, clerical support, facility costs, etc.) The University has a negotiated indirect cost rate agreement with the Office of Naval Research, our cognizant agency, to be applied to all sponsored research budgets. Here is the current Facilities and Administrative (F&A) rate agreement.
What items do not incur F&A costs in a proposal budget?
In accordance with OMB Uniform Guidance, F&A is applied to the Modified Total Direct Cost (MTDC) base. MTDC is defined as the total direct costs less equipment that meets or exceeds the University’s threshold, other capital expenditures, tuition remission, rental costs, scholarships and fellowships, participant support costs, and the portion of each sub-grant and subcontract in excess of $25,000. 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 exerted by the project personnel on a specific project is carried out off-campus. A project is considered off-campus adjacent within 50 miles of the Fairfax campus; outside of that it is off-campus remote. 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. Federal sponsors must follow the Uniform Guidance, section 200.414(c). For non-federal sponsors, 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.
Do federal agencies have to accept our indirect cost rate? Wont I be more competitive if my indirect cost rate is reduced?
Under the Uniform guidance, Federal agencies must accept an applicant’s Federal negotiated indirect cost rate agreement unless they meet the terms in 2 CFR 200.414(c) listed below.
Uniform Guidance 2 CFR 200.414(c)
Federal Agency Acceptance of Negotiated Indirect Cost Rates. (See also § 200.306.)
(1) The negotiated rates must be accepted by all Federal awarding agencies. A Federal awarding agency may use a rate different from the negotiated rate for a class of Federal awards or a single Federal award only when required by Federal statute or regulation, or when approved by a Federal awarding agency head or delegate based on documented justification as described in paragraph (c)(3) of this section.
(2) The Federal awarding agency head or delegate must notify OMB of any approved deviations.
(3) The Federal awarding agency must implement, and make publicly available, the policies, procedures and general decision-making criteria that their programs will follow to seek and justify deviations from negotiated rates.
(4) As required under § 200.204, the Federal awarding agency must include in the notice of funding opportunity the policies relating to indirect cost rate reimbursement, matching, or cost share as approved under paragraph (e)(1) of this section. As appropriate, the Federal agency should incorporate discussion of these policies into Federal awarding agency outreach activities with non-Federal entities prior to the posting of a notice of funding opportunity.
My sponsor won’t pay indirect/ F&A costs. Am I still able to submit; is there a waiver request process?
For federal Sponsors, unless the sponsor meets the criteria of Uniform Guidance section 200.414(c), the University will propose its applicable federally-negotiated rate.
For non-Federal Sponsors, if the sponsor has a written policy referencing limited or no F&A allowable on the budget, GMU is able to proceed and the PI will not need to request a waiver. If a written policy is not in place, the PI will need to follow GMU’s F&A waiver process.
Is there a difference between a Sponsors indirect rate and a Sponsor limit on indirect costs?
Yes. We are only required to confirm to Sponsor limits on recovery of indirect costs under the funding opportunity or per their organizational policies. We do not have to follow the organizations own indirect cost rate. Many non-federal Sponsors will have their own organization indirect cost rate. George Mason has our own federally negotiated indirect cost rate agreement (NICRA) recognized under the uniform guidance that we follow unless a non-federal Sponsor’s solicitation or policies specifically limits indirect cost recovery. Federal Sponsors must follow the Uniform Guidance, section 200.414(c).
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.
Can I use the off campus indirect cost rate if I work off campus (remote work/alternate worksite/telework)?
No. remote work locations, alternate worksites, and telework are not considered off campus.
I am applying for renewal (competitive grant). Do I use the original F&A (indirect costs) rate or the current rate?
The budget should reflect the current F&A rate published at the time of the application.
I am applying for a non-competitive continuation. Do I keep the rates from the original application or change the rates to reflect the current rates?
Once a grant has been awarded, the F&A rate remains the same throughout the non-competitive life of the grant.
I am applying for a supplement. What F&A rate (indirect costs) do I use when calculating the budget?
In most cases you would use the same rate as the main grant unless stipulated by the Sponsor. If the rate used is different from the rate used in the main grant, then the supplement must be set up in a separate fund.
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.
Does a 58.9% overhead mean more than half of my grant goes to indirect costs?
No. F&A is charged as a surcharge on select direct costs, not a fraction of the total grant. In short, the portion that goes to overhead is much lower than this rate implies. For example, for Mason’s the F&A rate of 58.9% of modified total direct costs, the most grant funds that can go to overhead are 35%, and if the award has subrecipients, it could be less than that!
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. Routing is completed electronically through workflow In order to access the workflow, you must be on campus or logged in through VPN. Routing completion is required before an award is able to be setup and the funds are made available to the PI.
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:
- OSP will notify the Principal Investigator once the award has been received and inform them of the next steps in award set up. OSP does not follow up with sponsor after the proposal submission to inquire on the status of proposals or potential awards.
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 firstname.lastname@example.org copying your unit’s research administration manager, 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)
- — Laboratory Safety
4. If you are conducting research involving humans or animals, there are certain ethical and procedural reviews that may be required under Mason and Federal policy. To find out what approvals–if any–are required before you begin a research project involving humans, animals, or both, click HERE.
- 5. If the prime sponsor is a PHS agency or has adopted PHS regulations, all project investigators must complete the Financial Conflict of Interest training program prior to award setup.
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.
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. Contact your team research administration manager for assistance.
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.
Follow these steps and use Banner Electronic Personnel Action Form (EPAF) to hire temporary employees.
The Pooled Position Lookup for temporary appointments is located under the Employee Services Tab in Patriot Web Self Service.
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.
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 the Cost Exemption Request Form 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.
What are the sponsored award requirements when a PI goes on study leave?
This is dependent on the funding agency and if this is considered a long term absence. Formal notification may be required to be submitted to the sponsor and approval may be needed. Policy information can be found in the GMU Faculty Handbook.
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 administration manager. You will need to submit the necessary 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 Angie Railey, Director, Post Award, prior to booking your flight to discuss exceptions and to provide supporting documentation if needed.
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 appropriate solely for the use of unspent funds; it should be used when more time is necessary to complete the scope of work and original project goals. Sponsor requirements may vary as to what is required for a no-cost extension request, and OSP is available to assist in this process.
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.
How do I register for training?
Can I request a training session for a group, i.e., department PIs, unit administrators?
Yes, please email Amanda Fucci-Bartoszek to schedule a customized workshop for your group.
What is the difference between cost-reimbursable and fixed price agreements?
Cost Reimbursable agreements are invoiced in arrears, based on actual costs incurred in the performance of the project. If the total award amount is not fully expended, Mason will neither invoice for nor receive those unspent funds. A Fixed Price Agreement is typically a bit more risky. It provides a specific cost for the completion of the scope of work with associated deliverables. If the work is not able to be completed with the funds provided, no additional funds will be granted yet the PI is still responsible for the completion of work. However, in the event that there are remaining funds, see University Policy 4013 to determine how these funds will be handled.
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. OSP’s contracts administrators 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 standard contract terms and conditions in our Corporate Sponsor Letter.
How long does it take to finalize a contract with a sponsor?
Award negotiations depend on a variety of factors, many of which are outside the control of the Contracts Administrators performing the negotiation. Some factors contributing 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 multiple versions of the contract are exchanged between OSP’s Contract Administrators and the other party. Some negotiations can be protracted, but OSP attempts to provide timely updates to PI and/or administrators.
Please note that if you are in conversations with a sponsor and have not notified OSP prior to your discussions, this may cause delays in processing any award or contract. You should contact OSP at anytime when you begin to engage or are considering engaging a sponsor for funding.
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 to 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 contractor or subrecipient?
A contractor (vendor/purchased service) provides ancillary goods and services that the PI needs to conduct the research effort. They are not responsible for the research results nor do they make programmatic decisions. A contractor typically provides these goods or services as part of their normal business operations to many different purchasers in a competitive environment.
A consultant provides review and analytical services as a one-time event, rather than establishing an ongoing relationship with the university. They provide expertise that is not otherwise available within the university and can be either an individual or a consulting firm. They do not have the ability to influence the direction of the research or the ability to make programmatic decisions. Their role is to produce a work product under the direction of the PI without having a named scientific role in the overall project.
A subrecipient carries out a portion of the prime award and has their performance measured against whether the programmatic objectives of the project were met. They are subject to all requirements specified in the prime award and responsible for programmatic decision-making. A subrecipient may also be identified as a Co-Investigator.
Please see additional information on vendor and subrecipient entities
What are purchased services?
Purchased Services are the goods and services provided by a contractor or consultant on a project and paid via a Purchase Order coordinated through the Purchasing Office. This is distinguished from research efforts provided by a subcontractor and paid under a subcontract administered by OSP. Examples of such services include: lab analyses, consulting services, translation services, animal care, and computer and media services.
What if a contract involves classified work or work with an export controlled technology, a foreign researcher, or a foreign sponsor?
If a contract involves classified work, or work with an export controlled technology, a foreign researcher or a foreign sponsor, please visit the Office of Research Development, Integrity and Assurance for additional guidance. OSP works closely with this office to ensure that all required safeguards are in place and that the university and researchers are in compliance with all federal export control laws before any research may begin. Compliance with these laws is essential as the criminal penalties for a violation are severe.
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.
Is there a minimum or maximum amount of effort that can be proposed?
The university does not have limitations regarding the level of effort proposed. The effort should be a reasonable estimating of the time that will be devoted to the project. For instance 100% effort on sponsored projects would be difficult to justify, since any of the PI’s time spent on other tasks (administrative, etc.) would not be directly allocable to the sponsored project and thus unallowable.
Unless the proposal qualifies as an exception (equipment grants, etc.), some level of effort should be proposed for all senior personnel. The effort should be a reasonable estimate to the level of effort that will be devoted on the project. Any amount unable to fit into the sponsor budget should be documented as cost share.
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 the prime award has been fully executed, the assigned Research Administration Manager will prompt the contracts team that a subagreement will need to be initiated. All documentation will be provided to the contracts team so they are able to reach out to the subrecipient to begin negotiations. Once the subagreement is fully executed, it is then encumbered in Banner on the prime fund.
I received a subcontract invoice from OSP, what do I do?
OSP staff reviews proposal submissions to ensure 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 the invoice amounts are consistent with technical progress and that the costs are allowable according to federal, state, university, and sponsor requirements. The PI review should take place within 15 days of receipt and if any discrepancies are identified, OSP will need to contact Accounts Payable to hold payment.
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 in other capacities, such as a Co-PI. It is important to note the role of all named personnel on projects and identify if they meet the definition of significant contributor/investigator. “Investigator” means any individual, regardless of his or her title or position, whether faculty, staff, or student, who has the ability to make independent decisions related to the design, conduct or reporting of University Research, but not including individuals who perform only incidental or isolated tasks related to a research project.
What is required to include a subcontractor on a proposal?
An organization will need to provide a letter of commitment, scope of work, budget, budget justification, Mason’s Subrecipient Commitment Form, indirect rate agreement and the Virginia Substitute W-9. Sponsors and solicitations may require additional information for included subawardees, such as biosketches, current and pending files, etc. Please work with your team research administration manager to ensure proper documentation is obtained during the proposal preparation process.