As of July 1, 2008 travel authorizations and reimbursements on sponsored funds (funds starting with a '2') no longer need to be submitted to the Office of Sponsored Programs (OSP) for prior approval before submission to the Travel Office. Principal Investigators (PI) and unit administrators should review award budgets and travel restrictions to ensure travel costs charged to sponsored funding are allowable.

Please note all federal funding must comply with the Fly America Act, which requires travelers funded by the U.S. Government to use a U.S. air carrier for foreign travel. In extenuating circumstances non-compliance may be approved in advance by OSP.

Exceptions may be made when using a U.S. air carrier rather than a foreign carrier would:
1) increase the number of aircraft changes you must make en route by two or more
2) extend your travel time by six hours or more
3) require a connecting time of four hours or more at an oversees interchange point

Cost is not considered a reason for exception under this federal regulation, and travelers will not be reimbursed for any transportation cost for which there is improper use of a foreign air carrier.

OSP will be performing a periodic post-audit review of travel expenses charged to sponsored funds. During this process, OSP will work with the PI and unit administrators to move the unallowable cost to an appropriate funding source. If there are questions regarding travel restrictions or award terms please contact your Post Award Team Leader in OSP http://www.gmu.edu/research/OSP/staff.html.

As of July 1, 2008, MasterCard transactions charged to sponsored funds (funds starting with a '2') no longer need to be submitted to the Office of Sponsored Programs (OSP) for prior approval before submission to Purchasing. Cardholders who make charges to sponsored funds must retain the original receipts with their departmental MasterCard records for no less than 10 years. Please use the new GE MasterCard Approval Form.

An updated policy for Financial Conflicts of Interest in Federally-Funded Research has been developed by a committee consisting of Associate Deans for Research, Faculty, Research Administrators and University Counsel. It was reviewed and approved by Deans and Directors, the Faculty Senate, the Provost and Senior Vice President. Policy 410 can be found at http://www.gmu.edu/facstaff/policy/newpolicy/research.html.

The policy provides guidance and direction and will help ensure compliance in an area that is receiving increased scrutiny from the federal government. Each investigator (PI, Co-PI and any other person identified by the PI as responsible for the design, conduct or reporting of research) will be required to disclose situations where " significant financial interests" are present through the submission of an online certification form found at
http://www.randed.gmu.edu/osp/coi/proposal/index.cfm
This online form is secured using your Mason email login and password. If no significant financial interests are present, the investigator will simply need to identify the proposal number, sponsor name and select the option stating no significant financial interests are present. If the investigator determines a significant financial interest is present the disclosure should be made to the appropriate Dean or Director (or that individual's designee). The details of the process are outlined in the policy.

Submission of the online form must be made prior to the university's proposal submission for Public Health Service and National Science Foundation funding. For all other federal sponsors, the disclosure form is due within 30 days of the proposal submission (no certification is required for non-federal funding). For Federal awards received, the investigator will need to update his or her certification by June 30 of each year (OSP will coordinate this process annually) or more frequently if a new reportable significant financial interest is obtained.

Effective July 1, 2008, OSP will send the link for the conflict of interest certification form with the initial assignment of a Grants Administrator for each proposal request for federal funding. This will allow maximum time for each investigator to review and submit their certification form prior to the proposal deadline.

After reviewing the policy, if you have any questions please do not hesitate to contact me at 993-4573 or mlaskofs@gmu.edu

George Mason University has enacted a new policy affecting the issuance and administration of subcontracts. University Policy 4009 sets forth our subrecipient monitoring practices and procedures. This policy is necessary because Mason is responsible for the financial and programmatic monitoring of sponsored project funds that are subcontracted to another institution or organization (subrecipients). When awarding to Mason, our prime sponsors (often the federal government) have specific terms and conditions that we are required to flow down to any subrecipient receiving a portion of those funds. To monitor these requirements and to ensure good stewardship of sponsored project funds, Mason will use reporting, site visits, regular contact, and other means to assure that the subrecipient administers awards in compliance with laws, regulations, and the provisions of Mason's prime award and that performance goals are achieved.

While subrecipient monitoring is a shared responsibility involving many offices throughout Mason, the primary duty falls to the Principal Investigator (PI) and the Office of Sponsored Programs (OSP).

The PI is responsible for monitoring the subrecipient's technical and programmatic performance and progress. Subrecipient activities should be consistent with the proposed statement of work and should be progressing in a timely manner. The PI should review technical reports and, if necessary, perform site visits to review financial and programmatic records to ensure appropriate progress is being made. The PI shall ensure that subrecipients are in compliance with the subagreement terms and conditions.

PI's must also review and approve all invoices submitted by the subrecipient. Subrecipients are required to certify their invoices for accuracy and the PI should, in turn, verify that invoice amounts are consistent with technical progress and that costs are allowable under federal, state, university, and prime sponsor requirements. While the level of involvement may vary, it is anticipated that departmental administrators will assist PIs in these subrecipient monitoring responsibilities.

OSP has numerous duties under the new Policy. It shall be responsible for establishing processes and procedures to ensure compliance with all applicable law and university guidelines. During the pre-award phase, OSP will review proposal submissions to assure subaward arrangements are appropriately budgeted in the prime award budget and that all of the subrecipient's representations, certifications, and assurances are in place. During the award stage, OSP performs a pre-review of all subcontract invoices to ensure sufficient funding is available before routing it to the PI for final review and approval.

OSP will also maintain a record of all active subrecipients and perform annual risk assessments. It will collect an annual A-133 audit certification letter and financial questionnaire for non-A-133 subrecipients.

The Office of Sponsored Programs is available to assist PIs and departmental personnel with interpreting this new policy. We will also take the lead in developing strategies for resolving cost or audit issues with subrecipients. To locate Policy 4009, please go to http://www.gmu.edu/facstaff/policy/newpolicy/4009res.html. The associated procedures can be found at http://www.gmu.edu/facstaff/policy/newpolicy/4009pro.html.

Policy 4008: Private Sector and Foundation Funding to George Mason University and the George Mason University Foundation, Inc. has been approved. The policy, procedures and overview document can be found on the university policy website at http://www.gmu.edu/facstaff/policy/newpolicy/4008res.html.

If you have any questions please contact Mike Laskofski at mlaskofs@gmu.edu or 993-4573.

Beginning April 7, 2008, NIH will require scientists to submit electronic copies of peer-reviewed journal articles that result from NIH funded projects to the National Library of Medicine's digital archive, PubMed Central. Investigators are required to make these manuscripts publically available no later than 12 months after the official date of publication. The purpose of this policy is to make these articles accessible to the public on PubMed Central in order to help advance science and improve health.

As of April 7, 2008, all articles arising from NIH funded projects must be submitted to PubMed Central. This requires investigators to inform any journal to which they are submitting that the article is subject to NIH's Public Access Policy and will also be submitted to NIH's archive for publication. Investigators must make sure that any copyright transfer or other publication agreement allows the article to be submitted to NIH in accordance with the policy.

As of May 25, 2008, NIH applications, proposals, and progress reports must include the PubMed Central reference number when citing an article that falls under the policy and is authored or co-authored by the investigator, or arose from the investigator's NIH award.

More information, including frequently asked questions, regarding the NIH Public Access requirement can be found at http://publicaccess.nih.gov/.

The F&A rate agreement for FY08 - FY10 has been finalized with the Office of Naval Research, our cognizant agency. Since July 1, 2007 we have been using the following rates for "other sponsored activities" and "sponsored instruction," but rates for sponsored research increased under the new agreement. Existing sponsored research agreements will not change, but the new rates will be used in proposals, effective immediately.

On-campus research 45.5%
Off-campus research adjacent 27.4%
Off-campus research remote 26%

On-campus instruction 52.3%
Off-campus instruction adjacent 39.6%
Off-campus instruction remote 26%

On-campus other sponsored activities 34.3%
Off-campus other sponsored activities adjacent 26%
Off-campus other sponsored activities remote 25.4%

Rates for DOD research contracts are 3.0% higher than the regular research rates because there is no cap on the administrative portion of the rate.

Sponsored Research includes all research and development activities that are sponsored by Federal and non Federal agencies and organizations. This term involves systematic study directed toward fuller knowledge or understanding of the subject and includes activities involving the training of individuals in research techniques (research training) where such activities utilize the same facilities as other research and development activities and where such activities are not included in the instruction function. Sponsored Research generally includes hypothesis testing and has a defined scope of work, a work plan, time frame and reporting requirements to the sponsor.

Sponsored Instruction is defined as teaching and training activities funded by grants, contracts, or cooperative agreements from Federal or non Federal sponsors. Sponsored Instruction includes agreements that support teaching/training activities, whether offered through regular academic departments or separate divisions. Other Sponsored Activities include programs and projects financed by Federal and non Federal agencies and organizations which involve performance of work other than instruction and organized research.

Other Sponsored Activities are established primarily to provide non instructional services beneficial to individuals and groups external to the institution. Some examples include: Travel, Conferences, Social Service, Community Service, Health Service and Program Operation.

If you have any questions, please contact Mike Laskofski at mlaskofs@gmu.edu or Beth Brock at ebrock1@gmu.edu.