Managing Sponsored Awards and Expending Funds

Please review Mason’s policy on Sponsored Programs Administration University Policy Number 4006.

OSP has entered the award budget into a unique account called a “fund.” This fund is viewable in MicroStrategy using the PI Report. The MicroStrategy Quick Guide: Running the PI Report tells you how to access the PI Report and view your project fund. Please compare your awarded project budget and the budget entered into Banner via the PI Report. If there are discrepancies, contact the Post Award Research Administrator immediately. You must use the fund number associated with the project when charging expenses.

You are responsible for all expenditures charged to the sponsored project. As the PI, it is your responsibility to ensure all expenditures are appropriate, authorized, charged correctly (using the correct account code), and consistent with University, state, and sponsor fiscal policies. All sponsored funds must be reconciled in a timely manner on a monthly or bi-monthly basis (period). Reconciliations must be prepared, approved, and PI certified no later than two months after the last day of the reconciled month/period. Except in extenuating circumstances, reconciling items should generally be resolved no later than three months from the last day of the reconciled month/period. Please review Mason’s policy on Reconciling Departmental and Sponsored Fund Accounting Records University Policy Number 2114.

Funding changes for personnel affiliated with the award must be processed as soon as possible, but no later than 60 days after the start of the project. If the award includes funds to support you and/or other personnel (i.e., faculty, research faculty, administrative faculty, classified personnel, graduate research assistants, or wage employees), please work with your department administrator to charge current Mason employees to the project. If you need to hire new employees, please work with your department administrator on the hiring process.

As PI, you are obligated to ensure that all personnel forms (hiring, funding changes, and timesheets) on this project are submitted in a timely manner. Failure to do so could result in disallowed salary and wage transfers resulting in effort being charged to a non-sponsored funding source. State and Federal law requires that all personnel selections comply with the Mason Affirmative Action program.

To be eligible for employment, new personnel must complete an I-9 form, verify citizenship status, and have the appropriate work authorization papers. PIs must disclose the hiring of immediate family members to the University (OSP) and the sponsor at the time of proposal or to the University (OSP) for any subsequent hiring actions. Generally, it is not acceptable for an investigator to be in a position of authority over an immediate family member (including serving as a PI or Co-Investigator on a project paying the family member).

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, please contact the Post Award Research Administrator to discuss requirements for informing the sponsor and requesting necessary approvals. If you plan to leave the University during the period of your award, you must contact OSP to discuss how your project will be handled. It may involve the transfer of your project to your new institution or could require that a new PI be approved by the sponsor to handle the project in your absence.

Business meals are not an allowable charge on federally sponsored funds. Please review Mason’s policy on Travel, Meals, and Entertainment Expenditures University Policy Number 2101.

Once subcontracts are executed on the award the PI is responsible for monitoring the subcontractor’s performance and approving invoices for payment. Please review Mason’s Subrecipient Monitoring Policy University Policy Number 4009.

Consultants must be hired prior to working on the project. Please see Hire a Consultant for additional information.

All Mason employees traveling on project funds must follow Virginia state travel guidelines. Please see the GMU Travel Office for additional information.

Some sponsors allow a certain percentage of funds to be transferred between budget line items without sponsor approval. Please refer to your notice of award for more information. If there are questions about rebudgeting requirements or whether or not sponsor approval is required, please contact the Post Award Research Administrator. To submit a revised budget request, please initiate a modification request in RAMP.

To request a no-cost extension for your project, please initiate a modification request in RAMP. Most sponsors require the request at least 90 days prior to the end date of your project. The sponsor may or may not approve the carryover of unexpended funds to the next year. Please refer to your notice of award for more information.

If the award 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 academic unit, school, or college.

As PI, you will receive a percentage of the recovered F&A charged to your project. The percentage you will receive was identified at the time you submitted the proposal. An indirect account will be established for you and your portion of recovered F&A will be transferred to that account twice a month for charges made to the project. Spending must comply with Virginia 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.

If your award includes Human Subjects Research, ORIA is responsible for Mason’s program for promoting excellence in all aspects of research with humans. Please see ORIA Human Subjects in Research and review Mason’s policy on Research Involving Human Subjects University Policy Number 4017.

If your award includes Animal Subjects, ORIA is responsible for ensuring the humane and responsible treatment of all animals being utilized for research, testing and educational purposes. Please see ORIA Animal Subjects and review Mason’s policy on Occupational Health and Safety Program for Animal Care and Use Personnel University Policy Number 4004.

If your award included laboratory hazards, the Environmental Health & Safety Office is responsible for all lab safety. Please contact EHS for additional information.

Closeout is an integral part of and the final step in the award. Award closeout procedures are primarily focused on achieving the following goals in accordance with the Sponsor and the University requirements:

• Closing the award with the sponsor and submitting all final reports.
• Closing the award in our internal financial system (Banner).

The closeout process can usually begin 60 days following the end of the period of performance. However, if the sponsor requests closeout before that time, the University will comply.

The treatment of copyrighted works resulting from sponsored projects varies from project to project. All agreements will reserve the right for faculty to publish scholarly and academic works; however, provisions covering the use and distribution of reports and software will vary from agreement to agreement. Please refer to your notice of award for more information. If you have any questions regarding the use of copyrighted material created during the course of sponsored research, please contact OTT for additional information.

Most sponsored research projects, whether funded by the federal government, industry, or foundations, include terms that govern the disposition of patentable inventions discovered during the course of the research. For this reason, researchers must disclose new inventions to the Office of Technology Transfer (OTT). The OTT staff can discuss possible inventions with the researchers before making a formal disclosure and assist with any required disclosure forms. Please contact OTT for additional information.

Most sponsors require technical progress reports and a final technical report. Most funding sources require the PI to submit a final technical report within 90 days after the end date of the award. It is the PI’s responsibility to ensure that the appropriate reports are submitted in a timely manner. For auditing purposes, you must keep copies of all reports submitted. Please refer to your notice of award for more information.

Most sponsors require interim financial reports and a final financial report within 90 days after the end of the award. OSP generally prepares and submits the reports using expenditures charged to the project fund in Banner. If there are questions regarding project expenses, OSP will contact you for clarification prior to report submission. Financial reporting requirements may vary based on award. Please refer to your notice of award for more information.

As a recipient of state and federal funds, the University 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 human subjects; care and use of animals; export controls; biological safety (including recombinant DNA); use of toxic chemicals and management of hazardous waste; and radiation safety. In addition, the University must demonstrate that it has established institutional policies and procedures for Affirmative Action, Sexual Harassment, Misconduct in Research, Conflict of Interest, and Maintenance of a Drug Free Workplace.

More information about on the above compliance subjects are located at Office of Research Integrity and Assurance (ORIA), Environmental Health and Safety Office (EHS), Office for Diversity, Equity, and Inclusion (DEI), and Human Resources.

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, the raw data, graphs, charts, video tapes, pictures, sound 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 investigator and witnessed by another responsible individual. These records are to be kept accessible to permit inspection by authorized representatives of the University, the sponsor, or agents of the state or federal government during normal business hours. If you leave the University prior to the completion of this five-year period, you are authorized to take photocopies of the data with you. However, the original data will remain at the University unless the University is guaranteed access to the data through mutual agreement.

As a part of sponsored project activities, it may be necessary to have access to confidential or proprietary information owned by the University or the sponsor. Often separate nondisclosure agreements (NDAs) are executed to specify restrictions on confidential information between the University 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. Please review the terms and conditions of your award for more details.

During the research project, PIs and others engaged in the project should keep a detailed account of the research process: the data generated, the experimental results, and the timing of events. This account can be very important in establishing the legal framework for determining inventorship of any patentable discoveries related to the research. Please contact OTT for additional information.