V.  PROJECT AWARD AND EXECUTION  

Section 14: Award Review and Set-up

14.1. AWARD SET-UP AND NOTIFICATION OF AWARD

The culmination of all the preparation and proposal writing and submission activity is a favorable response from the sponsor. If all goes well, an award is made, negotiations are completed and the award is accepted, reviewed and set-up for expenditures and execution.
 
14.1.1. Prompt Award Set-up

After award documents are accepted, they are scanned into the Documentum, the University’s electronic information storage and retrieval system.  As soon as all required actions, forms and any required compliance approvals have been completed by the program office and others, the award is set-up in the EAS (Oracle) Financial System. The Award Set-up Process involves entering a variety of data into the University’s Financial System to establish budget line items, performance period dates, deliverable requirements and certain terms and conditions as well as other information in the system for tracking and reporting purposes. How awards are set-up depends on whether they are new awards or modifications, and, if modifications, whether they are complex or standard as summarized in the following:

14.1.1.1. New Award Set-up: Office of the Chief Research Officer sets-up new awards following: acceptance/full execution, scanning for Documentum and completion of all necessary program documents/approvals by the program office. To achieve this, the RSC prepares an Award Set-up Sheet to reflect the terms of the award as they need to be entered into EAS/Oracle, reviews it with the Awards Manager, obtains Award and Banner Index numbers, and enters it into the system.  The Awards Manager sets-up the new Banner Index number in the Banner Payroll System to link the University’s payroll system to the EAS/Oracle Financial System.

14.2. AWARD ADMINSTRATION ROLES AND RESPONSIBILITIES – ADDITIONAL DETAILS

14.2.1. Award Stewardship:

Sponsors make awards to the University, not to individual investigators. While the University is legally responsible for the stewardship of an award, the investigator is accountable to the sponsor, the University, and the school and department in which the program is conducted for all aspects of the program, whether the award is in the form of a grant, a contract, or other award mechanism. In addition to bearing the responsibility for conducting the program in a manner consistent with professional standards, investigators must be aware of and observe all of the terms and conditions of the award.

14.2.2. Principal Investigator Additional Detail Regarding Award Administration Role and Responsibilities:  While certain tasks identified below may be delegated to Project Research Administration, Department, and School Staff, the Principal Investigator has the primary responsibility for the conduct of the program in accordance with relevant regulations, sponsor requirements and University policies and procedures. 

Following is a Checklist of Principal Investigator and OCRO Post-Award Roles and Responsibilities.

14.2.2.1.: Principal Investigator’s Post-award Roles and Responsibilities Checklist

Click here to use the fillable pdf version of the PI's Post-award Responsibilities Checklist.

Section 15: Program Expenditures

Following is a partial listing of the more common types of Direct Cost Expenditures that are charged to sponsored programs at GW. The emphasis is on what information is needed to enable the Principal Investigator to properly charge these costs to a sponsored program. For information on how to properly propose these costs in the proposal submission phase, please refer to Section 7, Preparing Well-Supported Budget Proposals.

15.1. PROGRAM PERSONNEL – How to hire project personnel

The information provided in this Section relates to the requirements and procedures for the effective recruitment and hiring of project personnel on sponsored research programs. References to important and detailed information about benefits, employment, disciplinary action, terminations and other matters of interest regarding employment at GW are also included at the end of this Section. To the extent the statements in this Handbook relating to the requirements and procedures for the recruitment and hiring of personnel for a research project at GW conflict with information originating from Human Resources, the latter supersedes.

Among other things, this Section discusses requirements for recruiting and selection, EEO and Affirmative Action Policies, and working effectively with Human Resource Services and the Office of Faculty Recruitment and Personnel Relations. The University is an Equal Employment Opportunity/Affirmative Action (EEO/AA) employer committed to maintaining a non-discriminatory, diverse work environment. The University does not unlawfully discriminate against any person on the basis of race, color, religion, sex, national origin, age, disability, veteran status, or sexual orientation, or other classifications protected by applicable law. This policy covers all programs, services, policies, and procedures of the University including admission to education programs and employment. The University is subject to the District of Columbia Human Rights Act. The University supports the employment and enrollment of qualified individuals with disabilities. For further information, see http://my.gwu.edu/files/policies/DisabilitiesFINAL.pdf. To request disability accommodations, students should contact the Office of Disability Support Services, (202) 994-8250 (TDD/voice), and employees should contact the Office of Equal Employment Opportunity, (202) 994-9656 (voice) or 9650 (TDD).

New full-time hires must be hired and retained on research programs in accordance with applicable University Equal Employment Opportunity Office, Human Resource Services, Office of Faculty Recruitment and Personnel Relations, Faculty Code and Faculty Handbook guidelines. If appropriate, waivers of certain recruiting requirements are available in appropriate circumstances on sponsored research programs. New part-time or temporary positions may be established using more simplified procedures which do not require a recruitment plan.

Fringe Benefits Specific to Research Employees

Tuition Benefits
Tuition benefits as described in the weblinks provided below are available to employees of GWU and their spouses and dependents on the semester start date following 90 days of regular employment.  However, Research professionals, Faculty, Medical Residents and the Executive group are eligible to receive tuition benefits for the first semester that follows or coincides with the date of appointment.  Spouses and dependents of Research professionals are still subject to the 90 day waiting period.   
Related weblinks are:
http://www.gwu.edu/~hrs/pdf_files/undergrad_tui_packet.pdf
http://www.gwu.edu/~hrs/pdf_files/research_tui_packet.pdf

Vacation Accrual
Full-time research employees accrue leave at the rate of 1 3/4 days per month. The accrual rate for full-time researchers does not change with years of service. Hospital residents should consult the Resident Manual provided by the Office of Graduate Medical Education.
The accrual rate for annual leave for regular part-time employees is calculated using the percentage of effort, which is based on the number of hours worked per week divided by 40. The accrual rate for part-time research employees is calculated by multiplying the percentage of effort times 1 3/4 days per month. The accrual rate for regular part-time employees and part-time researchers does not change with years of service.

Sick Leave Accrual
Paid sick leave is provided for absence from work due to illness and medical or dental treatment. Accrued sick leave is credited on the last working day of each month and may not be used prior to accrual.  Regular full-time employees accrue 1 day of sick leave per month, up to a maximum accrual of 180 days.

For more specific information regarding these and other benefits please contact the Human Resources Benefits Services.  The weblink is http://www.gwu.edu/~hrs/benefits/index.html

For Questions

For additional information regarding the University’s commitment to equal opportunity employment, please see the Equal Employment Opportunity /Affirmative Action Statement Policy at http://my.gwu.edu/files/policies/EqualEmploymenOpportunityStatement.pdf, and the Equal Employment Opportunity Office website at http://www.gwu.edu/~eeo, or contact the EEO Office at 4-9656. With respect to research staff, employment is "at will" similar to other regular staff, i.e., such 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 benefits, employment, disciplinary action and terminations, please see the online, please see the Faculty Code and Faculty Handbook at http://www.gwu.edu/~academic/Resources/main.htm , the online Guide for Supervisors, at http://www.gwu.edu/~hrs/manual/, the Employee Handbook at http://www.gwu.edu/~hrs/handbook/contents.html, and the Office of Human Resource Services website, at http://www.gwu.edu/~hrs. Other University employment-related policies may be found in the University’s Policies, Section III, Human Resources, at http://my.gwu.edu/mod/upolicy/index.cfm?thisTab=2&indsho=0,95,114. You may also contact HRS at (202) 994-9610.

In addition to the above, following are some of the additional steps to be taken in hiring project personnel for sponsored research programs.

15.1.1. General Position Definitions:Following are definitions of research staff positions:

15.1.1.1. Research Staff: “Research Staff” are persons holding one of the eight positions identified for this category (research assistant, senior research assistant, research associate, senior research associate, post-doctoral scientist, research scientist, senior research scientist, lead research scientist) regardless of the source of funds for the position. Research staff are generally paid from one or several sponsored research accounts.

15.1.1.2. Research Faculty: “Research Faculty” are Faculty members with the word “Research” in their titles whose appointment letter states that their continuing appointment is contingent on the availability of funds from external sources.

15.1.1.3. Graded Staff: “Graded Staff” are personnel employed in positions for which the University has assigned grades.

15.1.1.4. Regular Staff: “Regular Staff” are personnel employed by the University for a minimum of 35% effort over a continuous period of at least six months. A regular employee may be paid from a sponsored research account or from University funds.

15.1.1.5. Temporary Staff: “Temporary Staff” are personnel employed less than 35% time (700 hours or less per year).

15.1.1.6. Full-Time: “Full-Time” personnel are employed for 100% time.

15.1.1.7. Part-Time: “Part-Time” personnel are employed between 35% and 99% time.

Again, please note that a recruitment plan is only required for full-time (100% effort) positions.

15.1.2. Research Personnel – How to Effectively Find, Transfer, Recruit and Hire Researchers

The University now identifies eight positions which are collectively referred to as “research staff.” These positions are:

• Research Assistant
• Senior Research Assistant
• Research Associate
• Senior Research Associate
• Post-Doctoral Scientist
• Research Scientist
• Senior Research Scientist
• Lead Research Scientist

While these titles do not accurately describe all possible positions associated with the conduct of research, they are the ones available. Alternative “working titles” may be used for internal program purposes in addition to these eight official titles..

To save time and effort, before proceeding to establish a new position every time a new program begins, first inquire as to whether the Department already has vacant research staff positions that might be applied to the new program.

15.1.2.1. New Positions – How To Establish a New Research Staff Position: To establish and recruit for a NEW position to support a sponsored research program:

Complete a Position Establishment Memo and address it to Office of the Chief Research Officer, (via the Department Chair, Dean, and Research Services Coordinator requesting a new position http://www.gwu.edu/%7Eresearch/researchhiring.htm#rstaffnew

1. . The memo must include the following information:

• Position title
• Brief description of duties
• Minimum degree and experience required for the position
• Full-time or part-time (indicate the anticipated level of effort for part-time)
• Duration of the position
• Salary level or range
• The Oracle program/task/award number against which the salary will be charged (if position is to be charged to a University account, provide the Oracle alias)
• Home Banner Index
• Charge-to Banner Index
• Supervisor’s name and position number (for questions about position number, consult RSC)

NOTE: For part-time or wage positions simplified hiring procedures apply\ - please  proceed to step 6.

2. When the memo is approved, it will be returned with a requisition number and a position number. For full-time hires, complete an The Office of Equal Employment Opportunity (EEO) recruitment packet. Complete all forms contained in the packet. Please contact EEO at 202-994-9656 for a packet.
3. Once the requisition and position numbers are received from OCRO, write these numbers on the EEO documents and send the packet to EEO office at 2033 K Street NW, Suite 320. (EEO will already have a copy of your original memo with the OCRO approval.)
4. Medical Center only: Attach creation memo to the recruitment packet, send documents to OCRO, OCRO will forward to EEO.
5. After EEO has approved the recruitment plan, proceed with this plan following the instructions in the EEO packet.
6. Only when recruitment is finished can an offer be made. Please do not make an offer to the applicant until the search has been completed and approved. Please contact the Office of Equal Employment Activities at 202-994-9656 for a recruitment packet. Also complete:
   

   - Employee Hire Form
   - I-9 Form (to be completed by the employee with HR)
   - Recruitment Summary

   Obtain the required signatures (Department Chair and Dean) and submit the packet to your RSC who will process the hire and forward the requisite materials to EEA.
7. Obtain the required signatures (Department Chair and Dean) on the position establishment form and submit the packet to the appropriate RSC who will process the hire and forward the requisite materials to EEO.
8. OCRO will prepare an appointment letter. If additional information should be added to the appointment letter, notify the appropriate RSC.

15.1.2.2. Existing Positions – How to Recruit for an Existing Research Staff Position:

To recruit for an already established Research Staff position:

1. Write a memo addressed to the Awards Manager, Office of the Chief Research Officer, (via the Department Chair, Dean, and RSC) requesting permission to recruit for an existing position. State who is leaving the position and the following information:
• Position title
• Brief description of duties
• Minimum degree and experience required for the position
• Full-time or part-time (indicate the anticipated level of effort for part-time)
• Duration of the position
• Salary level or range (see chart, below)
• The Oracle program/task/award number against which the salary will be charged (if position is to be charged to a University account, provide the Oracle alias)
• Home Banner Index
• Charge-to Banner Index

2. When the memo is approved, it will be returned to you with a requisition number. The position number remains the same. For Fulltime Positions, complete an Office of Equal Employment Activities (EEA) recruitment packet. (Note: Please contact the Office of Equal Employment Activities at 202-994-9656 for a recruitment packet) Complete all forms contained in the packet.

3.  Once the requisition number is received from OCRO, write the requisition and position numbers on the EEO documents and send the packet to EEO office at 2033 K Street NW, Suite 320. (EEO will already have a copy of your original memo with the OCRO approval.)

After EEO has approved the recruitment plan, proceed with the plan following the instructions in the EEO packet.

4.  When recruitment is finished, complete:

• Employee Hire Form
• I-9 Form (to be completed by the employee with HR)
• Recruitment Summary
Recruitment Packet Recruitment Summary

5.  Obtain the required signatures (Department Chair and Dean) and submit the packet to the appropriate RSC who will process the hire and forward the requisite materials to EEO.

6.  OCRO will prepare an appointment letter. If additional information is to be added to the appointment letter, notify the RSC. For Research Staff Salary Ranges and Position Descriptions, see Section 8.

15.1.2.3. Research Faculty – How to Recruit Research Faculty

Due to the unique characteristics and skills required for individual research projects, 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.

15.1.2.4. Graded Staff

Under the regulations imposed on the University by the US Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions, the University is prohibited from charging clerical and/or administrative salaries to a federally funded program. Exceptions to this regulation may be made in cases where you can to answer “yes” to all of the following questions:

1. Is the clerical/administrative salary allocable to the program?
2. Are the duties of this position functionally different from those of
   institutionally funded clerical/administrative personnel?
3. Does the program have extraordinary clerical/administrative requirements?
4. Were the clerical/administrative costs budgeted in the proposal and
   approved by the federal sponsor in the award document?

To recruit and hire a regular staff position, (e.g., a senior secretary or an executive aide) 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.

15.1.2.5. Temporary Research Staff – Student

Temporary student wage employees are limited to 700 hours or less per fiscal year. The hiring of temporary student wage employees does not require a recruitment plan or Human Resources clearance. Wages should be consistent with departmental standards for comparable work.

To hire such employees:

• The Hiring Department must initiate a Hire Form for the prospective student employee. Hire Forms can be found online under the “Forms” section of the Human Resources website, http://www.gwu.edu/hr/forms_library/index.html. These Hire Forms are submitted with appropriate signatures to the RSC for approval and further processing.
• The Hiring Department receives an I-9 receipt from the student employee. The new student employee must present the hiring department with an I-9 receipt. A copy of this receipt must be retained in the Department’s student file. This receipt is the Hiring Department’s confirmation that the student has successfully completed the federally required I-9 “Employment Eligibility Verification Form” and is eligible to work in the US. Students may complete the I-9 Form only at the GW Career Center or at Human Resources Services. This form is not to be completed in the Department.
• The Hiring Department submits forms to the GW Career Center. Attach the I-9 receipt to the Hire Form and deliver both to the student employment unit at the GW Career Center.

Federal Work Study Hires:

• If the student has been awarded a federal work study award by GW’s Office of Student Financial Assistance, the Student must submit to the Department an Employment Authorization Form (EAF). The EAF is obtained by the student at The Career Center. An authorized department representative signs the EAF and keeps a copy. The EAF is attached to the Hire Form and the I-9 receipt and all three documents are submitted to the GW Career Center. These three documents are required in order for The Career Center to “Hire” the student into the Banner System.  

Submitting CIS Forms:

• If a student is already employed by the department but there is a need to change the job the student performs, the wage that is earned or the distribution of the funding for the wages, a change-in-status or CIS Form must be generated, approved by the RSC and transmitted to the student employment unit within the GW Career Center.
  

Wages for hourly research assistants/aides require timekeeping through a new reporting telephone system. It is your responsibility to supervise research assistants/aides employed on your award and to ensure that each RA is keeping track of his/her time correctly. Timesheets are no longer accepted. The new system involves the RA calling into 202-994-2274 and designating when he/she arrives and leaves for the day by dialing 1 for arrival and 9 for departure. The paperwork to hire research assistants/aides must be processed through the Office of the Chief Research Officer prior to starting work. Since this new timekeeping system has been implemented, we have noticed a few issues we would like to bring to your attention.

It is critical that you:

In addition to hourly Research Assistants, a post-doctoral scientist position can also be a temporary position.

Post-Doctoral Scientist (Post doctorate Scientist)
Primarily a temporary position in which the incumbent plays a substantive role in planning and conducting research. Requires a PhD in the field or in a related area. Familiar with a variety of the field's concepts, practices, and procedures. Performs a variety of tasks. Performs work under the supervision of experienced researchers.

15.1.2.6. Process CIS Forms
A Change in Status (CIS) form must be initiated and submitted for various approvals and subsequent entry into Banner in order to move sponsored research program personnel from one award to another award, or to change the award(s) to which personnel are charging their time. Detailed procedures for CIS processing can be found here http://www.gwu.edu/~research/files/CIS Desk Procedures final.pdf

Payroll processing dates are very important to keep in mind for successful outcomes of data entry for Hire forms and CIS forms. The tables found on this weblink http://www.gwu.edu/~payroll/calendar.html list relevant dates for the monthly and bi-weekly pay schedules for the fiscal years. As a general guideline, monthly CIS forms that are forwarded to the Research Services Coordinator (RSC) approximately 25 days prior to the “enter change date” will be entered into Banner by that date to meet the intended pay period. Similarly, biweekly CIS forms that are forwarded to the RSC approximately 21 days prior to the “period end date” will be entered into Banner by that date to meet the intended pay period.

There will be instances in which circumstances prevent the processing of CIS forms according to these guidelines. In these cases, the initiator should contact either the CIS Form Help Desk at cishelp@gwu.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.

15.2. PROCUREMENT PROCEDURES

15.2.1. Procurement Policy Overview

In accordance with the University’s Bids, Quotes and Sole Source Justification Policy http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFINAL.pdf the University procures goods and services for Sponsored Programs based on the standards applicable to federally-sponsored programs. Such procurements require appropriate approvals and detailed documentation that will generally be sufficient to meet the rules of state, local or private sponsors as well as the requirements of a specific sponsored agreement. Any additional procurement requirements of a particular sponsored agreement also should be addressed as necessary. 
                    
15.2.2. Preferred Suppliers

Purchases are simplified if Preferred Suppliers are used. When SCO receives a purchase requisition, they check to see if the goods and services are covered by an existing contractual agreement with a Preferred Supplier indicated on the Preferred Suppliers List at http://www.gwu.edu/~supchn/prefvend.htm . A “Preferred Supplier” is one that has met certain University requirements, price, quality and other factors considered.  Additional competitive processes are not required in acquiring goods and services from Preferred Suppliers. SCO will issue Purchase Orders to Preferred Suppliers if possible.

The University’s Supplier Selection policy provides details on obtaining approvals for suppliers. See http://my.gwu.edu/files/policies/SupplierSelectionFINAL.pdf. For information as to whether a vendor is a Preferred Supplier or how a vendor may be qualified as a Preferred Supplier, please refer to the SCO website,  http://www.gwu.edu/~supchn/supplier_registration.htm or Appendix E for current SCO listing of Preferred Suppliers.
.
15.2.7. Foreign Suppliers
Investigators interested in initiating activity with potential supplier should be aware that before any supplier or individual can receive payment from GW, they must first  register as a GW-approved supplier. Contact the appropriate RSC for information on this process, which includes the supplier or individual completing a Supplier Registration Form, supplying GW with their appropriate tax-identification number, and subscribing to GW’s Supplier’s Code of Conduct. For a copy of the Supplier Registration Form, see the SCO website at http://www.gwu.edu/~supchn/supplierreg.pdf.  Special tax rules apply to individuals who are not US citizens or permanent residents, Before non-US citizens, organizations, or companies may receive payments from The George Washington University, they must consult and register with GW’s Tax Department. The Tax Department may be reached at 202-994-2556.

15.3. PURCHASING EQUIPMENT ON SPONSORED PROGRAMS

Federal Procurement Policy and  2 CFR (Code of Federal Regulations) (OMB A-110  Circular) sections 215.41 through 215.48 set forth standards for use by recipients of  in establishing procedures for the procurement of supplies and other expendable property, equipment, real property, and other services with Federal funds. Under this regulation, the files of the University must include the following for procurements in excess of $25,000

• Basis for contractor selection
• Justification for lack of competition when competitive bids or offers are not obtained, and
• Basis for cost/ price agreement.

Capital Equipment at GW is defined as any equipment having a unit cost of $2,500 or more and a useful life of two years or more.
To align GW with current federal practice, the University maintains a formal procurement system to satisfy requirements for how goods and services are acquired on Sponsored Programs.  The GW Policy   has been provided here for reference.  When equipment is procured, conflicts of interest should be avoided at all times.  GW maintains a list of conflicted vendors, these vendors will be checked against the list by the RSC’s prior to any purchase being made. University Policy explicitly prohibits employees from participating in the selection, award or administration of a federally funded contract if a real or apparent conflict of interest exists. 

Equipment procured at thresholds of $2,500 or more shall be conducted in a manner to provide the maximum extent practical, open and free competition OR through the single/sole source mechanism as delineated below in the embedded link.

Equipment Purchases $2,500 - $25,000 under Sponsored Projects

• Equipment must be listed in proposal budget and approved by the sponsor.
• If equipment was not originally proposed or budgeted to sponsor, contact your RSC who can provide guidance if re-budgeting can occur or sponsor approval is required. If sponsor approval is required, PI’s will draft correspondence requesting the equipment purchase and send to the RSC who will then send to sponsor.
• Determine what and from whom you’re buying equipment items.  The PI or the PI’s designee must obtain access to the Oracle Purchasing System through the Enterprise Accounting System to generate a Purchase Requisition.
• Equipment can be purchased from preferred suppliers. If purchasing from a preferred supplier, quotations are not required. http://www.gwu.edu/~supchn/prefvend.htm.
• If equipment item(s) cannot be obtained from a Preferred Supplier listed in Oracle or on the SCO site, then the SCO or the PI should obtain three written quotes in accordance with the Bids, Quotations, and Named Source Justification Policy http://my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFINAL.pdf
• This policy includes Appendix A, the Selection of Source Form.  If the PI obtains the quotes, the Selection of Source form must be sent to Supply Chain and can be attached to the purchase requisition in Oracle as the purchase requisition is initiated.  If the SCO obtains the quotes, the Selection of Source form is not required.

Procurements between $25,000 and $100,000

• The Selection of Source form is required.  The form is signed by the PI and the RSC.  The form is attached by the PI at the time the purchase request is initiated in Oracle.

Equipment Purchases >$100,000

• Selection of Source form is required
• The option to request written quotes or formal bids via a Request for Quotation (RFQ) or Request for Proposal (RFP) are required if the estimated amount of the single contract or the multi-year contractual agreement exceeds $100,000.

Please note that the form entitled “Selection of Source” form, see Appendix E, can also be used for the selection of an Independent Contractor (previously Consultants/Service providers).

15.4. INDEPENDENT CONTRACTORS

15.4.1. Independent Contractors:

The following information, forms, and procedures are provided to assist in dealing with Independent Contractors.

Independent Contractors (“ICs”) have unique expertise, provide professional advice and guidance, provide a distinct service or product, typically a report, translation, analysis, or the like.  The work is usually performed off University premises and often offered to many different buyers within normal business operations.  The work performed by an Independent Contractor is ancillary to GW’s sponsored project but necessary to carry out the overall objectives of GW’s sponsored award.  ICs are not employees of the University and may not use GW resources to perform their services.  Formerly, these agreements were called Consulting/Services Agreements.  Effective July 1, 2007, GW will enter into Independent Contractor Agreements. 

A PI should not confuse an Independent Contractor with a Subrecipient.  A subaward is collaborative in nature whereby the subrecipient is performing an actual portion of GW’s statement of work to the prime sponsor.   A subrecipient may be a co-author in a publication or may seek protection for his or her invention.  Subrecipients have their performance measured against the portion of the scope of work proposed to GW and have the responsibility for programmatic decision making.  The scope of work proposed by a subrecipient is generally of a research and development nature performed on a best efforts basis.  The cost proposed are generally based on estimates as the outcome may be unpredictable.  The appropriate RSC within the OCRO is available to provide information and assistance in initiating Subawards when appropriate.  Please see Section IV of the handbook for proposing Subawards.

15.4.2. How to Process Independent Contractor Agreements:

Prior to entering into an ICA, a PI must submit the following forms to his/her School Research Administrator or Departmental Administrator.  These documents must be attached at the time the purchase requisition is initiated.

• Request to Enter into an ICA form (forward to RSC independently) 
• Twenty Factors Test (for an individual not associated with an entity).  Note:  This form is used to confirm that an individual is acting as an independent contractor and should not be engaged as an employee. This form is required for all Independent Contractors when the Independent Contractor is an individual http://www.gwu.edu/~supchn/twentyfactors.pdf
• Resume or Curriculum Vitae (if not originally included the proposal to the prime awarding agency and if Contractor is an individual)
• Selection of Source Form http://www.gwu.edu/~supchn/forms.htm. This form is required for all services exceeding $2,500 on Sponsored Projects when the department or the PI names the source or provides the quotations.  If the SCO conducts the sourcing, this form is not required.   The form must be attached to the purchase requisition in Oracle.  See http://eas.gwu.edu/home/support/documentation/documentation.cfm for instructions regarding attaching documents.
• Supplier Registration Form if this is the first time the supplier has conducted business with GW.  http://www.gwu.edu/~supchn/supplierreg.pdf
• W9 http://www.gwu.edu/~supchn/supplierreg.pdf
• Foreign Nationals performing services inside the US must submit the following to the Tax Department: 

      1) Alien Information Request Form (AIRF)
      2) Form W8-BEN
      3) Copy of U.S. Visa
      4) Copy of Foreign Passport
      5) Copy of I-94 Card

As work is completed according to the terms of the Independent Contractor Agreement, invoices received from the company/entity or individual should be approved by the Principal Investigator and submitted to Supply Chain using Payment Request Forms. Please reference the PO# on payment request forms.

15.4.3. How to Extend Independent Contractor Agreements: Depending upon restrictions of the award under which an agreement has been issued, Agreements may be extended by issuing a modification to the individual or company through OCRO, modifying the agreement as necessary. Please note that extensions should be issued prior to the expiration of the current agreement. If an agreement expires and additional services are required, a new agreement should be issued, provided, however, that the extension can not be for a period of time that is longer than the prime award.

If an agreement is to be extended, the forms and documents (Twenty Factors Test, Selection of Source, etc.) already on file in the OCRO concerning the original agreement will be sufficient. In most cases, only the modification is needed by the OCRO. However, if an extension obligates additional money, which when added to the original funding brings the total obligation to $2,500 and/or $25,000, the Selection of Source document may be required (see above).

15.4.4. Procurement Follow-up:

For further information on procurement of goods and services for sponsored programs, please refer to the  Bids, Quotes and Sole Source Justification Policy, my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFINAL.pdf, contact the appropriate RSC within the OCRO http://www.gwu.edu/~research/orsstaffing2.htm#rsc, or consult the SCO website, www.gwu.edu/~supchn/scmain.htm.

15.5. SUBAWARDS

A “Subaward” means an award of financial assistance in the form of money, or property in lieu of money, made under an award by a recipient to an eligible subrecipient or by a subrecipient to a lower tier subrecipient. The term includes financial assistance when provided by any legal agreement, even if the agreement is called a contract, but does not include procurement of goods and services (independent contractors). Subawards terminology is primarily associated with grants and cooperative agreements. Subawards are issued to Subrecipients when the intent is to work collaboratively with another organization or institution to help carry out the goals and objectives included in GW’s prime award from the sponsoring agency. Each subrecipient of a subaward will have its own PI responsible for the subrecipient’s programmatic decision making.

Subrecipients are subject to the compliance requirements and the award terms and conditions that flow down from the PI’s prime award. In addition states, local governments, and non-profit subrecipients with annual federal funding in excess of $500k are subject to the audit requirements in OMB A-133
GW serves as the legal awardee and as such is primarily responsible to ensure that all obligations of the award are met. A subaward may be referred to as a subgrant or subagreement where GW’s prime award is a grant or cooperative agreement. In both cases the purpose is to work collaboratively with another entity (subrecipient) to carry out the objectives for which the program funding has been awarded.  
If GW receives a prime award that is contract, then any third party agreement will be issued as a subcontract and will be subject to procurement regulations.
A subaward shall be used when:

• GW (with assistance from its sponsor, as required) determines who is eligible to receive the subaward;
• the Subrecipient has its performance measured against whether the objectives of the sponsored program are met;
• the Subrecipient has responsibility for programmatic decision-making;
• the Subrecipient assumes responsibility for adherence to applicable sponsor program compliance requirements; and
• the Subrecipient uses sponsor funds to carry out a program (Statement of Work) of GW as compared to providing goods or services.

To review the forms required to enter into a Subaward, go to the following link:  http://www.gwu.edu/~research/preforms.htm

15.5.1 Subrecipient Monitoring

The Principal Investigator has the primary responsibility for fiscal and technical monitoring of his or her subrecipient; however, many other offices also play a significant role in subrecipient monitoring as delineated below.
GW’s approved template for subawards specifically includes provisions that permit GW to audit subrecipients as appropriate on GW programs. The University Policy on Subrecipient Compliance states that the University is responsible for entering into research subawards responsibly. This policy outlines procedures for assessing the financial stature of proposed subrecipients and it explicitly identifies various methods for monitoring performance relative to the scope of work, compliance with laws and regulations, and award specific terms and conditions.
For the University’s policy regarding subrecipients, including annual GCAS review requirements of subrecipient audit reports, see http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.pdf
Subrecipient Monitoring Roles and Responsibilities:
Principal Investigator

• Reviews technical reports from subrecipients;
  
• Maintains original copies of technical reports or other deliverables including the final report for a period of at least 3 years for record retention purposes.
  
• Review of invoices from subrecipient to ensure expenses are appropriate for work being performed.
  
• Signs or initials invoices to indicate approval and forwards to his or her RSC.

OCRO

• RSC/SRA’s review invoices  to verify PI approval and allowability of expenses;
• If necessary, obtain clarification and detailed documentation from subrecipient of invoiced charges for explanations on allowability of costs;
• Coordinates with GCAS for further instructions for potential on-site monitoring and awaits additional guidance from GCAS should justifications of allowability become questionable.
• Provide copies of final report to Executive Coordinator for Documentum scanning.  Simultaneously, notifies ORT&C Director of final report receipt;

ORT&C

• ORT&C maintains database for subrecipient monitoring of final reports from subrecipient and works with PI and RSC to ensure timely receipt of deliverables. 
• ORT&C maintains a list of the most recent approved subrecipient list prior to execution of subrecipient agreement.

 

GCAS

• Reviews all subrecipient audit reports and financial statements prior to execution of a subrecipient agreement.
• GCAS responsible for maintaining internal controls necessary to document subrecipient cost-sharing (if any) and that expenses-to-budget have been met and are allowable in accordance with Cost Accounting Standards and the terms and conditions of the award.

These guidelines and procedures are provided to assist responsible faculty and staff in ensuring that subrecipients conduct their portions of the research statement of work in compliance with laws, regulations and terms and conditions of the subrecipient agreement and that project costs incurred by subrecipients are reasonable and allowable.

The above list is not exhaustive of all compliance requirements. In addition to the general elements of compliance noted above, there may be additional sponsor- or program-specific requirements that mandate collecting and documenting other assurances (e.g. on lab animals, human subjects, biohazards, etc.) during the course of a project.

15.6. PROCUREMENT CARDS (P-CARDS)

15.6.1  P-Card Policy

GW’s policy is to use a GW Procurement Card (P-card) for most low-dollar purchases, defined as those less than $2,500, including for goods, services, and travel expenses.

Procurement requests in excess of the low-dollar threshold, or those that have special purchasing restrictions imposed by the sponsored research agreement or GW Policy, must be ordered through the Supply Chain Organization on a purchase order and be recorded through the Enterprise Accounting System (EAS). The P-card is simply a procurement and payment method and does not change any existing Supply Chain Organization policy regarding preferred vendors, restricted purchases, documentation requirements and so forth.

It is the Principal Investigator’s and department’s responsibility to monitor the usage of their P-cards. Although there are simplified procedures for acquiring items with P-cards, the same requirements for reasonableness, allowability, allocability and consistency apply to these purchases. For example, even though an item only costs $100, it could not be bought on a P-card and charged to Program A if it was allocable for use on Program B. To further monitor such P-card charges, on a monthly basis, P-Card purchases are subject to review by the Research Services Coordinator for reasonableness, allowability, allocability and consistency.

For general information regarding P-card use, including a list of restricted items not available for purchase with a P-card, refer to the P-Card Policy at http://www.policy.gwu.edu. For more detailed information refer to the P-Card Policies and Procedures Handbook located at http://www.gwu.edu/~supchn/PCardManual.pdf.  P-cards are issued to individuals, not departments, and the only person authorized to use a P-card is the individual whose name is embossed on the P-card. Please note that the Medical Center does not permit P-cards to be used for travel.

15.7. TRAVEL – HOW TO ARRANGE FOR TRAVEL

15.7.1. Pre-approval for trips

Prior to taking a trip funded under a sponsored program, obtain approval from the appropriate RSC within the Office of the Chief Research Officer. This review is to assure that the trip is allowable: that there is funding available, that it is related to the purpose of the grant, that it occurs within the period of the award, and that the person traveling is associated in some way with the program. If the purpose is to attend a conference, it is very helpful to attach a brief memorandum stating why attendance is necessary in order to perform on the program.

15.7.1. Pre-approval Form: The form used for this purpose is the Travel Authorization/Advance Request/Expense Report. This form is available on-line at the following web site: http://eas.gwu.edu/home/forms/sc/sc.cfm

• Select Forms
• Select Accounts Payable
• Select Travel Authorization/Advance Request/Expense Report

The traveler (or designee) fills out Section 1 of the form, including:

• Traveler's Name
• Social Security Number
• Mailing Address
• Itinerary (with dates)
• Purpose of Travel

The traveler signs and dates the form in Section 2, and adds the Oracle program/task/award number to be charged. The department chair must also sign and date in Section 2. The expenditure types typically used for travel are:

• 53102 - Meals (business)
• 53111 - Domestic Travel
• 53112 - Foreign Travel
• 53121 - Local Travel
• 53131 - Non-GW Travel
• 53132 - Trainee Travel

15.7.2. Pre-Approved Travel Form Submission: When completed, submit the form to the appropriate Research Services Coordinator assigned to the department/school for review and approval. Forms may be faxed to the RSC. After approval, the form is returned to the traveler for use in submitting expenses.

If you wish to charge airline tickets directly to award funds, work through one of GW's approved travel agents. Fill out Sections 1 and 2 of the form and add a note indicating which travel agency is involved. See the Auxiliary Services web site for links to approved travel agents. The appropriate RSC within OCRO will fax the completed and approved form to the agency to complete the purchase. Tickets are initially charged to an institution-wide American Express account. The cost of the tickets is not transferred to the P/T/A until the trip is completed and the travel claim is filed. Travel Agency Waivers are no longer required if you choose to use another travel agency.

Should you need a travel advance, complete Section 3 of the form. This asks for some of the same information and signatures required in the Section 2, but also asks for the amount of the advance requested. The typical advance is issued at the rate of $100 per day. Extraordinary requests require additional justification, which may be attached to the form. When an advance is requested, the RSC approves the request and forwards the form to Supply Chain, returning a copy to the traveler.

After the trip is completed, use the same form to request reimbursement. Report expenses in Section 4. Attach receipts, indicating the accounting distribution, and sign the form again at the bottom. NOTE: The GW Travel Policy http://my.gwu.edu/files/policies/TravelandEntertainmentPolicy.pdf requires original receipts or a signed statement by the traveler for all expenditures regardless of dollar amount except for meals. Original receipts are required for expenditures on meals equaling or exceeding $35. Send the completed form to the RSC for review and forwarding to Supply Chain.

For further information regarding travel advances, see http://my.gwu.edu/files/policies/TravelAdvanceFINAL.pdf. For rules and restrictions on travel and entertainment, see http://my.gwu.edu/files/policies/TravelandEntertainmentPolicy.pdf.

15.7.3. Travel Advisories

Travel to countries subject to U.S. State Department Travel Advisories is subject to additional reviews and approvals. For further information, please consult with the appropriate RSC within the OCRO.

15.7.4. Free International Travel Assistance Program
The George Washington University has purchased an international travel assistance program that is of tremendous benefit for ALL faculty, staff and students of GW who travel internationally on university-related business or study. This program is for those participating in study abroad (semester, year, summer or short term), international internships or field work (whether for credit or not) and teaching or researching abroad. The coverage is free to individual users simply by registering with the assistance provider, International SOS - http://www.internationalsos.com .

GW's program with International SOS includes coverage for evacuation and repatriation for both medical and political reasons. Medical evacuation and repatriation applies when an individual is in need of acute medical care and is unable to receive such care in the local area. Individuals are transported, with medical staff assistance, to facilities that can better address their needs. Political evacuation applies when an individual is caught in an area that has become dangerous due to a political situation. Political evacuation coverage is especially important for those who travel and study in areas of the world where a historical pattern of strife exists.

For specific information about the program and a list of Frequently Asked Questions, please visit http://www.gwu.edu/~riskmgnt/travelinsurance.cfm . If you have any further questions regarding the international travel assistance program, please feel free to contact the Office of Risk Management at 202-994-3265 or via email at risk@gwu.edu.  If you have questions pertaining to study abroad, please contact the Office for Study
Abroad at 202-994-6242.

 

Section 16:  Program Income

16.1. PROGRAM INCOME OVERVIEW

16.1.1. Program Income Defined
 
Program Income is any income earned by the recipient of a sponsored award that is directly generated by a supported activity, or earned as a result of the award. Such income may include income from fees for services, use of property acquired under a sponsored program, the sale of goods or items developed under the sponsored program, license fees and royalties on intellectual property such as patents and copyrights.

16.1.2. Acceptable Uses of Program Income
                                                         
OMB Circular A-110 and the Code of Federal Regulations set forth specific requirements for the identification, use, accounting and reporting of income generated from a federal sponsored program during the program period.  To be consistent, the University extends the requirements of OMB Circular A-110 to income generated on all programs sponsored in whole or part by both federal and non-federal sponsors, except where the terms of any such agreement are explicit and mandate some other treatment.  

16.1.3. Identifying Program Income

 The Principal Investigator (Principal Investigator) is responsible for identifying sources of actual or potential program income. Appendix A to GW’s Policy on Program Income provides guidance for determining whether any income earned as a result of a sponsored program is program income.  This Appendix A Guide to Identifying Revenue Generating Activities and Program Income includes the following:

Any external or internal sale that results from a sponsored activity is likely to be program income. If the activity will be partly or fully supported by sponsored funds, it is program income.  A non-exhaustive list of examples of program income includes:

• Income from fees for services performed such as laboratory tests;
• Money generated from the use, sale, or rental of equipment purchased with program funds;
• Proceeds from the sale of supplies or equipment purchased or fabricated with program funds;
• Proceeds from the sale of software, tapes, or publications;
• Income from the sale of research materials such as animal models;
• Fees from participants at conferences or symposia; and
• Sales of products with an accompanying material transfer agreement.
• Income generated from license fees and royalties on patents and copyrights is included in the federal definition of program income. However, unless federal awarding agency regulations or the terms of the sponsored program specifically state that income generated from license fees and royalties on patents must be reported as program income, GW has no obligation to the federal government with respect to this program income.

Even if the Principal Investigator includes this income in the proposal budget calculations, it will be program income and the proposal routing form must be completed accordingly. For example, if conference fees are to be used to cover part of the cost of the program, this revenue is still program income. The Principal Investigator, in consultation with his/her Chair is responsible for knowing that a sound accounting system, specifically a cash management system conforming to generally accepted accounting principles, has been developed for the financial management of the program income project. The Principal Investigator obtains the guidelines for developing such a cash management system from the school or department’s designated financial manager. These guidelines should include at a minimum:

• Payment instructions;
• A receipt register for tracking receipts; and
• A periodic reconciliation of the receipt register to the record of deposits.

The Principal Investigator should also notify the RSC so that a Project-Task-Award (PTA) for the program income activity can be created in the EAS (Oracle) financial system and so that the RSC can assist the Principal Investigator in reviewing sponsor regulation and/or specific award terms to identify which options are available for using the program income and in managing that the program income plan is being implemented properly.

A Principal Investigator needing further guidance should call his/her Research Service Coordinator (RSC) in the Office of the Chief Research Officer (CRO). The GCAS Research Administrator should be consulted on the proper use and reporting of Program Income to verify that no unintended tax or other consequences result. For more details on Program Income, please refer to GW’s Policy on Program Income, my.gwu.edu/files/policies/ProgramIncomeFINAL.pdf or see OMB Circular A-110.

16.1.4. Service Centers

Income generated may also involve establishing Service Centers which entail a complicated series of financial and tax consequences. A Service Center is an entity that provides a broad range of specific technical or operational services primarily for internal users throughout campus for a fee.. For further information, please confer with a GCAS Research Administrator, the OCRO RSC, or the University’s Tax Office as well as referring to the University’s Policy on Service Centers http://my.gwu.edu/files/policies/InterdepartmentServiceRechargeCenters.pdf.

 

Section 17 Award Administration

In addition to accomplishing the technical performance requirements of the Project, there are many management and administrative requirements relating to the University’s responsibility for completing the Project.  This Section provides guidance to the Principal Investigator in exercising his or her responsibility to oversee the execution of the Project plan on behalf of the University.

This Project Management Section includes coverage of the Principal Investigator’s responsibilities for managing the following:

• Project Financial Responsibilities
• Project Changes and Required Approvals
• Transferred Projects
• Project Reporting and Deliverables
• Project Intellectual Property Responsibilities
• Capital Assets and Disposition

17.1.  PROJECT FINANCIAL RESPONSIBILITIES

17.1.1. Financial Management

GW’s faculty and staff are accountable for processing and recording financial transactions on sponsored programs in a timely and proper manner. For all sponsored research activities, as well as all other business activities of the University:

• All revenues generated by University activities and all expenditures for goods and services must be recorded in the Enterprise Accounting System (EAS),
• All financial transactions should be recorded in a timely and accurate manner and in a way that clearly and completely identifies the true business nature of the transaction,
•  All funds and assets must be used for a lawful and proper purpose,

GW uses the Enterprise Accounting System (EAS) financial system to track and monitor program expenditures on sponsored programs. With a little training, Principal Investigators can check EAS at any time to see what expenditures have posted to their award and how much money is not yet spent. Committed salary costs appear in the Banner Payroll system, and monthly reports on these costs are available and should be reviewed each month to monitor labor charges on programs.

17.1.2. Principal Investigator Monthly Cost Monitoring

It is important for Principal Investigators to monitor monthly program expenditures. Cost monitoring involves two main activities: checking to see that desired charges have posted, and ensuring that incorrect charges do not post or that they are promptly removed. There are a host of sponsor and University rules, requirements and polices that are dependent on timely and effective monitoring and control of Program expenditures. These are dependent on the Principal Investigator maintaining careful review to verify that items that are expected to be charged to the Program are being charged as planned, and that any unexpected charges are promptly noted and corrected as appropriate. As with reviewing Banner Payroll Reports, Principal Investigators should monitor awards on a monthly basis so as to be able to address any issues as soon as possible. This is especially critical at the end of an award to avoid overspending.

It is not uncommon that certain otherwise allowable charges are precluded because they are not identified until it is too late to include them in invoices to sponsors. On the other hand, the University will not permit any unallowable charges to remain on a Program regardless of when they are discovered. As such incorrect charges will be transferred off the Program, sometimes leaving an unexpended balance.

Another vital reason for careful monthly monitoring of expenditures on Programs is that the University’s Effort Reporting system is dependent on Banner Payroll Reports. These Banner Reports reflect the anticipated charges of Program personnel and become the basis of subsequent Effort Reporting certifications. To the extent that these charges are not accurate, it is important that they be reviewed monthly so that appropriate Change is Status forms can be completed, thereby ensuring that program charges are correct and that subsequent Effort Reporting certifications are accurate. For further information on Effort Reporting certifications and requirements, please see Section 25, Effort Reporting.
To facilitate monthly reviews, Principal Investigators may request that their RSC schedule monthly expenditure reports to run automatically. Principal Investigators will then receive email with links telling them to check their Budget Performance Reports.

17.1.3. Charging Practices

17.1.3.1. Direct Costs:  A “Direct Cost” can be specifically tied to the work conducted on a program. Such costs provide direct benefits for a specific programmatic purpose..

Examples of typical direct costs include:

• Project-specific personnel (salary for Principal Investigators, technicians, etc.)
• Consultant fees
• Technical equipment and lab supplies specifically required to complete goals of sponsored programs
• Travel
• Patient care costs
• Animal care costs
• Subcontract costs
• Long-distance telephone charges

17.1.3.2. Facility and Administrative (F&A) or Indirect Charging Practices: F&A or Indirect costs cannot readily be allocated to a specific program but are part of the University’s costs of carrying out sponsored research activities. For example, the costs for general office supplies such as paper, staplers, file folders and the like are items that the University provides to support research activities without direct charge to the program. F&A costs, which include on-campus space and utilities devoted to research purposes, administrative and library support for the University's research effort, etc., represent real costs to the University in conducting research, real, but by their nature cannot be directly allocated to a specific program. Another substantial F&A cost is for administrative and clerical salaries. GW’s policy is to treat administrative and clerical salaries as indirect costs, except in unusual circumstances as detailed in Section 4.1 of GW’s Policy on Consistency in Charging Administrative and Clerical Costs Associated with Research  at  http://my.gwu.edu/files/policies/ConsistencyinChargingAdminandClericalCostsFINAL.pdf.

Additional examples of typically F&A (indirect) items include:

-Operation/maintenance of University facilities
-Depreciation/use of buildings and equipment
-Library services
-Research Administration

• Department Administrative and clerical salaries
• Office supplies
• Most Postage
• Telephone service
• Other supply and related costs (e.g., photocopying).

F&A rates are periodically negotiated with GW’s cognizant agency, the Department of Health and Human Services, and rates are established for both on- and off-campus activities for both the University and the Medical Center. “Off-campus” refers to a program housed in a space that is rented or provided to the program by the sponsor. 

17.1.3.3. “Major Project” Exception - Unlike Charging Circumstances: While administrative and clerical salaries are generally not allowable as direct charges, there are limited circumstances where these normally indirect charges may be charged directly. These circumstances only occur in relatively rare cases with specific written approval of the sponsor when a sponsored program or activity, due to its size and nature, requires administrative or clerical services, supplies, postage and/or telecommunications costs that are well beyond the core of departmental support routinely provided for departmental activities. In such cases, the program typically has a “Major Project” designation (OMB Circular A-21, Exhibit F). Because of the requirements for prior approval, Investigators interested in determining whether a Major Project designation might be possible should confer with the applicable Research service Coordinator as early as possible.

17.1.3.4. Select Charging Practices for Common Items: For more details and a comparison of direct and indirect charge items, the following chart provides charging practice guidelines on specific items commonly associated with running programs.

Charging Practice Examples by Categories

Category	Direct	Indirect
General Office Supplies	Office supplies may be charged directly to sponsored accounts when The supplies can be specifically identified with the work of a particular program or group of programs There is a high demand for the supplies as described in the budget justification If supplies are used by multiple programs, the allocation between the programs is reasonable and documented appropriately A program requires specific-purpose computer software (usually involving line item approval in the proposal budget)	General office supplies (e.g., pencils, paper, staples, etc.) or general purpose computer supplies (e.g., paper, diskettes, general purpose software) should be charged to department or other non-sponsored accounts
Postage	Regular postage may be charged directly to sponsored accounts when: There is a high demand for postage as described in the budget justification Postage can be specifically identified with the work of a particular program or group of programs A meter or log is used to document the appropriateness of the charge to the sponsored program(s)   Overnight mail costs (e.g., FedEx, UPS) may be charged directly to sponsored accounts only if the cost is program specific (e.g. specimens)	Regular postage should be charged to department or other non-sponsored accounts
Telephone	Basic/local telephone service costs may be charged directly to a sponsored account in relatively rare circumstances when: A dedicated line is installed solely for the performance of the program The size and nature of the program requires extensive use of such a service which are described, in detail, in the budget justification to the sponsor Long distance telephone service costs should be charged directly to sponsored accounts provided that: Costs can be identified and allocated appropriately to the program or programs that received the benefit The costs are reasonable and necessary to perform the program	Basic/local telephone service costs are almost always indirect costs

17.1.4. Accounting for Cost Sharing

In addition to monitoring expenditures in the monthly Budget Performance Reports.for sponsored awards, the Principal Investigator is responsible for monitoring cost share on sponsored research programs. The Principal Investigator is responsible for initiating the cost sharing charges as they do not automatically occur on the project just because they were part of the approved budget and award set-up. Cost sharing documentation must be prepared contemporaneously with program progress as opposed to waiting until program completion. If the monthly report does not include the appropriate allocation of cost share, then PIs should seek assistance from the applicable RSC and/or School Research Administrator (SRA) or Departmental Administrator.   

Cost sharing charges on federal programs, like charges to the sponsor, must meet the requirements of OMB Circulars A-21 and A-110. 
 Normally, cost sharing charges must be:

• Necessary, reasonable, allocable to the award and allowable
• Verifiable from GW’s records
• Expended if approved in the award budget before the program is completed.

Cost shared expenses must NOT be:

• Already committed expenses or included under another federally sponsored program
• Paid by any federal sponsor under another agreement unless authorized by federal statute for that purpose and approved in writing.

Cost Sharing also has implications for Effort Certification because Effort Certificates break out as separate line items, with IXXS charge numbers, any cost sharing of labor for the period in question. Researchers on the Program will be asked twice a year to sign Effort Certificates to certify the percentages of effort for sponsored research. In doing so, these researchers are also certifying the correctness of the other line items listed, including any for cost sharing. By initiating the cost sharing charges on the program and monitoring them monthly, the Principal Investigator helps keep the cost sharing charges on the program accurate so that the cost sharing information supporting the Effort Certification process will also be accurate as well.

17.1.5. Cost Transfers & Approvals: GW’s policy is to record all financial transactions to the proper organization, funding source and account in a timely manner. A “Cost Transfer” is the mechanism for moving charges from one account or fund center to another. Under University policy, errors in the allocation of direct costs to sponsored programs are to be identified, corrected and documented in a timely and consistent manner. Charges to be moved should be allocable, allowable and justified costs to the new specified award. It is imperative that these transactions be made to correct errors in posting, not to manage cash flow when there are more funds available in one award than in another. The latter is prohibited and not practiced at GW.

17.1.5.1. Transfers Requiring Special Approvals: Occasionally, in posting charges, some charges are initially assigned to the wrong account and appropriate corrections are made. Under certain circumstances, however, such cost transfers require further justification and a corrective action plan as well as approvals by the CRO and the Comptroller. These include:

• Second Transfers of Erroneous Charges - A charge to a sponsored agreement that is determined to be erroneous can be moved only once. Any further transfers require detailed justifications and written approvals.
• Late Transfers - Errors in charging costs to a sponsored agreement must be identified and the appropriate correction initiated within 90 days of the error or within 30 days after the end of the grant period, whichever date occurs first. Any transfers occurring outside these periods are Late Transfers and they require additional justifications and approvals.
• Already Certified Payroll Charges – Payroll cost transfers occurring after Effort Certifications related to those charges have been made must be necessary to correct a material error, and must be explained in writing.
• Already Ended Agreements - If an adjustment is otherwise appropriate to be made to a sponsored agreement that has already ended and for which the final financial report has been filed with the sponsor, the University Comptroller, along with OCRO and GCAS, will assess whether the University will request the adjustment from the sponsor or absorb the impact of its mistake due to the delay in detecting it. If the adjustment is not requested/permitted, then the cost will be charged to the department in which the sponsored agreement was housed.

Any credit due to a sponsor is always processed, regardless of when discovered.

The primary responsibility for recording charges to the correct sponsored agreement is at the academic department level when the costs are incurred and recorded. The Principal Investigator’s signature is required for all cost transfers, and department Chairs and fiscal personnel are responsible for following GW’s guidelines for cost transfers. Errors in charging costs must be identified and appropriate corrective action taken within 90 days. For errors discovered after that, a detailed written explanation must accompany the request stating the reasons for the error and what actions are being taken to prevent the recurrence of similar errors. This explanation is submitted through the RSC to GCAS for approval by the University Comptroller. Every effort must be made to correct errors in the same fiscal year in which made. Cost transfers to reimburse sponsors must be processed as soon as the error is made. Cost Transfers must be made for proper reasons and not simply because of funds availability. The OCRO RSCs review and approve cost transfers including review of the specific sponsored agreement applicable to verify the allowability of a proposed cost transfer.

17.1.5.2. Cost Transfer Process and Forms: For more information on Cost Transfers, see the University’s Policy at http://my.gwu.edu/files/policies/CostTransfersSponsoredAgreementsFINAL.pdf, and the University’s Financial Transactions Adjustment Policy,  http://my.gwu.edu/files/policies/FinancialTransactionsAdjustmentPolicyFINAL.pdf. Non-payroll cost transfers are initiated using a Departmental Corrections Form (DCF), and Payroll cost transfers are initiated using the Change in Status (CIS) form, www.gwu.edu/~hrs/pdf_files/CIS.pdf.

17.1.6. Statute of Limitations: Financial Responsibility

Principal Investigators need to be aware of the potential for financial impacts to their respective departments or schools when sponsored research programs do not go as planned and issues occur such as uncollectible account receivables. As provided in the University’s Policy on Financial Responsibility, http://my.gwu.edu/files/policies/FinancialManagementRespFINAL.pdf, in order to effectively monitor the finances of sponsored programs, efforts are required from three primary sources: the department/school’s Principal Investigator, the OCRO Research Service Coordinator and the GCAS Research Administrator. 

The role of the Principal Investigator is supported by the department chair and the dean (or their designees). The RSC is assisted by others in the Office of the Chief Research Officer, and the Research Administrator is assisted by others in Grants and Contracts Accounting Services.

Each participant has a specialized role to play and a “Statute of Limitations” has been established for allocating the financial impact when programs incur financial difficulties. The University’s Financial Statute of Limitations is predicated on the following Statement of Financial Responsibilities.

Principal Investigator

• Supervises the technical performance and cost progress of the program
• Reviews the award terms and conditions and manages the program expenditures
• Notifies the RSC of completion of deliverables in a timely fashion
• Coordinates award close out with RSC, including requesting assistance with obtaining authorization for any No Cost Extensions (NCEs) as may be required.

Chairs/Deans

• Provide overall program management including as further discussed in The Chair’s Roles and Responsibilities for Oversight of Sponsored Programs at GW  http://www.gwu.edu/~research/files/chairresponsibilites.pdf

OCRO Research Service Coordinator

• Establishes the award in EAS (the enterprise accounting system)
• Helps train the Principal Investigator as well as the  program, school, and department staff in the policies and procedures involved in research administration
• Assists with post-award administrative tasks
• Supports the preparation of necessary financial reports
• Assists the Principal Investigator in obtaining a NCE if approved by the sponsor
• Assists the Research Administrator with the closeout process

GCAS Research Administrator

• Prepares financial reports
• Provides ongoing accounting, adjustment and reconciliation support
• Bills and collects accounts receivable (with assistance of the Principal Investigator in contacting counterpart to clarify any billing disputes)
• Coordinates award closeouts

Additional information regarding specific responsibilities is found at http://www.gwu.edu/~research/awdmgmt.htm  and see Statute of Limitations: Financial Responsibility, Roles and Responsibilities. For additional information, see also GW’s Financial Transactions and Adjustment Policy, http://my.gwu.edu/files/policies/Financial%20Transactions%20Adjustment%20Policy%20FINAL.pdf

17.2. PROJECT CHANGES AND APPROVALS - Significant Program Changes That Typically Require Internal Authorizations and Sponsor Approval by CO/Authorized Representative

The following guidelines are provided to assist with the types of changes that usually require sponsor notification and approval. In most cases, any such notification and approval is required in advance of the change. In this regard, it is important to consult with the RSC as early as possible in the process to verify that appropriate advance approvals are obtained. Involving the RSC will help in verifying that the approval is obtained from the right source with authority to commit the sponsor. Additionally, consulting with the appropriate RSC will help in determining whether the University is permitted under a delegation from the sponsor referred to as “expanded authorities” to internally approve the project change within some defined boundaries by Agencies such as NIH that participate in this Expanded Authorities program.

17.2.1. Circumstances When Advance Approval of Changes Generally is Required

While the following are suggestive of when sponsor approval is necessary, this list is not intended to be all inclusive. In any case, the award document terms and conditions should always be consulted about such requirements as they would prevail over these guidelines.

Except for any approvals permitted under expanded authorities as confirmed by the appropriate RSC, advance approval from the Sponsor should be requested when any of the following occurs:

• A significant change in the Principal Investigator’s time on the program
• A change in the Principal Investigator or other Key Participant on the program
• Equipment costing more than $25,000 is to be purchased
• Capital equipment if not included in the proposal budget
• A subcontractor is added, replaced or released from the proposed program
• Significant variances of budgetary line items
• Changes in stipend or tuition rates
• Other significant budget items not included in the original proposal budget
• Construction or renovation costs
• Foreign travel costs are required or added
• Student support costs are added
• Scope of Work changes, especially if it affects the budget
• Timeframe for completing the work increases at all or decreases substantially.

17.3. TRANSFERRED PROJECTS

17.3.1. Incoming Transferred Programs [Reserved]

17.3.2. Outgoing Transferred Programs [Reserved]

17.4. PROGRAM REPORTING & DELIVERABLES

17.4.1. Available Internal Program Reports

The University’s Enterprise Accounting System uses Oracle and Banner to track and account for Program expenditures.  Consult with the appropriate RSC to learn about what reports are available to assist in program management and to arrange to have such reports made available on a regular basis. The most important in this regard for internal cost monitoring is the monthly Budget Performance Reports (BPRs) that Investigators use to track monthly charges to programs. In reviewing these BPRs, Investigators identifying any personnel charges that are in error would initiate an appropriate Change in Status (CIS) Form , Appendix E, to make corrections or, for non-labor charges, a Departmental Correction Form (DCF), Appendix E.

17.4.2. Reports to Sponsors

In general, Sponsored Research programs require both financial and technical reports as well as property, patent and other reports. These reports are required at the end of the Program, and may be required on an interim basis for longer programs. These reports are deliverable requirements and it is the Principal Investigator’s responsibility to verify that these reports are completed and submitted in a timely manner. These reports are signed and submitted through the Managing Director for Research Support and Analyses. In general, these reports should be submitted within 30-60 days beyond the program end date, but each Program award should be consulted for the particulars of that Program.

17.4.2.1. Technical Reports: Technical Reports are prepared by the Principal Investigator with the assistance of Program personnel and submitted to the Sponsor. These reports should be submitted through the Research Service Coordinator to verify that a proper and official record of delivery has been made in accordance with the award requirements. Further, these reports can be scanned in through OCRO’s Documentum scanning and information management system so that they will be retrievable and producible in the event that the sponsor requires verification of submittal or seeks additional copies. To avoid a situation where a submission in hard copy is made directly and the sponsor is not able to locate the report and is withholding payment as a result, it is best to submit Technical Reports through the ORCO. The Principal Investigator may make informal distribution to his or her COTR or technical counterpart, but the formal submission should go through the OCRO RSC. At a minimum, the Principal Investigator should copy the OCRO RSC on any direct transmission of such reports.

17.4.2.2. Financial Reports: Financial Reports are prepared through Grants and Contracts Accounting Services with the assistance of Departmental personnel and the Principal Investigator. The preparation and reconciliation of these interim and final financial reports is very important. Additionally, because recovery of any further costs incurred under the program would generally be precluded after submission of the final financial report, these reports have to be prepared in a timely and correct manner.

17.4.2.3. Other Reports and Deliverables:  Most sponsors require reports on property and the disposition of assets as well as a patent invention disclosure reports identifying any potentially patentable subject matter. For other deliverables that may be specified in the award, Principal Investigators should review the terms of the particular sponsored program. For further information on patent invention disclosure reports, including when subject matter is required to be disclosed because it has been conceived or first reduced to practice during the sponsored research program, see Section 17.6.

17.5. PROGRAM INTELLECTUAL PROPERTY RESPONSIBILITIES

This Section sets forth guiding principles and responsibilities for satisfying program responsibilities related to Intellectual Property on sponsored agreements. For a more extended discussion of University Policy regarding Intellectual Property requirements, see Section 20, Intellectual Property and Sponsored Research.

17.5.1. University Organization Overseeing Intellectual Property

The Associate Vice President for Health Research, Compliance, and Technology Transfer is responsible for patent matters affecting the Medical Center, The Chief Research Officer is responsible for patent matters affecting the University. These officials administer the Policy on Patents and Scholarly Works my.gwu.edu/files/policies/PatentsandScholarlyWorksFINAL.pdf and verify compliance with agreements with sponsors, and coordinate on such activities for joint endeavors that involve both components, i.e., Medical  Center and University.

17.5.2. Relations with Sponsors of Research

Agreements for sponsored research may contain provisions allocating the parties’ rights in any Inventions or Discoveries made under the agreement. The University will not enter into such an agreement if its provisions differ in any way from University policy unless the deviating provisions are deemed acceptable in writing by the faculty member or staff member who will be the principal investigator for the program.

Faculty, staff, and students are permitted to publish the results of their research in a timely manner. The University normally will agree to maintain confidentiality of confidential information provided by the sponsor and to withhold publication of research results for up to 60 days after disclosure to the sponsor in order to accommodate the filing of a domestic or foreign patent application covering the subject matter of the publication.

17.5.3. Invention Reporting and Disclosures Forms

For information on Invention disclosure, forms and processes including links to GW’s Invention Disclosure Statement see http://my.gwu.edu/f