Grant Management

  • Labor Expenditures
    This section provides information related to managing personnel expenditures on sponsored projects.
  • Non-Labor Expenditures
    This section provides information related to managing non-labor (direct) and indirect expenditures on sponsored projects.

Management Resources

Guide to Roles and Responsibilities

A chart of who is responsible for managing specific tasks related to sponsored projects.

PI Responsibilities

National Aeronautics and Space Administration (NASA)
In February 2012, NASA began including a clause in all of its agreements and modifications 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.” Therefore, if the PI has any Chinese researchers, student assistants, or subcontractors on the project at this time, or plans to at any time in the future, please contact your OSP Research Administrator for additional guidance.

National Science Foundation (NSF)
All individuals working on NSF projects are required to complete a brief exercise every five years regarding misconduct in research. The PI is responsible for ensuring all individuals supported on the project have completed the exercise, which can be found at GMU Misconduct in Research and Scholarship.

NSF projects are also subject to the NSF Responsible Conduct of Research (RCR) training requirement. All undergraduates, graduate students, and postdoctoral researchers who will be supported by NSF to conduct research should take the RCR training prior to working on the NSF project.

NSF limits salary compensation for senior project personnel to no more than two months of their regular salary in any one year. This limit includes salary received from all NSF funded projects. Additional details are available at NSF Senior Project Personnel Salaries & Wages Policies.

National Institutes of Health (NIH)
The Executive Level II salary cap is currently set at $185,100 effective January 10, 2016. Detailed information can be found at NIH Notice on Salary Limitation on Grants, Cooperative Agreements, and Contracts.

Department of Justice (DOJ)
No Office of Justice Programs (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, and your OSP Research Administrator would need to be contacted for additional guidance.

Firm Fixed Price Agreements
Firm Fixed Price (FFP) agreements have a degree of risk as deliverables must be met even if costs incurred exceed the funded amount. The PI and their unit are responsible for covering any costs incurred in excess of the funded amount. If the funding exceeds the costs incurred, the residual balance will be transferred to the PI pool org after the appropriate overhead charge has been assessed.

Cost Share
Cost share is the portion of project expenditures related to a sponsored project that is contributed by parties other than the sponsor and not directly charged to the sponsored project fund. Types of cost share include:

  1. Mandatory Cost Share- Required by the sponsor as a condition of receiving an award.
  2. Voluntary Committed Cost Share- Offered by the PI by including it in the sponsored project proposal document.

Cost sharing must be proposed, approved, administered, and accounted for in a consistent and prudent manner. This includes understanding workload implications of the cost sharing commitment, determining when cost sharing is appropriate, and accurately recording and reporting cost sharing expenditures.

If a sponsored project includes cost share, use the appropriate non-sponsored organization number with the cost share activity code provided in the project’s OSP award letter to charge and track cost shared expenditures for the project.

Project Review and Reconciliations
The PI is responsible for all expenditures charged to their sponsored projects. It is the PI’s responsibility to ensure all expenditures are appropriate, authorized, charged correctly (using the right account code), and consistent with GMU and sponsor fiscal policies. All discrepancies must be resolved within 30 days of the required reconciliation review.

The PI must sign and date the reconciliation to certify that all charges and credits are allowable, allocable, and reasonable. The PI may not delegate this responsibility.

Reviewing Federally Funded Projects
For federally funded projects, additional restrictions may apply, such as:

  • Cost Transfers: A cost transfer is a transfer of expenses to a federally funded sponsored project for a charge previously recorded elsewhere. Federal projects generally have a fund number that starts with 20.
    Cost transfers over 120 days will only be approved if there are extenuating circumstances. Cost transfers must comply with Mason’s policy on Cost Transfers, University Policy No. 4005.
    For additional information, review Mason’s Cost Transfer Procedures.
  • OMB Uniform Guidance (UG): UG establishes the rules on which most sponsor and university policies and procedures are based including rebudgeting, prior approvals, extensions, equipment procurement, and reporting requirements.
    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 additional information, see OMB Uniform Guidance.
Personnel Expenditures
Funding changes for personnel affiliated with a sponsored project must be processed as soon as possible, but no later than one month after the start of the project. If the sponsored project includes funds to support the PI, and/or other personnel (i.e., research faculty, administrative faculty, classified personnel, graduate research assistants, or wage employees), please work with your unit administrator to charge current GMU employees to the project.

If new employees need to be hired, go to the Human Resources and Payroll website for more information on the hiring process. State and Federal law requires that all personnel selections comply with the Mason’s policy on Non-Discrimination, University Policy No. 1201. For more information, visit the Compliance, Diversity, and Ethics (CDE) website.

PIs are obligated to ensure that all personnel forms (hiring, funding changes, and timesheets) on a sponsored project are submitted in a timely manner. Failure to do so could result in disallowed cost transfers resulting in effort being charged to a non-sponsored funding source.

Payroll Certification
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 sooner.

The PI is responsible for reviewing charges and committed cost sharing for personal services annually and 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.

Payroll Certification.

Absence or Change of the PI or Other Key Personnel
Most sponsors require notification if there will be a change in key personnel or if there will be an extended absence of the PI. If there will be changes in key personnel, the PI must contact your OSP Research Administrator to discuss requirements for informing the sponsor and requesting necessary approvals.
If the PI plans to leave GMU during the period of a project, the PI must contact OSP to discuss how the project will be handled. It may involve the transfer of the project to the new institution or could require that a new PI be approved by the sponsor to handle the project in the PI’s absence. Review the terms and conditions of the project for more details.

Other Direct Expenditures
  • Subcontracts and Subrecipient Monitoring: A subcontractor is a research collaborator to which GMU may assign certain rights (i.e., ownership of intellectual property) and flow-down the terms and conditions and other requirements (i.e., human subjects and OMB Uniform Guidance) from the prime award. Once a subcontract is executed, the PI is responsible for monitoring the subcontractor’s performance and approving invoices for payment. Review Mason’s policy on Subrecipient Monitoring, University Policy No. 4009.
  • Consultants: Consultants must be hired prior to working on the project. Instructions for hiring a consultant can be found at the Fiscal Services website.
  • Travel: All Mason employees traveling on sponsored project funds must follow the state travel guidelines. Information can be found at the Travel Office website. In addition to following state travel guidelines, all travel supported by federal funds must comply with the Fly America Act using U.S. air carriers unless appropriate extenuating circumstances apply as outlined under the Fly America Act and have been clearly documented in advance.
Rebudgeting
Some sponsors allow a certain percentage of funds to be transferred between budget line items without prior sponsor approval. Review the terms and conditions of the project for specific details.
If there are questions about rebudgeting requirements or if sponsor approval is required, please contact your OSP Research Administrator. This post-award authority should be used on rare occasions only and should never be used to circumvent the integrity of the proposal budgeting process.

No-Cost Extensions
A no-cost extension is used if the PI needs more time to work on the project and did not reach all goals and original scope of work for the project. A no-cost extension is not meant to simply “spend out” the remainder of the project funds.
To request a no-cost extension for a project, send the following to your OSP Research Administrator:

  • A request for the extension
  • A justification
  • A new project end date

Most sponsors require the request at least 90 days prior to the end date of the project. The sponsor may or may not approve the carryover of unexpended funds to the next year. Review the terms and conditions of the project for more details.

Overspent Funds
If the project is overspent at the end of the project, all over-expenditures will need to be moved to a non-sponsored source of funding. If a PI does not have sufficient funds to cover the over-expenditures, the overspent amount will be the responsibility of the unit or college.

Regulatory Compliance
As a recipient of state and federal funds, GMU is obligated, by law, to assure that all research activities are conducted in accordance with state and federal rules and regulations.

These include regulations for research with:

In addition, GMU must demonstrate that it has established institutional policies and procedures for:

Contact your OSP Research Administrator if there are any questions regarding PI responsibilities under these regulations.

 

Reporting
  • Technical Reports: Most sponsors require technical progress and final reports. Most sponsors require the PI to submit a final technical report within 90 days of the end date of the project. It is the PI’s responsibility to ensure that the appropriate technical reports are submitted in a timely manner. For auditing purposes, the PI must keep copies of all reports submitted.
  • Financial Reports: Most sponsors require interim financial reports and a final financial report. Most sponsors require the final financial report be submitted within 90 days of the end of the project. OSP generally prepares and submits the financial reports using expenditures charged to the project fund in Banner. If there are questions regarding project expenditures, OSP will contact the PI for clarification prior to report submission. Since financial reporting requirements may vary based on the project, review the terms and conditions of the project for more details.
  • Records/Data: The University will maintain contractual and fiscal records of sponsored activity for a minimum of five years after the expiration of a project. However, it is the responsibility of the PI to maintain the records of research or educational activities including, but not limited to, raw data, graphs, charts, videos, pictures, recordings, and signed informed consent documents for research with human subjects. It is required that these records be maintained in appropriate data books or other filing systems that are signed and dated by the PI and witnessed by another responsible individual. These records are to be kept accessible to permit inspection by authorized representatives of GMU, the sponsor, or agents of the state or federal government during normal business hours. If the PI leaves GMU prior to the completion of this five year period, the PI is authorized to take photocopies of the data. However, the original data will remain at GMU unless GMU is guaranteed access to the data through mutual agreement.
  • Privileged Information: As a part of sponsored project activities, it may be necessary to have access to confidential or proprietary information owned by GMU or the sponsor. Often separate nondisclosure agreements (NDA) are executed to specify restrictions on confidential information between GMU and another party. Typically, funding agreements require that all parties use the same reasonable efforts to protect their own confidential or proprietary information. Only those directly participating in the project activities are allowed access to such information, and only after agreeing to abide by the terms of the funding agreement. It is the responsibility of the PI to ensure that all participants of a sponsored project understand and agree to terms relating to confidential or proprietary information. In some cases, confidentiality clauses or agreements may influence reporting requirements. Review the terms and conditions of the project for more details.
Recovered F&A (Indirect) Costs
The PI will receive a percentage of the recovered F& A charged to the sponsored project. This is typically between 10.29% – 10.5%, but may vary based on agreements made among the recipients designated to receive F&A for the project. The percentage the PI will receive is identified on the Proposal Routing Form at the time the proposal is submitted.
An indirect org will be established for the PI. The PI’s portion of recovered F&A will be transferred to that indirect org twice a month for charges made to the project.
Spending using the indirect org must comply with state spending rules and must be used in support of research. Typically, recovered indirect funds are used to support travel, purchase equipment, support students, or for other traditional research expenditures. Recovered indirect funds may not be used to increase the salary of the PI.

PI Report

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. There are also Fund by Month, Reconciliation by Fund, and data export options.

Reconciliation

Reconciliation is a systematic review of charges and credits posted in Banner against source documents to verify that all charges and credits are accurate and appropriate, and to identify expected charges and credits that have not yet occurred. The PI must sign and date the reconciliation to certify that all charges and credits are allowable, allocable, and reasonable.

Office of Management and Budget (OMB) Uniform Guidance

In 2013, OMB issued final guidance on administrative requirements, cost principles, and audit requirements for federal awards. This guidance will supersede requirements from eight OMB Circulars including A-21, Cost Principles; A-110, Administrative Requirements; and A-133, Audit Requirements.

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George Mason University Foundation (GMUF) Funding

Resources related to GMUF funding: