- 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.
Guide to Roles and Responsibilities
National Aeronautics and Space Administration (NASA)
National Science Foundation (NSF)
- Review Mason’s policy on Misconduct In Research and Scholarship at University Policy No. 4007
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)
Department of Justice (DOJ)
Firm Fixed Price Agreements
- Review Mason’s policy on Fixed Price Agreements at University Policy No. 4013
- Mandatory Cost Share- Required by the sponsor as a condition of receiving an award.
- 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 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
- 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.
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.
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.
Absence or Change of the PI or Other Key Personnel
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.
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.
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.
These include regulations for research with:
- Human Subjects (IRB)
- Animal Care and Use (IACUC)
- Export Controls
- Biological Safety
- Chemical Safety
- Radiation Safety
In addition, GMU must demonstrate that it has established institutional policies and procedures for:
- Sexual Harassment
- Misconduct in Research
- Financial Conflict of Interest
- Maintenance of a Drug Free Workplace
Contact your OSP Research Administrator if there are any questions regarding PI responsibilities under these regulations.
- 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
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.
Office of Management and Budget (OMB) Uniform Guidance
George Mason University Foundation (GMUF) Funding
- Review Mason’s policy on Private Sector and Foundation Funding to George Mason University and the George Mason University Foundation, Inc. at University Policy No. 4008
- Overview of Policy 4008 and Procedures
- Procedures for Acceptance and Administration of Policy 4008