If one or more of the following criteria exist within a grants or contract proposal, it must be processed through the OCRO:
The award requires a line-item financial report to the grantor/sponsor at any time during the life of the project.
The award has a cost-sharing component (University, school, or department matching funds).
The award is one of several to a project for which there is a project-wide financial reporting requirement (i.e., any of the granting/sponsoring entities require a financial report for the entire project).
The grantor/sponsor controls the scope of the project and/or requires scientific or technical reporting of specific milestones as a condition of the grant/award.
The award includes funds that will be re-granted or subcontracted by the University to non-GW entities.
The award includes indirect costs recoveries.
What constitutes Sponsored Research at GW, cont.
The award involves an Intergovernmental Personnel Act (IPA) agreement that places GW personnel on assignment to a Federal agency.
The grantor/sponsor states in its award letter that it maintains the right to perform a detailed financial audit of the award expenditures.
The proposal indicates a conflict of interest;
The proposal contains the use of animals, human subjects, or hazardous agents requiring the review of OHRCTT;
There are conditional obligations of the funding indicated in the award document or solicitation (e.g., time and effort, space, budget restrictions, return of unused funds, contingent payments, employment requirements);
The award or solicitation contains intellectual property provisions, indemnification, hold harmless, provisions containing restrictions on publication of research results and other contractual provisions that place risk on the University.
A “Letter of Intent” (LOI) expresses the intention to submit a proposal in response to a particular program announcement or request for proposals.
LOI’s are generally solicited by the sponsor in conjunction with an announcement that is expected to generate widespread interest.
If the LOI contains budget estimates or representations, it should be reviewed and approved by the appropriate RSC prior to submission. The Managing Director of Research Support and Analysis will sign the letter as an indication of the institution’s concurrence with the planned submission.
Personnel (expressed in % of total GW effort) include anticipated salary increases if multi-year. (Jan 1 – admin and research staff and Med Ctr. Staff, and July 1 for MC Faculty and Jan 1 for University Faculty, not the anniversary of the project award).
Fringe benefits are charged as the University provides a percentage of salaries for all regular full-time employees and certain part-time employees to cover such benefits as retirement, health care, and tuition benefits. The funds generated are pooled and eligible employees may draw from them to the extent appropriate to the terms of their employment. There is a separate rate for temporary hourly wage employees who work 700 hours or less per year. Fringe benefit rates are determined annually; consult the Office of the Chief Research Officer or its Web site ( http:// www.gwu.edu/~research/boiler.htm ) for current rate information.
The base to which indirect costs rates are applied. Modified Total Direct Costs consist of "salaries and wages, fringe benefits, materials and supplies, services, travel, and subgrants and subcontracts up to the first $25,000 of each subgrant or subcontract (regardless of the period covered by the subgrant or subcontract).
Exclusions from Base:
Equipment, capital expenditures, charges for patient care, tuition remission, rental costs, scholarships, and fellowships as well as the portion of each subgrant and subcontract in excess of $25,000 shall be excluded from modified total direct costs.
All proposal submissions require the following no matter what :
The proposal in accordance with the sponsor’s solicitation or guidelines.
Proposal Submissions Workflow… Principal Investigator (PI) informs OCRO of RFP/RFA and initiates documentation Research Service Coordinator (RSC) completes First Review of Proposal Pre-Award Specialist completes Second Review of Proposal Managing Director Research Support and Analysis completes Third and Final Review Proposal Complete PI submits proposal to RSC Proposal inaccurate/incomplete Proposal inaccurate/incomplete After Final Approval – returned to Pre-Award Specialist for Electronic Submission Paper proposal submissions are routed to the department for mailing
PI initiates/informs RSC of RFP (Request for Proposal) and in turn, RSC sends RFP information to the Pre-Award Specialist and Contracts Manager)
Route to Dean for signature
Submit to Anne Hirshfield ( if voluntary cost-sharing)
Return to RSC
Optional Forms Required for the following cases:
Cost Sharing Form (Attach if you plan to cost-share, either mandatory or voluntary/committed) http://www.gwu.edu/~research/forms/costshareform.pdf
Are multiple investigators involved? If so, submit this form:
Is a sub-award to another collaborator required? Remember, subwards are issued when GW plans to collaborate with another entity to help perform a part of the statement of work. Submit the following checklist with forms: http://www.gwu.edu/~research/forms/SubAchecklist.pdf
Are human subjects involved? Submit form on website http://www.gwumc.edu/research/human/
Are animals involved? Submit form on website http://www.gwumc.edu/research/animal/forms.htm
Are biohazards involved? Submit form on website: http:// www.gwumc.edu/research/labsafety/commbull.htm
Forms are filled out, where do I route my proposal?
All investigators involved on the project must sign the proposal routing form first; for multi-year cross departmental situations, it is the lead PI who is responsible to ensure that all signatures are contained, all assurances are met, and all terms and conditions upon receipt of award are complied with.
Chairs, Deans, Directors, VPs must sign where appropriate.
Additional signature(s) - As required. Loudon Campus: the Executive Director and the VP for Academic Affairs must sign all proposals originating from or involving the Loudoun Campus .
Medical Center - The Associate VP for Health Research, Compliance, and Technology Transfer must sign all proposals originating from or involving the Medical Center .
The Research Service Coordinator (RSC) must initial before the proposal is received and signed by GW’s Institutional Official (Hal Gollos) in OCRO.
Cost sharing are those costs borne/shared by the University, not the agency, and are proposed up front. There are three types of Cost sharing:
Mandatory – Required by the agency in solicitation or guidelines;
Voluntary Committed – an implied willingness for the University to bear certain project costs contained in the proposal submitted to the sponsor. The commitment is not a requirement imposed by the sponsor. Requires approval from Anne Hirshfield. Must be tracked in the financial system if specified in proposal.
Voluntary Uncommitted - neither a sponsor requirement nor a University commitment but represents additional costs incurred by the University beyond the levels in the proposal and/or award documents. Voluntary cost sharing is not specifically quantified in the proposal submitted to the sponsor. Federal regulations do not require the University to document voluntary cost sharing.
Once approved, the RSC sets up the award as an Administrative Establishment in the financial system for a period of up to 90 days.
If the award is not forthcoming, then at least two-weeks before the expiration of the Administrative Establishment period, the Principal Investigator should discuss the matter with the Chair and/or Dean and determine whether to recommend that the Administrative Establishment be extended for an additional period.
Should an extension be desired, requests for existing Administrative Establishments must be processed and approved through same process as the originating Administrative Establishment.
Officials Authorized to Commit the University: Donald Lehman, Executive Vice President for Academic Affairs Carol Sigelman, Chief Research Officer Robert Donnally, Managing Director, Research Services & Operations *Hal Gollos, Managing Director, Research Support & Analysis (*Hal Gollos is the primary signature authority, however if he is unavailable for any reason then RSCs are notified about who will sign in his absence.)
PART II Post Award Activity I’ve received my award: what happens now?
Review the award document very carefully and read embedded links to terms and conditions or attached terms and conditions thoroughly. These terms will dictate to you what prior approvals are required should you anticipate the following:
Request additional time to complete your project;
Request a leave of absence or substitute a change in key/senior personnel;
Move funds between budget categories (most re-budgeting is allowed unless it exceeds 25% of the total amount awarded) check the terms first though to ensure sponsor specific criteria.
Request a sub-award (collaborator) or independent contractor for services not originally anticipated or budgeted for in the initial proposal submission;
Request to purchase equipment not originally proposed
Fixed price awards are risky. One price is set for the work, generally not recommended for research;
Costs resulting in over runs cannot be recovered.
Work performed should be at a level where predictability is accurate.
No financial reporting, audit requirements, any reference to costs being “reimbursable”, are not subject to cost accounting standards or federal circulars except A-133 and no references to allowable expenditures or prior approval related to expenditures.
Excess funds must be
Caution: Over-pricing and large remaining balances create huge red flags to auditors.
Notify your CFA, SRA or RSC of any changes such as a change in scope, leave of absence, addition of subcontractor, equipment purchase, etc.
Monitor your expenditures closely;
If committed cost sharing was proposed, ensure commitments are fulfilled and reported to GCAS in a timely manner;
Complete effort reports;
Provide care and maintenance of any property procured;
Write and submit progress reports, fulfill deliverables as proposed;
Review monthly payroll reports (ensure the person charged in the payroll report is the actuall person on project –six digit account codes may cause error);
Ensure subecipients perform in accordance with statement of work, complete deliverables on a timely basis.
Submit invoices on time
Know how to interpret the reports sent to you and who to contact for questions:
BPRs – GM-139/GM-140
Invoices – Thorough review of invoices are crucial in meeting the monitoring requirements of Contractors and Subrecipients. Effort proposed, potential cost sharing proposed, and review of other items proposed in the budget to ascertain work was performed to satisfaction is important before payment is approved. Issues with performance should be addressed immediately to avoid potential litigation.
Advances may be issued for up to $100 per day up to a maximum of $500 per week for reasonable out-of pocket expenses.
The preferred method for obtaining advances is via ATM withdrawal using the P-Card (Medical Center does not permit P-Cards for travel and entertainment).
ATM advances may not be taken more than three (3) days before the expected travel. Cash advances at ATMs overseas are dispensed in local currency and travelers may check with the P-Card Office to determine the availability of ATMs in their destination country.
Travelers may request travel advances in the form of direct deposit or GW check (depending upon their payroll setup) issued by AP within two (2) weeks of travel dates. Only one (1) outstanding advance is permitted at any time.
The IRS requires that travel reimbursement requests be submitted in sixty (60) days. Reimbursements submitted later will become reportable and will be grossed with income and taxed. 30 day submittal at end of travel is strongly encouraged.
Federal Travel Regulations require that U.S. carriers must be used for travel that is to be reimbursed from federal grants and contracts. This policy is called the Fly America Act.
Compliance with the Fly America Act is our responsibility.
Exceptions to the Fly America Act:
When the use of U.S. carrier service would extend travel time by 24 hours or more
When the costs of transportation are reimbursed in full by a third party, such as a foreign government or an international agency
When U.S. carriers do not offer nonstop or direct service between origin and destination. However, a U.S. carrier must be used on every portion of the route where it provides service unless, when compared to using a foreign air carrier, such use would:
Increase the number of aircraft changes outside the United States by two or more
Extend travel time by at least six hours or more
Require a connecting time of four hours or more at an overseas interchange point.
Note: When one or more of the above circumstances apply, an explanation indicating the appropriate exception must be provided on the Travel Report.
Know how to purchase items (travel and supplies) for your project using the P-card
The GW Procurement Card (P-card) is to be used to make low-dollar purchases (<=$2,500). Any procurement request >$2,500, or those that have special purchasing restrictions, must be processed through Procurement via a purchase order. Three categories: Goods only, goods plus travel & entertainment, goods, travel & entertainment and cash.
It is the PI’s and department’s responsibility to monitor the uses of their P-cards. (Please note that the Medical Center doesn’t allow P-cards for travel.)
Charges must be within the award period, and they must be allowable on the Award per sponsor’s guidelines. All charges must be allocated through GW’s Pathway system (p-card system online)!
P-card charges and backup documentation must be approved by a supervisor.
Honoraria are non-routine, monetary payments given to individuals in appreciation for their willingness to contribute to University events or projects of short duration, such as:
presenting a lecture or speech
serving as a discussant of or reviewing papers for a conference
attending an advisory board meeting
carrying out other short-term academic activities
Requests for payments of honoraria must be accompanied by a Form W-9, or the equivalent information, and by documentation regarding the nature of the event in which the recipient of the honorarium will be participating (such as a program or agenda).
A Supplier Registration Form and 20 Factors Test are not required for payments of honoraria.
These titles may not accurately describe all possible positions associated with the conduct of research. Alternative “working titles” may be used for internal program purposes in addition to these eight official titles.
GW research position descriptions and salary ranges are outlined in the Handbook on Sponsored Programs, sections 8.1.1 http:// www.gwu.edu/~research/handbook/develop.htm#resa
Recruitment and Hiring of Research Employees (cont.)
Complete the Request to Establish a New (Fill Existing) Full Time Research Staff Position
Recruitment Steps (waivers of certain recruiting requirements are available in appropriate circumstances)
Approving the Hire Request
Extending Job Offer
Completing Administrative Hiring Processes
PI initiates Hire Documentation
CFA enrolls the final candidate who is an external hire, upon acceptance of the job offer, in the first available New Employee Orientation session
Upon completion of hire process, OCRO prepares Appointment Letter. If additional information is to be added to the appointment letter, PI/CFA notify the RSC
Recruitment and Hiring of Research Employees (cont.)
New part-time or temporary positions may be established using simplified procedures which do not require a recruitment plan:
Recruitment and Hiring of Regular Part-Time Research Staff (FTE 35% - 99%)
The recruitment process for regular part-time research positions is under the PI and Department discretion. Once the candidate is identified, proceed with Completing Administrative Processes (step 3 of Hiring Full-Time Research Staff)
Hiring of Temporary Research Staff (less than 35% FTE)
Temporary wage employees are limited to 700 hours or less per fiscal year. Usually, an appointment for a period of less than six months is done on a wage basis payable bi-weekly. The hiring of temporary wage employees does not require recruitment or waiver of recruitment. Wages should be consistent with Research Position Classification Descriptions and salary ranges (hourly rate is calculated by dividing the annual salary by 2088).
Research Faculty – How to Recruit Research Faculty
Research Professors are often hired with a waiver of search. To hire a Research Professor when a waiver of search is requested, the Department Chair should send a memorandum through the School Dean to the Executive Vice-President for Academic Affairs. The memorandum should state the appointee’s name, proposed title, salary if applicable, and planned percentage effort. The memorandum should explicitly state that a waiver of search is being requested and the candidate's CV should be attached. Additional information may be required at the discretion of the relevant Dean or in the Medical Center.
Special Hiring Cases
Foreign Nationals – Hiring is similar to the process above, but the appointment letter reflects the need for acquiring the appropriate visa to be eligible to work in the US. The International Services Office (ISO) is available to consult on issues associated with hiring foreign nationals. Plan in advance. Some federal projects have special terms and conditions on foreign nationals.
Visiting Research Scholars – International visiting scholars are typically hired for short periods following part time hiring processes, but with the added requirement for verifying eligibility to work in the US. ISO is available to assist with these as well.
Human Resources Website
To recruit and hire a regular staff position for a research program, go to the Human Resources website Guidelines for Recruiting at http://www.gwu.edu/~hrs and follow the links from Staffing and Compensation to Recruitment Process for Staff Positions . Where the process indicates “Budget Office,” refer to your RSC for review and approval.
CIS form must be initiated in order to transfer project personnel to/from sponsored programs, to change the allocation of personnel effort and to request other changes of employee status: change FTE, LOA, reclassification, etc
Proper processing of CIS forms is essential in order to ensure that the University is correctly recording and charging labor on sponsored programs and for Effort Reporting purposes in accordance with the University’s Effort Reporting Policy
GW is partially implementing the CIS process on an electronic basis. This electronic processing is currently limited to a program for CIS forms involving Terminations
Terminations should be processed electronically in advance of the effective date of termination. To avoid any overpayments PI should notify CFA and RSC on termination actions as soon as PI has made determination on termination
Payroll processing dates are very important to keep in mind for successful outcomes of data entry for Hire forms and CIS forms.
There will be instances in which circumstances prevent the processing of CIS forms according to established guidelines. In these cases, the initiator should contact either the CIS Form Help Desk at [email_address] .edu or the Director of Research Finance and Administration so that the OCRO is aware of the circumstances and can facilitate processing of these forms so that sponsored research personnel can be paid correctly and in a timely manner as soon as possible.
Equal Employment Opportunity /Affirmative Action Statement Policy information can be found at http://my.gwu.edu/files/policies/EqualEmploymenOpportunityStatement.pdf ; on the Equal Employment Opportunity Office website http://www.gwu.edu/~eeo , or by contacting the EEO Office at 4-9656.
For research staff, employment is "at will" similar to other regular staff, i.e., employees may be terminated at any time for performance issues or other reasons even if program funding is otherwise available, in addition to termination due to program changes or lack of funding.
For additional information about recruitment and employment related policies and guidelines, including information on employee salary, merit increases, benefits, employment, disciplinary action and terminations, please see:
Faculty Code and Faculty Handbook http:// www.gwu.edu/~academic/Resources/main.htm
Online Guide for Supervisors http://www.gwu.edu/~hrs/manual/
Bring any discrepancies to RSC’s attention including any other comments on CGAS 90-day review
Ensure that all contractual agreements are fully executed, funds are encumbered and contractors/subrecipients are notified for deadlines on reports and final invoice submission
Initiate actions needed for resolving identified discrepancies: process any outstanding orders, personnel actions, and direct payments.
PI and CFA should review suspense and funds check failure reports and take corrective actions to clear all items
Consider requesting a no-cost extension, if appropriate
Award Close-out (cont.) 60- and 30- Days Prior to Award End Date
Continue to identify and process actions needed for resolving identified discrepancies: process any outstanding orders, personnel actions, and direct payments with special emphasis on items in suspense and funds check failure
At the 30-day notice verify that all corrective actions submitted have been processed
Ensure that all contractual agreements are encumbered
No Cost Extensions (NCEs) should be requested only if there is need for additional time to complete the SOW
Processing NCE varies depending upon whether a formal modification to the grant or contract is required
Informal (i.e., approved by email)
In the event the NCE has already been requested by the PI, the RSC shall obtain a copy of such correspondence together with any reply received from the sponsor.
Once the RSC receives an approval from the sponsor, the revised End Date/Close Date established pursuant to the approved NCE is entered in the EAS system to extend the period of the award and any applicable cost sharing awards associated with that award.
Formal NCEs: When the sponsor requires formal signatures or modification of the award to approve the NCE request
PI initiates NCE request per award terms and conditions
The NCE shall be forwarded to the RSC for review and forward the OCRO Managing Director for signature