Contents
Overview of Principal Investigator’s Obligations For Management of Sponsored Projects
Expenditure of Funds
Personnel
Fiscal Responsibility
Technical Reports
Financial Reports
Time and Effort Reporting
Cost Share Reporting
Subcontracts
Absence or Change of the PI or other Key Personnel
Regulatory Compliance
Intellectual Property
Privileged Information
Recovered F&A (Indirect) Costs
Records/Data
Overview of Principal Investigator’s Obligations For Management of Sponsored Projects
When George Mason University formally agrees to accept funding for a sponsored project, institutional acceptance of the award places obligations on the University and the Principal Investigator (PI) is responsible for meeting many of these institutional obligations. Some or all of the obligations below apply to sponsored projects. When you receive an award you should review this information carefully. If you have any questions, your primary point of contact in OSP is the team leader for your department or unit.
Expenditure of Funds
OSP enters your budget into a unique account called a fund. OSP has posted on the OSP web site information about how to access your account in Banner, the online financial system. If you do not know how to use Banner, you can sign up for the 1-hour training session offered throughout the year by the Office of Fiscal Services (3-2920)
When you receive an award, some important things you should do to manage expenditures on your project are:
- Compare your award budget and the budget entered into Banner. If there are discrepancies, please contact your OSP team leader immediately.
- When you spend money for a project, you are obligated to charge it to your account using the Grant/Fund Number.
- It is very important that you monitor your expenses and compare them to your account at least monthly to ensure that the charges are appropriate and that you do not overspend the account or end up with insufficient funds.
- Your funder may not allow you to carry over unspent funds to the next year. Or, your funder may allow a carryover as long as you request it several months in advance of the end of the reporting period. It is your obligation, as the PI, to be aware of what your funder allows. You should contact OSP about a request for an extension of the funding period at least three months prior to the scheduled expiration date. OSP will contact the funding agency with your justification as a formal request from the University.
Personnel
If your 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 check with your department administrator about how to charge current GMU employees to the project or refer to the Human Resources (HR) web site, www.hr.gmu.edu, or call 3-2600 for information about how to initiate hiring procedures as soon as possible. The University provides an electronic hiring process for use in hiring for classified and wage positions. See the HR website for additional information.
As a PI, you are obligated to ensure that all personnel forms (hiring, time sheets, and personnel change) on this project be submitted in a timely manner. Failure to do so could put you in financial risk and could result in insufficient representation of personnel effort on your project. Delayed submission of personnel forms could also result in charges that are not allowed to be charged to this project.
State and Federal law requires that all personnel selections be in compliance with the George Mason University 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.
Fiscal Responsibility
When you receive notification of your award, your OSP team leader will send you a signature form to complete to establish your signature authority. This will allow you to begin spending on the project. You may also delegate signature authority.
You are responsible for all expenditures charged to this project. This includes approving payments, making certain payments are correct, ensuring that payments are not duplicated, verifying that expenses are in the correct budget category (account code) in Banner and making sure the services or merchandise are received. You must sign all invoices and requisitions to verify approval. If you have questions concerning personnel, travel or expenditures, please contact your team leader.
As the PI, it is your responsibility to review your account at least monthly for accuracy and ensure that all expenditures and transfers were authorized, appropriate and consistent with George Mason University and Sponsor fiscal policies and procedures. If you detect an error, contact OSP within 30 days of the occurrence.
It is the responsibility of all PIs to monitor expenditures in budget line items, including salary and fringe benefits to ensure they are accurate. In the budget, salary and fringe rates are estimated. You must review the actual charges because what is actually charged may exceed the budgeted amount, potentially resulting in insufficient funds to cover salary and fringe costs. You may be able to re-budget if the sponsor allows or you may be responsible for covering those charges from another account. Some sponsors place restrictions on the amount of funds allowed to be transferred from one budget line to another without sponsor approval. If you anticipate that you will need to spend more in a budget line than was originally budgeted, you must contact OSP to request that OSP obtain the necessary approval from the sponsor.
If the project is overspent at the end of the project, all overexpenditures will need to be charged to a nonsponsored source of funding. If a PI does not have sufficient funds to cover the overexpenditure, the overspent amount will be the responsibility of the academic unit, school or college.
For additional information concerning the University’s fiscal policies and procedures, please visit the Fiscal Services website at www.fiscal.gmu.edu/index
Technical Reports
Most sponsors require technical progress and final reports. Most funding sources require the PI to submit a final technical report within 90 days after the end of the funding period. It is your responsibility to ensure that the appropriate reports are submitted. You must keep copies of all reports you submit because audits of externally sponsored projects records will include review of reports.
Financial Reports
Most sponsors also require final financial reports. The final financial report is routinely required within 90 days after the end of the award period. Usually, OSP will prepare and submit these using your project’s financial information in Banner. If there are questions regarding project expenses, OSP will contact you prior to the financial report submission for clarification. Please note: requirements for reporting may be affected by the terms and conditions of the formal agreement between the University and the sponsor.
Time and Effort Reporting
Federal requirements are strict for time and effort reporting. OSP prepares and sends effort reports to individuals who receive federal funding. The effort reports are prepared every semester based on the percent of your effort charged to your projects. You are required to certify that the effort documented is correct. The total amount of effort cannot exceed 100%.
Cost Share Reporting
Federal requirements are also strict for cost share/matching funds reporting. If you made a commitment to cost share or provide matching costs for this project, you must keep detailed documentation of the expenditures that meet cost share requirements. This documentation should include the account information for where those costs are charged. Effort reporting can capture cost share of time and effort on the project but you must also keep careful explicit documentation of all types of cost share for this project. The documentation should parallel the commitment made to the sponsor in the proposal. The documentation should also be collected as expenditures are made. This is a serious responsibility as projects can be audited and if documentation is not adequate there could be an audit finding against the University which could affect project funding or future funding. If your project involves cost share/matching funds, please contact your OSP team leader for methods to identify and track cost share or matching funds information.
Subcontracts
You are responsible for notifying OSP about initiating any subcontracts on your project. Once the subcontracts are executed you are responsible for monitoring your subcontractor’s performance and approving their invoices for payment.
Absence or Change of the PI or other Key Personnel
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 mayinvolve 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. You should contact OSP at least 90 days before you plan to leave the University. Sponsors often also need to be notified if you change other key personnel on your project.
Regulatory Compliance
As a recipient of state and federal funds, George Mason 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; 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, Financial Conflict of Interest, and Maintenance of a Drug Free Workplace. Contact your OSP team leader if you have any questions regarding your responsibilities under these regulations.
Intellectual Property
Copyrights: 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. If you have any questions regarding the use of copyrighted material created during the course of sponsored research, please contact your Team Leader.
Patents: 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). Disclosure forms are available at http://techtransfer.gmu.edu/form.htm. The OTT staff is also happy to discuss possible inventions with the researchers before making a formal disclosure. Please call Gloria Garcia at x38933 so that she can direct questions to the proper individual.
Research Record-Keeping: During the research project, PI’s and others engaged 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. The article on the Office of Technology site found at http://techtransfer.gmu.edu/record.htm provides an excellent guide to establishing a good record of the research process. It is reprinted from the August, 1990 issue of Touchstones (vol. 22. no. 3) published by University Industry Research Relations of the University of Wisconsin-Madison.
Privileged Information
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 insure 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 refer to the award agreement for specific requirements for your project.
Recovered F&A (Indirect) Costs
As PI, you will receive a percent of the recovered F&A charged to your project. This is typically 10.5%, but may vary because of agreements made among the recipients designated to receive F&A for this project. The percent you will receive was noted on the Proposal Routing Form when you submitted your proposal. OSP will set up a separate account for you and your portion of recovered F&A will be transferred to that account at the beginning of each month for charges made to the project in the previous month. They will show up as charges to your sponsored account at the time of the transfer. These funds must be expended consistent with federal regulations regarding recovered F&A costs. Additionally, as a state institution we must comply with state restrictions on spending. Typically recovered indirect is used to support travel, purchase equipment, support students or for other traditional academic expenditures. Recovered funds may not be used to increase the salary of the PI.
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, the raw data, graphs, charts, video tapes, pictures, sound recordings, and signed informed consent documents (for research with human subjects). These materials are required to be maintained in appropriate data books or other filing systems which 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.
For further information on any of the above issues, you can contact your OSP team leader for information about University and external sponsor policy, or access them electronically. If you receive a Federal award, please refer to OMB Circulars A-21 “Cost Principles for Educational Institutions” and A-110 “Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations”. These are available at www.whitehouse.gov/omb/circulars. If you have any questions, or need further assistance please do not hesitate contact the OSP team leader for your unit or visit our website at www.gmu.edu/research/OSP/ | 
