Introduction
University Research Services & Administration (URSA) is Georgia State's central administrative office responsible for coordinating all pre-award and post-award administrative activities associated with sponsored programs. Members of University Research Services & Administration (URSA) report to the Vice President for Research. Two offices within URSA, the Office of Sponsored Programs (OSP) and Research Financial Services (RFS) are responsible for sponsored programs administration and function as the official University contact between various funding agencies, faculty members, community groups, and other University offices. Every Georgia State University department or unit has assigned representatives in OSP and RFS responsible for assisting faculty and staff with sponsored project administration. Our website contains a directory of the staff assigned to the University units.
OSP's major activities include processing grants and contracts prior to submission to a funding agency in order to ensure proposal conformity to funding agency and university requirements, negotiating the terms and conditions of contracts with funding agencies; and providing post-award nonfinancial administration of grants and contracts (e.g., subcontract agreements, no-cost extensions).
RFS provides centralized fiscal oversight for externally sponsored awards by determining that the University complies with all financial provisions of awards or agreements entered into with outside entities. RFS responsibilities include advisement to PI's and departmental administrator on the fiscal management of awards; special studies relating to indirect costs; ensuring the University's effort reporting system documentation is in compliance with OMB Circular A-21; interpretation and implementation of Federal guidelines as related to sponsored projects administration.
The RFS staff is responsible for maintaining auditable records in support of direct and indirect charges to sponsored awards and for preparing and filing fiscal reports required by grantor agencies or companies. They perform billing and collection activities for costs incurred on sponsored awards, and draw down of funds for awards funded by letter of credit. This manual details procedures and addresses some of the common areas of concern that faculty and staff have for grants administration.
Differences between Sponsored Projects and Gifts
All sponsored projects, whether a grant or contract are administered through URSA, with Georgia State University Research Foundation (GSURF) serving as the award recipient. Fellowships are also processed through URSA, though individuals may sometimes be the award recipient. On the other hand, externally funded gifts are NOT considered sponsored projects and are administered through the Development Office with the Georgia State University Foundation as the award recipient. The following sections differentiate between sponsored projects and gifts:
Sponsored Projects are all externally-funded research or scholarly activities that have a defined scope of work or set of objectives which provides a basis for sponsor expectations. The two most common sponsored projects' funding mechanisms are grants and contracts.
A sponsored project normally has one or more of the following characteristics:
Gifts (which are not considered Sponsored Projects):
Gifts that are administered through the Development Office may have the following characteristics:
Inevitably, there will be situations when the classification of a grant or gift will be unclear. When such situations arise, contact your Sponsored Programs or Development representative for clarification.
When preparing the budget the PIs need to ensure that they request the funds to accomplish the scope of work of the sponsored project and comply with the rules and regulations involving sponsored projects' expenditures. This section of the manual provides guidance on how to complete the common categories of a proposal budget.
OSP staff can advise faculty members as they are preparing their budget and its justification, and help identify costs that may be included as cost share or match, when required, if an appointment is made well before the 5 day deadline for final proposal submission. When a proposal is submitted through OSP, the budget will be reviewed to ensure that all potential costs have been identified, that fringe benefit and indirect cost rates are used and calculated correctly, and that it conforms to solicitation requirements and federal, state, and university policies and procedures. The budget must always include a listing of all the direct costs and indirect costs associated with the project, as described below under budget categories. A budget worksheet is also available on URSA's Proposal Preparation webpage.
Budget Categories
Costs of a sponsored project are divided into direct and Facilities &Administration (indirect) costs as well as cost-sharing. These categories are described below.
Direct Costs
These are costs that can be distinctly identified as benefiting the project, such as salaries and fringe benefits, equipment, supplies and travel.
Rules and regulations governing allowable direct costs in budgets
When preparing a budget, be mindful that certain costs may be unallowable as a direct cost of a sponsored project. Georgia State University is required to comply with the US Government Cost Accounting Standards, in addition to state regulations, in determining if an item is an allowable direct cost for a sponsored project. The distinction between allowable and unallowable costs is summarized here, with more detailed information available in the awards management section of this manual.
Allowable costs are those categories of costs that can be charged to a grant or contract and represent a direct benefit to the project (i.e., salaries, equipment, travel, participant stipends, supplies, etc.).
Unallowable costs. Certain types of costs (e.g., cost of alcoholic beverages, etc.) are not allowable because of the nature of the costs and may not be charged to a contract or grant. Other unallowable costs are not allocated to sponsored projects as either a direct cost or as indirect costs (see below for definition) because they are treated either as part of the Other Institutional Activities base for determining facilities and administrative indirect cost rates, or are included in an administrative cost pool, neither of which is allocated to sponsored agreements. Generally, unallowable costs include:
If a charge is unallowable as a direct cost, it is usually unallowable as a match or cost sharing unless prior agency approval is attained.
If there are extenuating circumstances that require including costs that are considered unallowable in the direct costs of a sponsored project, then the rationale for this needs to be included in the budget justification and these costs need to be approved by the sponsoring agency.
Definitions of different types of direct costs are listed below:
Personnel Salaries
This includes GSU personnel only, their roles on the project, titles, the percentage of effort/time each will devote to the project, the rate of pay, the amount requested from the sponsor to support each person per year (or for the entire budget period) and the amount of cost share. Administrative and clerical salaries are generally not charged to sponsored projects. However, such charges may be appropriate in certain large complex programs. Please consult OSP for further information.
GSU Faculty and Staff Base Salary
Faculty and staff salaries typically are based on a percentage of effort (expressed either as an actual percentage of number of months) and are compensated based on a nine month academic year appointment; however, some faculty are compensated based on a 12 month calendar year. An appropriate percentage of the academic year or calendar year salary should be specified in the budget.
Daily/Hourly Rates
Some proposal budgets may require that faculty or staff time be reported on an hourly, daily or weekly basis. The number of hours worked will depend upon whether the person listed in the budget is a nine- month faculty member or a 12 month employee. The hourly rate is computed as follows:
Academic Year (9 month faculty): 9 month salary ÷ 1560 hours = Hourly Rate
Calendar Year (12 month employees): 12 month salary ÷ 2080 hours = Hourly Rate
The daily rate would merely take the hourly rate and multiply it by 8 hours. To calculate the weekly rate, just multiply the daily rate by 5 days.
Sponsored activities may not result in any employees receiving compensation at a rate in excess of their authorized institutional salary. However, for multi-year projects, the budget should take into consideration any possible salary increases (typically a 3% - 6% yearly increase). In no case can funds be requested or used to augment salaries of any faculty or staff beyond University-approved rates
Nine Month Faculty Summer Salary
For summer salary, a maximum of three months of summer effort and salary (calculated up to 33 1/3 % x 9 month base salary for the current fiscal year) may be requested when this is acceptable to the sponsor. This summer salary must be identified as such in the budget.
Faculty Extra Compensation
Occasionally, there will be times when a faculty member may request and receive additional compensation beyond the base salary. This is an allowable direct cost only if the funding agency specifically allows extra compensation. Extra compensation must be labeled as such in the budget submitted to and approved by the funding agency. Please note that Federal funding agencies and some state agencies do not allow extra compensation during the academic year.
When a proposal requesting extra compensation has been submitted to OSP, a letter, signed by the PI, the person(s) receiving extra compensation, their Department Chair(s) and their Dean, must be attached to the proposal stating that all four of the following conditions of the Board of Regents Policy Manual (section 803.1404) for extra compensation will be fulfilled.
When extra compensation is paid, it must be in line with the compensation paid for the performance of the faculty member's normal duties. (Policy Manual, Board of Regents of the University System of Georgia).
If extra compensation is not included in the original proposal, extra compensation can not be paid without seeking agency approval, especially in federal and federal flow through projects.
Graduate Research Assistants
A graduate research assistant (GRA) may be assigned research duties each semester or on a monthly basis.
Non - GSU Personnel
If your proposal includes individuals who are not employed by GSU, those individuals cannot be included in the "Salaries" section of the budget. They must be listed in either as Consultants or as a Subcontract (see sections below.)
Fringe Benefits
Fringe benefits require a separate category in the budget and should not be combined with salaries. Current fringe benefits rates are shown on the Proposal Fact Sheet available at the URSA website. The rate includes the University's contributions to Social Security, retirement programs, health insurance and employment compensation.
Permanent Equipment
Permanent equipment is defined as any item of non-expendable, tangible, personal property having a useful life expectancy of two or more years and an acquisition cost of $5,000 or more per unit. Equipment needs must be itemized and justified. In addition, the Principal Investigator must determine that the equipment requested is not already available within the University. The cost of equipment generally includes needed accessories, installation, and delivery costs. In some cases the sponsor may provide the equipment directly rather than provide acquisition funds or a short-term rental may be preferred. Permanent equipment costing more than $5,000 is not included in the base amount for calculating F& A (indirect) costs for a proposal.
Travel
The need for Project Directors to consult with colleagues and disseminate new knowledge through scholarly meetings is an expected practice and an accepted cost in most projects. There must be a correlation between the project and the purpose of the meeting. Such costs may include transportation, lodging and meals (per diem). If the project requires travel to various locations in order to perform the work, these costs should be identified; an itinerary may be required if travel is a significant portion of the total cost. Some examples would be travel to various localities to collect samples, to interview respondents or to make special measurements. Special costs should be identified and justified. Once again this category is for travel costs associated with GSU employees only. Travel for non-GSU personnel is to be listed under "Consultants", "Subcontracts" or "Participant Costs."
Domestic Travel. Domestic travel on most sponsored project accounts is subject to the University's Institutional Travel Policy (be sure to get the most up to date version from Disbursement). In some instances, however, the agency may put forth more restrictive travel regulations. In those cases, the agency's regulations must be followed. For example, some federal agencies limit reimbursement for meals and lodging to the federal per diem rates. GSU uses the federal government CONUS rate for meals and lodging for cities located in the United States. Their website is located at: http://www.policyworks.gov/org/main/mt/homepage/mtt/perdiem/perd04d.html
Also see the state of Georgia travel regulations at http://www.audits.state.ga.us/internet/nalgad/trvlreg.pdf
Foreign Travel. Because of certain agency regulations for prior approval and the requirement of federal agencies for utilization of U.S. flag carriers, OSP should be contacted as far in advance of such trips as possible. The Foreign Travel and Per Diem Rates can be located at the U.S. State Department's website: http://www.state.gov/m/a/als/prdm/2004/
Participant Support Costs
This budget category refers to direct costs for items such as stipends, subsistence allowances, travel allowances and registration fees paid to or on behalf of participants or trainees in connection with meetings, conferences, symposia, training activities and workshops. Participant support costs are NOT human subject payments (which are considered miscellaneous expenses). Participant support costs are excluded from the base for calculating F&A (indirect) costs.
Materials, Supplies, and Expendable Equipment
Expendable equipment is defined as any item of an expendable nature, regardless of service life, and having an acquisition cost of $4,999 or less. These items should be specifically identified and justified. They include, for example, chemicals, disposable lab ware, glassware, small electronic components, animals and animal rations, and unusually large quantities of paper supplies as in the preparation and distribution of questionnaires or other brochures and forms. General office supplies should not be included as a direct cost of a grant except when the scope of work requires unusual amount of a certain type of supplies (e.g., paper for distribution of a large quantity of surveys) and such inclusion must be approved by the sponsoring agency.
Publication
This should include manuscript illustrations, cost of reprints and page charges to be incurred in publishing articles resulting from the project. In some contracts a large number of copies of the project's final reports is required; this cost should be estimated and included in the budget. The publication costs of a book or monograph are generally not allowed (except at NIH); special permission should be obtained from the sponsor before including these costs in the budget.
Consultants
Consultant fees may be paid only to experts not employed by Georgia State University who provide a unique contribution to the project. While a Consultant may contribute their expertise on a project, they can not be named as a Co-PI or Co Director, nor can they be considered as "Key Personnel". University System and State of Georgia employees are not eligible to receive compensation for consulting services on sponsored projects unless prior approval from both chief executive officers is received. Federal agencies specifically prohibit the payment of consultant fees from Federally-supported projects to persons employed by the Federal government. When listing a consultant in the budget, include all their travel expenses and supplies as line items under the "Consultant" subheading. Since they are not employed by GSU, their travel and supplies cannot be listed under the normal "Travel" and "Material & Supplies". Fees for consultants are generally listed as a daily/weekly rate or a flat fee for services. Typically, consultants should supply a letter of agreement to be included in the application.
Subcontracts
Work to be done by individuals from other institutions, businesses, corporations or organizations (other than consultants) must be listed here. Each subcontractor must have their own itemized budget which includes: salaries, fringe benefits, equipment, travel, supplies, other direct costs, indirect costs and cost sharing. Proposals which include subcontracts must be accompanied by a statement from the authorized signatory of the subcontractor of their intent to participate in the program, their agreement to the proposed budget and include any cost sharing dollars they maybe providing. It should also include specific language explaining how cost sharing will be documented. This should include a statement of work and an estimate of the time required to complete the work. Any subcontracts from other Universities must be routed through the subcontracting Institution's approval process to obtain the necessary approvals prior to the proposal's routing through GSU.
The Principal Investigator must submit to OSP a statement disclosing any direct or indirect financial interest in the subcontractor organization; see GSU Policy on Conflict of Interest on URSA Research Integrity webpage.
Only the first $25,000 of each subcontract for the entire project period is included in the base for calculation of indirect costs. Contact OSP for assistance in preparing subcontracts.
Miscellaneous Expenses
These expenses include, but are not limited to, the following: renovation of space that is necessary in order to carry out the project; rental of space; maintenance of specialized equipment which is necessary to the project; communication costs such as regular and long distance telephone costs; postage charges when large volumes of mailing are required, and human subject or informant fees.
Facilities and Administrative (F&A or Indirect) Costs
These are expenses that are incurred by the University through the cost of facilities and services for common or joint objectives. F&A Costs also are frequently called indirect costs. These costs reimburse the University for laboratory and office space, utilities, and administrative services (e.g., purchasing, accounting, research, personnel, telecommunications, security, custodial services, buildings, grounds and street and parking lot maintenance). Specifically, they include all the essentials to support sponsored activities that cannot be broken down and directly charged to a specific grant or contract. The University calculates its F&A cost rates from actual cost records through a detailed cost accounting procedure. The F&A cost rates are subsequently negotiated and accepted by the Department of Health and Human Services (DHHS) Audit Agency acting on behalf of all federal agencies. There are off-campus and on-campus F&A cost rates depending on where the project is performed. Some funding agencies will ask for the date of our negotiated Indirect Cost Agreement and our "cognizant agency." The Proposal Fact Sheet has all this information (and is available on the URSA Proposal Development Webpage).
The rates are calculated on a modified total direct costs (MTDC) base, which means total direct costs less:
F&A costs may change from year to year, primarily due to the federally-imposed calculation methods. Check the Proposal Preparation Fact Sheet available on the Proposal Preparation webpage for the updated indirect cost rate.
It is the policy of Georgia State to charge the appropriate F&A rate on all grants. All requests for F&A modifications/waivers should be submitted to the Vice President for Research for approval. See F&A (Indirect) Cost Waivers for more information.
Budget Justification
Documentation and justification of budget requests should be provided in narrative form on additional page (s) immediately following the budget in the proposal and should be identified by line item.
It is the position of the University that all proposals requesting support from any sponsor, either government or non-government, must include a request for full indirect cost recovery. However, some sponsors, particularly certain foundations, have specific written policies that preclude the use of the University's full F&A (indirect) cost rates; the rate allowed by the sponsor must be used in these cases. Either a copy of the agency's guidelines specifying their policy on indirect costs, or a letter/ email from the agency is required if less than full indirect rates are to be used. Please consult OSP for further information.
All requests for F&A modifications/waivers should be submitted to the Vice President for Research for approval. The one page letter from the investigator should provide a brief description of the project, a budget and a rationale for the request; it should include any written statement from the funding agency regarding F&A rates. The Unit Head and Dean should cosign this letter. This request should be submitted at least five (5) full working days prior to the date of submission of a proposal.
Cost sharing is defined as a financial commitment by GSU to share in the expense of conducting a project for which funding is being requested from an external agency. It is not the same as institutional support you might receive from the GSU internal grants programs or GRA support from your Department Chair or Dean.
The same cost sharing dollars can be used only once. Cost sharing cannot come from federal funds. When cost-sharing is met by contributing time and effort, the University will also claim as cost-sharing the fringe benefits and facilities and administrative costs (indirect costs) that it would have earned had that time and effort been charged as a direct cost to the grant. The University's share of cost-sharing commitment may come from several sources; however, the originating department is responsible for securing the required funds. A separate cost sharing budget and/or budget narrative must be included with a proposal.
There are two types of cost sharing, namely involuntary cost sharing and voluntary cost sharing.
Involuntary (mandatory or required) cost sharing is when a sponsoring agency requires the institution to share in the costs of doing the proposed project. Required cost-sharing will be included in the sponsor's guidelines for proposal submission. Some sponsoring agencies have a specific percentage requirement. It is not unusual for private foundations to require a dollar for dollar match or to require cost sharing for faculty salaries. Some agencies require a match for any equipment that may be budgeted. Whatever the requirement, it will be specified in their guidelines and must be met for the proposal to be accepted. The dollar amount should be identified on the Proposal Routing Form. Within the proposal itself, a budget detailing the budgetary areas used for match should be included. Because it is required by the agency and are so stated in their call for proposals, these types of cost sharing will typically be approved by OSP without question.
In contrast, voluntary cost sharing is where there is no stated requirement by the funding organization that there be any cost sharing. Agency directors emphasize that voluntary cost sharing will not increase the likelihood of a proposal being funded. Therefore, unless a program officer has specifically indicated that cost-sharing will increase the probability for funding you should not include cost-sharing in your proposal. Cost sharing that is mentioned in the budget narrative or in the research narrative is still considered a commitment to cost sharing, even if it is not included in the budget itself.
GSU discourages voluntary cost sharing. A letter of support signed by Department Chair and College Dean is required for all voluntary cost share. Include any documentation from the agency about the desirability of cost sharing (e.g., email from a sponsoring agency official).
Note that where cost sharing is committed on a subcontract, it will be the responsibility of the GSU Principal Investigator's department to cover this cost sharing if the subcontractor does not commit (and document) the promised cost sharing. Note that this may end up being in the form of a Fund Code 10 budget transfer.
NIH allows certain new, revised, and competing continuation R0, R03, R15, R21, R41 and R43 grants and supplements, as well as some RFAs, to be prepared under its Modular Grant Application and Award Initiative. Modular proposals are simplified proposals requiring limited budget information and no Other Support pages. GSU will support this more efficient proposal development and review process by following the below specified procedures.
To submit an NIH Modular Grant Application to the OSP for review and processing, please include all PHS 398 grant application forms as required with the following components specifically addressed:
Item 8a (initial period direct and indirect costs) should also be figured carefully. You are required to subtract estimates of the following items from any direct cost totals before indirect costs are derived:
For more specific Modular Grant preparation information, see:
http://grants.nih/gov/grants/funding/modular/modular.htm
Please note that the Principal Investigator has even greater responsibility to ensure that their direct and indirect cost projections for their modular grants are accurate and adequate to meet their research project needs over the entire length of the project. NIH has given notice that the total amount of modular grant awards cannot be changed once awarded. Given that the Office of Sponsored Programs cannot cross-check PI's modular budgets (unless they want to develop a detailed budget with Office of Sponsored Program assistance or review), any errors will have to be managed by the Principal Investigator.
Once awarded, Principal Investigators will have to provide the Office of Sponsored Programs with their budget broken down into standard Spectrum budget categories, including any cost sharing requirements. All costs charged to a Modular grant must still conform to all the standard OMB Circular A-21 accounting requirements. Note though that Modular grants allow for significant rebudgeting across budget categories without NIH notification. If you apply for any supplemental awards (minority, etc.) connected to a modular award, they also have to be in modular format.
(Approved 10/26/04 VPR)
Procedures for Processing a Proposal Prior to Submission to a Sponsor
All sponsored project proposals, grants, fellowships, sub-contracts and contractual agreements must be reviewed by OSP to ensure institutional eligibility, conformity to sponsor guidelines, accuracy of budget, applicability of cash match and cost sharing, human subjects or animal use approvals, etc. Proposals are reviewed to ensure that any commitments included are consistent with federal, state and University policies, as well as to ascertain approval of the proposal by Department Chairs and Deans. It also serves to indemnify the faculty member should the agency dispute the quality or quantity of the award's deliverables.
Proposal routing through Georgia State University
PIs must complete and obtain the necessary signatures on the Proposal Approval Form which is available on our website. The Routing Form must bear appropriate endorsement signatures before submission to OSP. Proposals proceed from the Principal Investigator to the Department Chair (or other unit head), to the Dean, and then to the OSP. In situations where a proposal involves faculty members or staff from different departments and/or colleges, it is necessary to secure signatures from the chair and Dean of each area. The OSP Quick Reference details what needs to accompany the Proposal Approval Form. Both the Proposal Approval Form and the OSP Quick Reference are available on the Proposal Preparation webpage.
The OSP must receive all copies of a proposal where the sponsor requires original signatures on each copy.
OSP's Time Requirements for Proposal Review
The time required for review of a proposal varies with its size, complexity, completeness, accuracy, and care taken in its preparation and prior review. It also depends upon the amount of work already in OSP and the staff available when it is received. To allow for necessary corrections and revisions and for greater assurance that sponsor deadlines will be met, allow AT LEAST FIVE, FULL WORKING DAYS for the OSP to review the proposal. Proposals which contain unconventional or unique features including cost sharing commitments, numerous subcontracts or consultants, conditions that necessitate legal review, etc., may require additional lead time.
Contracts
Any sponsored project that is a contract must also be reviewed by Legal Affairs. OSP will forward contracts to Legal Affairs for review.
Roles and Responsibilities for Review
The people or offices involved in the internal review and processing are as follows:
The Principal Investigator/Project Director (PI/PD) is responsible for the budget, technical content, quality and preparation of the proposal presenting his or her ideas for a project, as well as securing institutional approval for the use of Human Subjects or Animals. The PI/PD also signs the conflict of interest, technology, debarment and lobbying certification sections of the Routing form.
The Department Chair or Unit Head is responsible for certifying to the academic validity of the project, the compatibility of the project with the Principal Investigator's other commitments, the availability of space, personnel, equipment and facilities, cost-sharing commitments and assuring that the project adheres to department objectives.
The Dean is responsible for determining the appropriateness of the project within the College or School and that requested resources will be available.
The Office of Legal Affairs is responsible for ensuring that any proposed contractual agreement complies with applicable federal and state laws. This means that all contracts must be reviewed by Legal Affairs, in addition to OSP, before submitting to an agency.
The Office of Sponsored Programs is responsible for ensuring that proposals comply with applicable funding source guidelines and regulations, and with federal, state and University policies, are sent for legal review as appropriate, include signatures for institutional assurances, have necessary approval of contractual terms, and contain accurate and reasonable budgets.
Submitting the Proposal to the Agency
After OSP approves the proposal and obtains the required authorizing institutional official signature, it is returned to the PI for submission. The only exception to this is when a funding agency requires electronic submission by the central administration (e.g., grants.gov). In these cases, the PI is responsible for forwarding the completed electronic proposal 48 hours prior to the agency submission deadline to their OSP Officer. Because procedures for electronic submission vary considerably, PIs need to consult the instructions available on the Proposal Preparation website for the procedures for their particular grant funding agency and work closely with his or her OSP representative to ensure successful submission.
Final Version
The PI must give OSP a copy of the final proposal document that is submitted to a sponsor, in its entirety. Therefore, if any changes are made to the proposal that accompanied the Proposal Approval Form (or the narrative did not accompany this Form), the PI must send a printed or electronic copy of the final proposal to OSP at the time of submission.
Once an award has been made, responsibility for the administration of sponsored awards at Georgia State University rests with several different individuals/offices, including the Principal Investigator/Project Director (PI/PD), Office of Sponsored Programs, department administrators and Research Financial Services. OSP provides the post-award functions of award acceptance, award negotiations, obtaining sponsor's prior approval when required, establishing subcontracts, transferring an award to another institution and assistance with closeout requirements, as discussed below. RFS provides the post-award functions dealing with the financial aspects of the award. Every PI is assigned a OSP and RFS staff member who can assist the PI in award management.
All grants and contracts are submitted through the Georgia State University Research Foundation, Inc. (GSURF). Therefore, awards will be accepted by GSURF and subsequently subcontracted to GSU for the project performance. It should be noted, however, that if GSURF is not an eligible applicant for a particular funding opportunity, the award is accepted by GSU directly.
An award to GSURF or GSU from a sponsoring agency serves as a legal document obligating the University to a contractual commitment. Awards may be in the form of a letter or check issued by an authorized agent of the sponsor, a grant Notification of Award (NOA), or may consist of a complete contractual document. In some cases acceptance by the grantee (and then by the agency) is required before the award is in force, in other cases no formal acceptance is required. When required, Georgia State or GSURF's authorized institutional officials (the Vice President for Research or Associate/Assistant Vice Presidents for Research) are responsible for signing these documents and thereby legally binding the University to the terms and conditions of the grant or contractual document.
PLEASE NOTE: PI/PD, Department Chairpersons, and Deans are not authorized to sign award documents on behalf of GSURF or the University. All original official award documents, if received by the PI/PD, should be forwarded immediately to OSP for processing. OSP will consult with a PI/PD if the award differs from the submitted proposal, so that the award may be accepted, modified through negotiation with the sponsor or rejected.
Award Negotiation
In some cases an award may be issued by the agency after a series of negotiations that may involve revisions to the scope of the project, period of performance and/or proposed budget. OSP, working with Legal Affairs, is the authorized agent for negotiating such revisions, but no changes to a project or a budget are authorized without the consent of the PI/PD. PI/PDs are reminded that the acceptance of a revised scope of work, period of performance or budget is a judgment that only they can make; it is not a judgment or condition that may be unilaterally imposed by the granting agency. If the agency requires the submission of a revised work plan or budget, this must be prepared by the PI/PD and submitted to OSP for institutional endorsement and for forwarding to the agency. Revisions, either programmatic or budgetary, which represent substantial changes to the original proposal must be reviewed and approved by OSP in the same manner as a new proposal.
Establishing an account for an award involves both the Office of Sponsored Programs and Research Financial Services. Upon receipt of an official award, OSP staff assigned to the project will request a project number assignment from RFS and prepare and distribute a Notice of Award to the PI/PD, Department Chair, Dean, and other administrative offices. The Project Transmittal Form indicates the project number established for the project and details pertinent award information, including the RFS staff assigned to the project, the budget, and any cost-sharing obligations. To protect the PI/PD and the University, expenditures should not be incurred against a sponsored project until OSP has received and processed the original award notification from the sponsor and a project account number has been assigned.
If compliance issues (human subjects, animal use, biohazards, or radiation) are involved, OSP will not release funds until the appropriate review board has approved the protocol.
The issuance of the project number for the award is a form of credit line against which the PI/PD may charge obligations and expenditures, without concern for sponsor payments and cash flow considerations. In reality, sponsoring agencies do not pay the University in the majority of cases until expenditures are incurred and invoices are submitted to the agency by Research Financial Services.
Account Set-Up
Based on information in the budget approved by the sponsoring agency, Research Financial Services staff review and record critical award information into the Financial Accounting System to allow proper processing and tracking of project accounting data. This information includes, but is not limited to:
NIH Modular Budgets
Once awarded, Principal Investigators need to provide their OSP representative a detailed budget in University budget categories, including any cost sharing requirements.
Advance Project Number
It is recognized that on some occasions receipt of the actual award documents authorizing expenditures for a project may be delayed. It is possible to obtain permission to initiate limited expenditures for a short time. For this purpose, an advance project number may be requested. Requests for an advance project number should be submitted on the Request for Approval under IPAS. This form must be signed by the PI/PD, the Department Chairperson, and the Dean of the college or school. Included on this form is a statement of assurance that commits the department to reimburse project accounts in the event that the expected sponsor authorization is not forthcoming. Because the financial risk for expenditures is on the department's part, OSP will approve an application for an advance project number if the appropriate administrators agree to assume this responsibility. A completed and signed form must be sent to OSP to initiate action.
Questions? Contact OSP
Every award comes with terms and conditions on the award which frequently accompanies the PIs Award Notice. All federal awards are governed by general federal rules and regulations. Some awards have terms and conditions that are specific to the sponsoring agency or grant mechanism. It is important for PIs to familiarize themselves with these terms and conditions so they know how to manage the award and comply with the rules and regulations governing that award. For example, the PI should know the regulations involving changes to the original proposal (e.g. rebudgeting, no-cost extensions, carrying funds from one year to the next) and reporting requirements and procedures during the award period. OSP and RFS staff can assist the PI in determining the terms and conditions of their particular award.
Questions? Contact OSP
Sub-Contracts
OSP staff will facilitate subcontract agreements by preparing documents and forwarding them to the subcontractor for all the subcontracts indicated in the approved award budget when an award is initially set-up. If additional subcontracts become necessary, the PI/PD should complete and submit to OSP a Request for Sub-Contract/Agreement form, found on the Proposal Development webpage
Questions? Contact OSP
Research Financial Services ensures that the University complies with all fiscal provisions of contracts, grants, and other agreements. Generally accepted accounting and reporting practices are followed in the management and administration of sponsored projects and programs. Consideration is also given to cost principles and standards promulgated by Office of Management and Budget (OMB) Bulletins and Circulars, including A-21, A-110, A-133, as well as to specific terms and conditions of each individual award. Specific terms and conditions of the award will accompany the notice of award received by the PI.
There are sponsor, federal, states, local and university rules and regulations which govern expenditures made against sponsored awards. Listed below are some areas of compliance with additional detail. This list is in no way exhaustive. It simply outlines the more common areas of concern. You are encouraged to familiarize yourself with these areas and determine which apply to your award and adhere to them. If any guidance is required, your Research Financial Services Officer is available to advise you.
Federal
Federal guidelines are usually quite broad covering the majority of federal agencies, but each agency could have more restrictive requirements depending on the type of the award. By in large, most federal awards will require compliance with OMB Circulars A-110, A-21, and A-133. The circulars can be found at http://www.whitehouse.gov/omb/grants/
Private
In many instances, private sponsors will utilize these same circulars in addition to any specific requirement they may have. Each individual award may have different requirements - even if it comes from the same sponsor. It could be that a sponsor, such as the American Heart Association, has categorized its awards with different regulations for each funding category. Project specific regulations should be outlined in the award documentation. This documentation should be reviewed for each new award.
State
In addition to the sponsor requirements, the State of Georgia and Georgia State University have their own regulations. Many of the regulations for the University System of Georgia are found in the Board of Regents Policy Manual located at http://www.usg.edu/admin/policy and are available for review. Procedures established by GSU Finance and Administration must be followed for sponsored projects and will ensure compliance with state regulations. These are available at http://www.gsu.edu/~wwwvpf/
The majority of awards received by Georgia State University requires compliance with the cost principles addressed in OMB Circular A-21. http://www.whitehouse.gov/omb/grants/index.htm and are defined in Section A (1) Objectives, which states
“This attachment provides principles for determining the costs applicable to research and development, training and other sponsored work performed by colleges and universities under grants, contracts and other agreements with the Federal Government. These agreements are referred to as sponsored agreements.”
Section C (1) – (3) addresses such things as Composition of total costs, factors affecting allowability of costs, and reasonable costs. This area is an excellent source of information if you have concerns about the allowability of certain costs. Also, Section J (1) – (50) will provide the principles to be applied in establishing the allowability of certain costs.
We have also developed the following guidelines to help you determine if a cost is allowable:
Allowable Direct Costs
Charge the following types of costs directly to sponsored agreements when they can be specifically identified as necessary to the work performed under those agreements.
Salaries, Wages and Fringe Benefits
Supplies and Materials
Other Direct Costs
Extra Compensation
Extra Compensation is used when work is done outside normal business hours and above whatever the normal full time EFT is for the individual. Extra-Compensation payments request forms require prior approval by the assigned RFS officer. These requests are approved only in cases where extra-compensation was included and approved in the award budget, or, approved by the awarding agency in writing after the receipt of the award. Please note that Federal funding agencies and some state agencies do not allow extra compensation during the academic year.
With government regulations becoming more stringent, it is imperative that the University community understand and comply with the existing guidelines concerning the payment of extra compensation on sponsored projects. Generally the following guidelines will apply.
Board of Regents Business Policy Manual http://www.usg.edu/pubs/index.html .
Extra Compensation (Section 803.1404)
“…adequate allowance in time assigned for extra compensation duties should be made by a proportionate decrease in teaching loads. Extra compensation may be paid, however, when all four of the following conditions exist: (1) the work is carried in addition to a normal full load; (2) no qualified person is available to carry he work as part of his/her normal load; (3) the work produces sufficient income to be self supporting; and (4) the additional duties must not be so heavy as to interfere with the performance of regular duties.”
OMB Circular A-21 http://www.whitehouse.gov/omb/grants/ (Section J 8d(1))
“…any charges for such work representing extra compensation above the base salary are allowable provided that such consulting arrangements are specifically provided for in the agreement or approved in writing by the sponsoring agency.”
While this makes extra compensation an allowable cost, certain federal criteria are applied in that
1. the “consulting” must be across departmental lines; or
2. the work involved is at a separate or remote location
Services other than these exceptions above are deemed to be an obligation of the university.
NOTE: extra compensation may not be paid from state funds.
A definition of “consultant” is found in Section J 32(a)
“Costs or professional and consulting services, including legal services rendered by the members of a particular profession who are not employees of the institution, are allowable…”
The most appropriate way to approach extra compensation as an allowable cost on a sponsored project is to specify this cost in the proposal (subject to the criteria above) in the personnel area. This cost includes associated fringe benefits of 7% (current FICA allocation rate which is subject to change). They are NOT consulting costs.
Equipment
Only equipment (defined as equipment that costs more than $5,000) which is not currently available for use in the project is allowed to be purchased on a sponsored award. During the requisition process in the Financial system, a button marked “distribute” appears on the screen marked Line 1 Schedule 1 details. If you click on the button, the following declaration will appear:
“This affirms the equipment item(s) being requested for subject grant has (have) been screened for availability and it has been determined that this equipment is not available as excess or under –utilized equipment for use on this Federal sponsored program”
Clicking on OK signifies that the project director has made the appropriate inquiries and is satisfied the equipment purchase is necessary.
Unallowable Direct Costs
The following items are explicitly disallowed in OMB Circular A-21:
Best Practices
Additional assistance in ascertaining correct or incorrect practices with regard to charging costs to sponsored project are listed in the table below for ready reference.
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Incorrect Practice: |
Correct Practice: |
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D Charging of salaries based upon funding instead of actual effort. |
C Charging of salaries must be based upon actual effort, and payment must be made in the corresponding pay period. |
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D Hourly wages paid with no documentation of hours worked and payment for hours not worked. |
C Payment of wages must be based upon actual hours worked and payment and hours must be properly documented and approved. |
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D Grant was "cross charged", i.e., costs charged to project based upon funding, convenience, or to "payback" for departmental accounts for coverage of deficits. |
C Use proper accounting and payroll forms such as Personnel Action Forms, forms for retroactive changes, or Amended Personnel Action Form. |
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D Non-Research activities performed while salary charged to grants, such as, classroom instruction, and preparation of new and competing grant proposals. |
C Charge only those costs that are in direct benefit to the research project. Preparation of new and competing proposals are unallowable charges to a sponsored project. |
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D Inconsistent treatment of grant support services such as clerical support, computer programming, and supplies. |
C Departmental services must be charged using a reasonable, consistent method (either direct or indirect) and be charged based upon actual services performed or units used. |
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D Deficient Personnel Effort Report, i.e., not signed, not submitted, or not signed by individual(s) with direct knowledge of work performed. |
C Personnel Effort Reports must be submitted to Grants & Contracts Services by the date noted on the cover sheet. They must be signed by the individual with direct knowledge of work performed by individuals paid on the research project or the Project Director. |
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Incorrect Practice: |
Correct Practice: |
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D Good and Services purchased that did not directly benefit the research project, or were received outside the project period. |
C All goods and services charged as direct costs must have a direct benefit to the research project and received during the project period. |
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D Office supplies, basic telephone, subscriptions and memberships charged directly without proper justification and approval. |
C Normal "indirect" costs may only be charged in "unlike circumstances" which have been properly justified and approved. |
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D Inadequate documentation of approval. |
C The PI or designee, with first hand knowledge of project and work performed, must indicate approval for goods and services, including payroll prior to the transactions. |
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D Improper or not "reasonable" basis used to allocate shared direct costs. Examples include lab supplies, equipment, rent for off-campus facilities, etc. |
C Distribute costs between two or more projects based upon "proportional benefit" or "interrelationship". |
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D Failure to obtain required sponsor approvals. |
C Written prior approval must be obtained to incur any costs which require prior approval as per sponsors rules and regulations and/or grant terms and conditions. |
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D Habitual transfer of costs from one sponsored project to another sponsored project. |
C Cost Transfers to correct an error. |
Questions? Contact RFS
GSU allows the purchasing of miscellaneous items such as paper, folders, binders, printing, GSU parking charges, etc., from such organizations as the GSU bookstore, supply room, Kinko's, Auxiliary Services, etc. through the use of a GSU charge card.
Questions? Contact RFS
The Georgia State University Purchase Card or P'Card is a valuable tool for quickly and efficiently purchasing and paying for goods. Because of the potential for abuse, expenditures for P'Cards are especially scrutinized during audits. For more information on obtaining and using P'cards see GSU Business Services http://www2.gsu.edu/~wwwpch/fordepartments.htm#pcard
Please be aware that items purchased with the charge card and charged to a sponsored project must be allowable and in accordance with university and federal guidelines.
Questions? Contact RFS
Cost Sharing is a contractual obligation committing the University to share in the costs of a Sponsored Award, usually made at the time a proposal is submitted to an agency. The proper documentation of cost share has been a major target of audits making it the second leading area of cost disallowances. In addition, it is essential data used to support the Facilities and Administrative rate proposal. Therefore, it is crucial that everyone involved in the financial administration of sponsored awards understand cost sharing.
The practice of cost sharing falls under one of two categories:
Required Cost Sharing will be addressed in the sponsor's documentation when preparing a proposal for submission. Some sponsoring agencies have a specific percentage requirement. It is not unusual for private foundations to require a dollar for dollar match. Some agencies require a match for any equipment that may be budgeted. Whatever the requirement, it will be specified in their guidelines and must be met for the proposal to be accepted. The dollar amount should be identified on the Sponsored Programs Proposal Approval Form. Within the proposal itself, a budget detailing the budgetary areas used for match should be included.
Georgia State University has an accounting procedure for documenting costs where an approved sponsored project has identified a commitment by GSU to share in the costs of such project. Both required and voluntary cost sharing using fund code 10 budgets must properly document the cost sharing using the following procedure. NOTE: If you “volunteer” cost sharing where none is required, you will still have to honor that commitment by supplying supporting documentation using this procedure.
For all sponsored projects that incorporate matching or cost share commitments, two accounts will be established at the time of the award. A sponsored project account in fund code 20 (General Fund – Restricted) and a companion account in fund code 10 (General Fund-Unrestricted).
These companion accounts will be uniquely identified to the related sponsored project as illustrated below:
1. SPONSORED PROJECT
Fund Program Department Class Project Budget
20 - 1210 - 110600000 - 61000 - ELD41 - 2004
The SpeedType/SpeedChart for this project would be ELD41
2. COMPANION ACCOUNT
Fund Program Department Class Project Budget
10 - 1221 - 11060ED41 - 11000 - N/A - 2004
The SpeedType/SpeedChart for this cost share account would be ED41- This arrangement is designed to correlate closely to the project number on the Fund Code 20 side.
Sponsor funded costs of accomplishing a project are processed through the account in fund code 20 and cost sharing transactions should be charged to the companion accounts in fund code 10.
Generally, cost share expense transactions will be derived from salary and wages and other direct expenses, including travel, supplies, materials, etc. The following procedures will apply to each of these expense categories:
Salary and Wages
All cost shared salaries and wages will be directly charged to the companion account via the PAF form Section E. “Earnings Distribution”. The companion account number will be indicated under the SPEEDTYPE Code column. There will no longer be a need to use the column labeled “If Salary/Effort is Cost Shared”.
Travel, Supplies and Material, Equipment (Non-Personnel)
Non-Personnel charges will be processed directly against the companion account number utilizing the assigned Speedtype (e.g.,. ED41) which will ensure expenses are charged to the appropriate account.
Budgeting for Cost Share Expenses
Although formal budget amendments are not required, it is strongly recommended that units reduce their departmental state budgets to accommodate the companion accounts. The companion accounts in the Financial System will be set up to allow expenses to be incurred against the department or college budget appropriation level. There are special companion account reports designed to assist in measuring performance. This will be accomplished by including an estimated amount based on cost share data contained in the Sponsored Agreement.
Monitoring of Cost Share Accounts
Two reports are available in the Spectrum System to assist in monitoring performance of cost share data. The navigation steps for accessing these reports are found by going to GO/GSU/GC RPTS/ and Cost Share Report. You will have to identify a Run Control ID and that will bring up a panel in which you will identify certain parameters such as date and then you will need to select the type of report you wish to process, i.e. Summary Report or Department Detail. The Summary report will provide data for all departments having cost share information, while the Department detail report is designed to provide information for a specific department.
Information on these reports will provide a budget estimate column from which actual expense performance can be measured for the current fiscal year and cumulative expenses to date. The final column on these reports provides an estimate of the remaining balance required to meet the budget estimate for each cost share account or department.
(Procedure established in June 2003)
Questions? Contact RFS
In addition to monthly reports, RFS is required to submit periodic financial statements concerning performance of the grant or contract. Often, this information must be submitted on a specific form or statement required by the sponsoring organization. Regarding these reports, it is important to keep in mind that the fiscal year of Georgia State University may not be the same as the sponsoring agency.
Year-end Closeout for Sponsored Awards
The University is required to develop and submit financial statements annually. Although Sponsored Awards have varying end dates, they are subject to certain year-end requirements in order for the University to produce accurate and timely financial statements. Everyone is encouraged to review accounting results monthly and submit adjustments and corrections in a timely manner. Each month-end accounting results are available by the second week of the month following the month just ended. Although this review should be ongoing, it is especially imperative to do so before the end of Georgia State's fiscal year.
Any adjustments needed on your project(s) should be processed without delay as soon as they are identified. You are particularly urged to review projects with the objective of determining whether there are over-expended budgets. These situations require urgent attention and should be resolved immediately. Also requiring special review are projects with an end date within the current fiscal year. Any payroll or non-personal adjustments relating to these projects should be processed within 90 days of the end date or earlier as specified by the awarding agency.
You are asked to review all payroll charges to ensure proper distribution to the correct departmental or project budgets. Requests for payroll adjustments should be forwarded to your designated college human resources officer of directly to Payroll, if you do not have a designee
Questions? Contact RFS
Under the Personnel Effort Reporting System, the distribution of salaries and wages will be supported by personnel effort reports as follows:
OMB Circular A-21 further requires that Personnel Effort Reports (PER) support cost sharing of salaries and wages on the sponsored programs.
Personnel Effort Reports should document personnel effort provided in support of departmental administration activities.
Georgia State University employees who meet the following criteria are covered by the personnel effort reporting system:
A PER will not be generated for any employee who does not meet the above criteria. However, if that employee did, in fact, expend effort on an activity described above, then that employee should request a PER for completion from RFS.
It is the responsibility of the employee (or certifying responsible official, if other than the employee) to identify and properly report effort expended.
The exceptions to the above criteria are any employees whose effort is accounted for by the time sheets (i.e. student assistants, temporary employees, etc.), part time instructors, and graduate teaching assistants. A PER will not be generated for these employees.
All Faculty, Staff and Graduate Assistants who meet the above criteria will complete a PER by semester.
As stated in above, OMB Circular A-21 requires that certification of effort expended be reported on an after-the-fact basis. The following information is provided for assistance in completing Personnel Effort Reports:
Monitoring and Review
Internal reviews and audits will be performed to assure that the PER System complies with the personnel effort reporting requirements as specified in OMB Circular A-21. Research Financial Services will monitor the system to insure that all personnel effort reports are returned and properly reflected in the University's accounting system. The University's Internal Audit staff will periodically review the system to insure the system's effectiveness and compliance with OMB regulations.
The Personnel Effort Reporting System will support personnel effort expended for departmental administration. Departmental administrative effort includes, but is not limited, to the following:
Salaries of department heads are, by virtue of their position, deemed to be all or in part administrative in nature.
For salaries of professorial and professional staff to be included in departmental administration, it is necessary for their workload to include administrative work as described above.
Organizational units such as institutes, study centers, and research centers must also support any departmental administration through the use of Personnel Effort Reports.
OMB Circular A-21 requires that all cost sharing be recorded, accounted for and documented in the same manner and to the same extent as all other costs of the grantee. Such documentation is frequently required by Federal, State, Local and Private sponsors.
All cost shared salaries must be accounted for by Personnel Effort Reports. The sponsored project for which the effort is being cost shared must be indicated on the PER. Enter the Sponsored Account – not the Cost Share account in the “Specifics” field of the report.
It is emphasized that the amount of University cost sharing included in proposals and applications should be limited to the amount specifically required by the funding agency. Documenting cost sharing will continue to be the Department Head's responsibility.
Activity Definitions (used in PERS)
Questions? Contact Nichole Andrews at (404) 651-3946
Re-budgeting
Re-budgeting within awarded budget line items is usually possible, however, the sponsoring agencies have different restrictions on deviations from the approved budget. When re-budgeting requires approval by the sponsoring agencies, a formal written request with accompanying justification must be made and processed through OSP. However, many awards allow these changes to occur at the discretion of the PI. In these cases, the re-budgeting section of the IPAS must be completed and sent to the assigned RFS staff. This form should be completed if you are re-budgeting more than 25% of any budget category. Less than 25% does not need prior approval.
The terms and conditions of the award agreement should specify any budgetary restrictions imposed by a particular sponsor. If the terms and conditions for re-budgeting are not addressed or are unclear in the award agreement the PI/PD should consult RFS for clarification and direction.
Change of PI/PD
Circumstances may on occasion warrant the designation of a new PI/PD. A sponsor must be advised, and permission obtained, before a new PI/PD may be designated. If the PI/PD finds it necessary to nominate someone, such requests must bear the signed endorsement of the Department Chairperson and the Dean. If the request is made by the Department Chairperson, it must be endorsed by the Dean. (If the PI/PD is the Dean, the request should bear the endorsement of the next higher authority). A request to a sponsoring agency for designation of a new PI/PD will normally state the reasons for such change and will include the curriculum vita of the PI/PD-designate. Such requests must be submitted to OSP for institutional endorsement, before forwarding to the sponsor.
Transfer of Contract or Grant
Transfer to another institution: A PI/PD who is transferring to another institution may wish to continue his or her sponsored projects at the new institution. Steps may be initiated to transfer the grant or contract only upon concurrence of the Department Chairperson and the Dean. There may be instances in which the University elects to retain the projects and nominate an alternate PI/PD. Permission must be obtained from the sponsoring agency for such transfers (transfers are by no means automatically granted by all sponsors). Arrangements must proceed through OSP.
Transfer from another institution: A faculty member coming from another institution who will be appointed to Georgia State University may have a sponsored project which he or she wishes to transfer here. Such transfer requires the home institution's approval in addition to the approval of the sponsoring agency. A new proposal (or the revised original) with new budgetary information must then be processed at Georgia State University through the normal routing and approval cycle, prior to submission to the sponsoring agency.
Questions? Contact OSP
Funds can not be expended past the project end date. However, if additional time is needed to accomplish the projects' objectives with no additional funds, a project may be eligible for a no-cost extension. A no-cost extension allows funds to be expended past the original project end date and extends the date that final programmatic and financial reports are due. All requests for no-costs extensions must be approved prior to the expiration of the grant. Under the terms and conditions of many federal awards, the University has the option of extending the project for a period of up to 12 months without having to contact the sponsor for permission. For these grants, PIs should complete the appropriate sections of the IPAS, obtain the appropriate signatures, and submit the request to their OSP officer.
For those grants that require agency approval, a PI should prepare a separate written request an includes a justification for the extension that relates to the completion of the objectives of the award, NOT that funds are remaining. These requests must be routed to OSP using the IPAS. Please note that requests to agencies generally take one-to two months to process and approve. Therefore, we suggest such requests should be submitted three months before the expiration of the grant in order to have the approved extension prior to the original expiration date.
PIs should consult with OSP early in the last year of funding to determine if their award is eligible for a no-cost extension and, if so, if agency approval is required.
Questions? Contact OSP
Reporting to Sponsor
With few exceptions, every sponsored project will require a number of reports during the life of the project and most certainly at its conclusion. Every PI/PD should be prepared to submit a final technical report at the very least. The importance of the submission of such a report on a timely basis cannot be overstated. In a grant or contract arrangement, unlike a gift, the sponsor expects and deserves to be informed of results. Negligence by the PI/PD may substantially impact his/her (and the University's) ability to receive other support from the sponsor; it may also result in a loss of payment for costs already incurred. In addition to technical report(s), other reports may be required relating to inventions, equipment accountability, and fiscal data and voucher submissions. The latter three are the responsibility of the RFS, while the PI must prepare the first two. The PI should send to OSP a copy of their final programmatic report—(if not required, a note from the PI/PD so stating) and a report of inventions, patents, and copyright materials produced with the aid of sponsored funds. These reports will be scanned and stored as an attachment to OSP's InfoEd data base.
Financial Project Close-Out
The Principal Investigator (PI) has responsibility for the technical and fiscal management of a sponsored project, and ultimately the orderly project closeout. Research Financial Services sends a number of letters described below to assist the PI in the vital financial close-out/termination process.
Department administrators/business managers also receive copies of each letter. The signed letters become part of the permanent financial records that are reviewed by internal and external auditors as well as applicable funding agencies.
Financial Management that Ensures Proper Project Close-out
To ensure that proper close-out of sponsored awards complies with agency rules, the RFS Officers perform a close-out review that includes the review of all award and companion account expenditures and receipts, as well as, a review of the payroll system records and the accumulation of data necessary to provide an audit trail.
It is the responsibility of GSU to ensure that adequate provision is made for the auditing of accounting information and the accounting system that processes the accounting data. To this end, the GSU financial system stores five or more years of award accounting data on-line. RFS maintains hard copies of financial reports submitted to sponsoring agencies and archives related budget and expenditure correspondence for a minimum of five years, unless specified otherwise by the sponsor.
RFS has liaison responsibility for the coordination of all audits, audit responses, and requests for accounting information on sponsored awards from organizations outside the University.
Important Polices to be Followed
Questions? Contact RFS
In order to appropriately administer and closeout awards within the University's financial system, OSP and RFS staff categorizes projects into two distinct types. The defining characteristics of each type are described below.
Cost-reimbursable sponsored projects provide for payment of allowable incurred costs, to the extent prescribed in the agreement. These agreements establish a budget of total cost for the purpose of obligating funds and establishing a ceiling that the sponsor will not normally exceed. Requests for reimbursement of costs are most likely accomplished through either drawing-down funds via letter of credit or invoicing. Most projects at GSU are categorized as cost-reimbursable. In rare cases, a sponsored project that is cost-reimbursable may provide payments in advance of costs being incurred. In these agreements, the sponsor requires a final or intermittent financial report reflecting all costs incurred and a refund of unused funds upon termination/closeout of the award.
Federal Projects. Most federal projects are cost-reimbursable and are paid via letter of credit. Costs are incurred and then “drawn down” through a reporting process where expenditures are reported on a quarterly basis. Federal projects are almost never funded in advance of expenditures, hence when a project is over, there are no actual funds that remain or need to be returned.
Non-Federal Projects. Although some non-federal projects also are funded through invoicing or letters of credit, many state, foundation, and private cost-reimbursable sponsored projects may be funded in advance (prior to incurring expenses).
Project Invoicing. For cost-reimbursable awards, as part of the monthly review process, RFS request funds from sponsors to reimburse GSURF for each month's expenditures. Invoices for state, local, and private sponsored projects are system-generated through our financial accounting system on a monthly basis. The RFS staff accountants generate quarterly invoices. Non-federal sponsors are invoiced either monthly or quarterly, depending on the terms of the award.
Sponsored Projects that are fixed price operate under an established price that is not subject to any adjustment on the basis of the contractor's cost experience in performing the agreement. This type of project places maximum risk and full responsibility for all costs and resulting profit or loss on the contractor. In these cases, the contractor is motivated to control costs, insure efficiency, and minimize the administrative burden on the contracting parties. When the fixed price total exceeds the total costs incurred, the remaining funds are considered residual balances. The treatment of these balances varies depending on whether the sponsored project is funded through the GSU Research Foundation or GSU. The vast majority of the university's sponsored projects are funded through the GSU Research Foundation where residual balances are transferred to departmental residual projects (i.e., ALR##, BLR##). Once all project deliverables are completed and all funds are received, the original project is closed out within 90 days of the project end date and all residual funds are transferred.
Questions? Contact RFS