Sponsored Project AdministrationSponsored Project Administration

Pre and Post AwardPre and Post Award

Jackie Bendall, Director 4-7991Jackie Bendall, Director 4-7991

Office of Research Training & ComplianceOffice of Research Training & Compliance

January 2009January 2009

AcronymsAcronyms FAR (Federal Acquisition Regulation)FAR (Federal Acquisition Regulation) OMB (Office of Management & Budget)OMB (Office of Management & Budget) NGA (Notice of Grant Award)NGA (Notice of Grant Award) RFP (Request for Proposal)RFP (Request for Proposal) RFA (Request for Application)RFA (Request for Application) FO (Funding Opportunity)FO (Funding Opportunity) CIS (Change in Status)CIS (Change in Status) CFA (Center Finance Administrator)CFA (Center Finance Administrator) BPR (Budget Performance Report)BPR (Budget Performance Report) MTDC (Modified Total Direct Cost)MTDC (Modified Total Direct Cost) TDC (Total Direct Cost)TDC (Total Direct Cost) FAC (Facilities & Administrative Cost)FAC (Facilities & Administrative Cost) GCRC (General Clinical Research Center)GCRC (General Clinical Research Center)

For complete list of commonly used acronyms, please seeFor complete list of commonly used acronyms, please see http://www.gwu.edu/~research/files/Acronyms.pdfhttp://www.gwu.edu/~research/files/Acronyms.pdf

What constitutes Sponsored Research at What constitutes Sponsored Research at GW?GW?

If one or more of the following criteria exist within a grants or contract proposal, it must be processed through the OCRO:

1. The award requires a line-item financial report to the grantor/sponsor at any time during the life of the project.

2. The award has a cost-sharing component (University, school, or department matching funds).

3. The award is one of several to a project for which there is a project-wide financial reporting requirement (i.e., any of the granting/sponsoring entities require a financial report for the entire project).

4. The grantor/sponsor controls the scope of the project and/or requires scientific or technical reporting of specific milestones as a condition of the grant/award.

5. The award includes funds that will be re-granted or subcontracted by the University to non-GW entities.

6. The award includes indirect costs recoveries.

What constitutes Sponsored What constitutes Sponsored Research at GW, cont.Research at GW, cont.

7. The award involves an Intergovernmental Personnel Act (IPA) agreement that places GW personnel on assignment to a Federal agency.

8. The grantor/sponsor states in its award letter that it maintains the right to perform a detailed financial audit of the award expenditures.

9. The proposal indicates a conflict of interest;

10. The proposal contains the use of animals, human subjects, or hazardous agents requiring the review of OHRCTT;

11. There are conditional obligations of the funding indicated in the award document or solicitation (e.g., time and effort, space, budget restrictions, return of unused funds, contingent payments, employment requirements);

12. The award or solicitation contains intellectual property provisions, indemnification, hold harmless, provisions containing restrictions on publication of research results and other contractual provisions that place risk on the University.

Proposal Search MechanismsProposal Search Mechanisms Community of ScienceCommunity of Science

GW subscribes to this service.

http://www.gwu.edu/~research/files/cosintro.pdf

The Illinois Researcher Information System The Illinois Researcher Information System (IRIS)(IRIS)

http://www.library.uiuc.edu/iris/

The Foundation CenterThe Foundation Center located right here in DClocated right here in DC

http://foundationcenter.org/washington/

Grants.govGrants.gov

http://www.grants.gov/search/search.do?docs1=doc_open_checked&dates=7&mode=Search

Federal Business OpportunitiesFederal Business Opportunities

http://www.fedbizopps.gov/

For direct assistance in solicitation searches, please contact Laura For direct assistance in solicitation searches, please contact Laura Walker, Information Specialist in OCRO at 4-9136 or email at Walker, Information Specialist in OCRO at 4-9136 or email at

alwalker@gwu.edu.

Pilot Project with CayusePilot Project with Cayuse

Web BasedWeb Based Streamlined Proposal SubmissionStreamlined Proposal Submission Electronic RoutingElectronic Routing Limited ReportingLimited Reporting Error ChecksError Checks Subawards.comSubawards.com Supports Most Grants.gov submissionsSupports Most Grants.gov submissions Pilot ends February 2009Pilot ends February 2009 Contact May Watling to be set-up (4-7990)Contact May Watling to be set-up (4-7990)

Responding to Solicitations/Funding Responding to Solicitations/Funding Opportunities Opportunities

Know the difference between an RFA , RFQ , RFP Know the difference between an RFA , RFQ , RFP Always contact your RSC if you receive an RFPAlways contact your RSC if you receive an RFP RFPs from federal sources result in contracts (not grants or RFPs from federal sources result in contracts (not grants or

cooperative agreements).cooperative agreements). Contracts result generally from a competitive selection process and are Contracts result generally from a competitive selection process and are

subject to Procurement regulations of the FAR.subject to Procurement regulations of the FAR. Always notify your RSC in advance if you know the solicitation or Always notify your RSC in advance if you know the solicitation or

funding opportunity you are responding to.funding opportunity you are responding to. RFPs contain representations and certifications that must be RFPs contain representations and certifications that must be

completed at proposal submission.completed at proposal submission. RFPs may contain preparation of small business and small RFPs may contain preparation of small business and small

disadvantaged business subcontracting plans for any anticipated disadvantaged business subcontracting plans for any anticipated award over $500Kaward over $500K

Elements of a ProposalElements of a Proposal

Statement of Work – (must in detail explain the Statement of Work – (must in detail explain the scope of the project, including detailed scope of scope of the project, including detailed scope of proposed collaborators/consultants.proposed collaborators/consultants.

BudgetBudget Budget JustificationBudget Justification Resources (if necessary)Resources (if necessary) CVs/Bios/PublicationsCVs/Bios/Publications Reps and Certs (if necessary)Reps and Certs (if necessary) Subrecipient’s budget/sow/budget Subrecipient’s budget/sow/budget

justification/letter of intentjustification/letter of intent

Letter of IntentLetter of Intent

A “Letter of Intent” (LOI) expresses the intention to submit A “Letter of Intent” (LOI) expresses the intention to submit a proposal in response to a particular program a proposal in response to a particular program announcement or request for proposals.  announcement or request for proposals. 

LOI’s are generally solicited by the sponsor in conjunction LOI’s are generally solicited by the sponsor in conjunction with an announcement that is expected to generate with an announcement that is expected to generate widespread interest.widespread interest.

If the LOI contains budget estimates or representations, it If the LOI contains budget estimates or representations, it should be reviewed and approved by the appropriate RSC should be reviewed and approved by the appropriate RSC prior to submission.  The Managing Director of Research prior to submission.  The Managing Director of Research Support and Analysis will sign the letter as an indication of Support and Analysis will sign the letter as an indication of the institution’s concurrence with the planned submission.the institution’s concurrence with the planned submission.

OMB Circular A-21 Cost PrinciplesOMB Circular A-21 Cost Principles

Read GWs policy on Direct Charging of Read GWs policy on Direct Charging of Administrative Costs (very important)Administrative Costs (very important)

Understand what costs are unallowable on Understand what costs are unallowable on FEDERAL awards in accordance with OMB FEDERAL awards in accordance with OMB Circular A-21 at Circular A-21 at http://www.whitehouse.gov/omb/circulars/a021/a21_2004.htmlhttp://www.whitehouse.gov/omb/circulars/a021/a21_2004.html

Understand the “exceptional circumstances” rule Understand the “exceptional circumstances” rule of thumb for charging administrative costs.of thumb for charging administrative costs.

Accounts typically not charged to Accounts typically not charged to federally sponsored projectsfederally sponsored projects

Advertising - 55151Advertising - 55151 Bad Debt Expense - 53911 Bad Debt Expense - 53911 Entertainment - 52611 Entertainment - 52611 Fines, Fees, and Penalties - 52442 Fines, Fees, and Penalties - 52442 GW Advertising - 59523GW Advertising - 59523 Lobbying - 52616 Lobbying - 52616 Metro Area Alumni Activities - 52722 Metro Area Alumni Activities - 52722 Prizes and Awards – 57121Prizes and Awards – 57121 Publicity & Promotion – 55152Publicity & Promotion – 55152 MISC Expense – 52691 MISC Expense – 52691 Office Supplies – 54111Office Supplies – 54111 Postage/Express Mail- Non-GW – 53411Postage/Express Mail- Non-GW – 53411 Telephone Direct – 53311Telephone Direct – 53311 Misc Supplies - 54541Misc Supplies - 54541

Exceptional CircumstancesExceptional Circumstances

- Large complex programs such as Clinical Research - Large complex programs such as Clinical Research Centers, primate centers and program projects that entail Centers, primate centers and program projects that entail managing teams of investigators from a number of managing teams of investigators from a number of departments and institutions.departments and institutions.

- Projects which involve substantial data accumulation, - Projects which involve substantial data accumulation, analysis, entry, surveying, cataloging, etc., such as analysis, entry, surveying, cataloging, etc., such as epidemiological studies, multi-center clinical trials.epidemiological studies, multi-center clinical trials.

- Projects involving extensive travel or meeting - Projects involving extensive travel or meeting arrangements for a large group of participants. arrangements for a large group of participants.

- Projects whose exclusive purpose is for the preparation of - Projects whose exclusive purpose is for the preparation of manuals/books, large reports outside the normal technical manuals/books, large reports outside the normal technical reports.reports.

Budget PlanningBudget Planning

Personnel (expressed in % of total GW effort) include Personnel (expressed in % of total GW effort) include anticipated salary increases if multi-year. (Jan 1 – admin anticipated salary increases if multi-year. (Jan 1 – admin and research staff and Med Ctr. Staff, and July 1 for MC and research staff and Med Ctr. Staff, and July 1 for MC Faculty and Jan 1 for University Faculty, not the Faculty and Jan 1 for University Faculty, not the anniversary of the project award).anniversary of the project award).

Fringe BenefitsFringe Benefits Supplies Supplies Travel (Foreign/Domestic)Travel (Foreign/Domestic) EquipmentEquipment SubawardsSubawards Independent Contractors/ConsultantsIndependent Contractors/Consultants Space/RentalSpace/Rental MTDC/TDC (remember exclusion criteria for MTDC)MTDC/TDC (remember exclusion criteria for MTDC)

Fringe BenefitsFringe Benefits

Fringe benefits are charged as the University provides a Fringe benefits are charged as the University provides a percentage of salaries for all regular full-time employees percentage of salaries for all regular full-time employees and certain part-time employees to cover such benefits as and certain part-time employees to cover such benefits as retirement, health care, and tuition benefits. The funds retirement, health care, and tuition benefits. The funds generated are pooled and eligible employees may draw generated are pooled and eligible employees may draw from them to the extent appropriate to the terms of their from them to the extent appropriate to the terms of their employment. There is a separate rate for temporary hourly employment. There is a separate rate for temporary hourly wage employees who work 700 hours or less per year. wage employees who work 700 hours or less per year. Fringe benefit rates are determined annually; consult the Fringe benefit rates are determined annually; consult the Office of the Chief Research Officer or its Web site (Office of the Chief Research Officer or its Web site (http://http://www.gwu.edu/~research/boiler.htmwww.gwu.edu/~research/boiler.htm ) for current rate ) for current rate information. information.

Budget Terms cont.Budget Terms cont.

MTDC = Modified Total Direct CostsMTDC = Modified Total Direct CostsThe base to which indirect costs rates are applied. Modified Total The base to which indirect costs rates are applied. Modified Total Direct Costs consist of "salaries and wages, fringe benefits, materials Direct Costs consist of "salaries and wages, fringe benefits, materials and supplies, services, travel, and subgrants and subcontracts up to and supplies, services, travel, and subgrants and subcontracts up to the first $25,000 of each subgrant or subcontract (regardless of the the first $25,000 of each subgrant or subcontract (regardless of the period covered by the subgrant or subcontract). period covered by the subgrant or subcontract).

Exclusions from Base:Exclusions from Base:

Equipment, capital expenditures, charges for patient care, tuition Equipment, capital expenditures, charges for patient care, tuition remission, rental costs, scholarships, and fellowships as well as the remission, rental costs, scholarships, and fellowships as well as the portion of each subgrant and subcontract in excess of $25,000 shall be portion of each subgrant and subcontract in excess of $25,000 shall be excluded from modified total direct costs. excluded from modified total direct costs.

Budget JustificationBudget Justification

Must explain each proposed cost to project and Must explain each proposed cost to project and how it is necessary to help accomplish the aims of how it is necessary to help accomplish the aims of the projectthe project

Any cost charged to a project must be specifically Any cost charged to a project must be specifically for that project alonefor that project alone

Do not use generic terms for supplies, if office Do not use generic terms for supplies, if office supplies are required, indicate what kind, if you supplies are required, indicate what kind, if you are using MISC supplies, indicate what types of are using MISC supplies, indicate what types of MISC supplies are being purchased.MISC supplies are being purchased.

Travel cost must explain where, when and why.Travel cost must explain where, when and why.

Optional Budget ToolOptional Budget Toolhttp://www.gwu.edu/~research/traininginfo6.htmhttp://www.gwu.edu/~research/traininginfo6.htm

Talk to your RSCTalk to your RSC Do not cost share unless it’s mandatoryDo not cost share unless it’s mandatory Review the application instructions in case a specific budget format is Review the application instructions in case a specific budget format is

requiredrequired Know your institutions’ ratesKnow your institutions’ rates

Budget TemplatesBudget Templates

What internal forms are required for routing?What internal forms are required for routing?

1.1. Proposal Routing and Approval Proposal Routing and Approval Form/Non-Competing Continuation Form/Non-Competing Continuation Routing Form Routing Form (if applicable)(if applicable)http://http://www.gwu.edu/~research/forms/routingform.pdfwww.gwu.edu/~research/forms/routingform.pdf

2.2. Conflict of Interest Disclosure Conflict of Interest Disclosure FormForm

http://www.gwu.edu/~research/forms/Conflicthttp://www.gwu.edu/~research/forms/Conflict%20of%20interest.pdf%20of%20interest.pdf

All proposal submissions require the following no matter whatAll proposal submissions require the following no matter what::

3.3. The proposal in accordance with the sponsor’s solicitation or The proposal in accordance with the sponsor’s solicitation or guidelines.guidelines.

Proposal Submissions Workflow…Principal

Investigator (PI) informs OCRO of

RFP/RFA and initiates

documentationResearch Service Coordinator (RSC)

completes First Review of Proposal

Pre-Award Specialist completes

Second Review of Proposal

Managing Director Research Support

and Analysis completes Third

and Final Review

Proposal Complete

PI submits proposal to

RSC

Proposal inaccurate/incomplete

Proposal inaccurate/incomplete

After Final Approval – returned to Pre-Award

Specialist for Electronic Submission

Paper proposal submissions are routed to the department for mailing

PI initiates/informs RSC of RFP (Request for Proposal) and in turn, RSC sends RFP information to the Pre-Award Specialist and Contracts Manager)

-Route to Dean for signature

-Submit to Anne Hirshfield (if voluntary cost-sharing)

-Return to RSC

Optional Forms Required for the Optional Forms Required for the following cases:following cases:

Cost Sharing Form (Attach if you plan to cost-share, either mandatory or Cost Sharing Form (Attach if you plan to cost-share, either mandatory or voluntary/committed) voluntary/committed) http://www.gwu.edu/~research/forms/costshareform.pdfhttp://www.gwu.edu/~research/forms/costshareform.pdf

Are multiple investigators involved? If so, submit this form:Are multiple investigators involved? If so, submit this form:http://www.gwu.edu/~research/forms/allocationform.pdfhttp://www.gwu.edu/~research/forms/allocationform.pdf

Is a sub-award to another collaborator required? Remember, subwards are issued when Is a sub-award to another collaborator required? Remember, subwards are issued when GW plans to collaborate with another entity to help perform a part of the statement of GW plans to collaborate with another entity to help perform a part of the statement of work. Submit the following checklist with forms: work. Submit the following checklist with forms: http://www.gwu.edu/~research/forms/SubAchecklist.pdfhttp://www.gwu.edu/~research/forms/SubAchecklist.pdf

Are human subjects involved? Submit form on website Are human subjects involved? Submit form on website http://www.gwumc.edu/research/human/http://www.gwumc.edu/research/human/

Are animals involved? Submit form on website Are animals involved? Submit form on website http://www.gwumc.edu/research/animal/forms.htmhttp://www.gwumc.edu/research/animal/forms.htm

Are biohazards involved? Submit form on website: Are biohazards involved? Submit form on website: http://http://www.gwumc.edu/research/labsafety/commbull.htmwww.gwumc.edu/research/labsafety/commbull.htm

Forms are filled out, where do I route Forms are filled out, where do I route my proposal?my proposal?

All investigators involved on the project must sign the proposal routing form All investigators involved on the project must sign the proposal routing form first; for multi-year cross departmental situations, it is the lead PI who is first; for multi-year cross departmental situations, it is the lead PI who is responsible to ensure that all signatures are contained, all assurances are met, responsible to ensure that all signatures are contained, all assurances are met, and all terms and conditions upon receipt of award are complied with.and all terms and conditions upon receipt of award are complied with.

Chairs, Deans, Directors, VPs must sign where appropriate.Chairs, Deans, Directors, VPs must sign where appropriate.

Additional signature(s) - As required. Loudon Campus: the Executive Director and the VP for Academic Affairs must sign all proposals originating from or involving the Loudoun Campus.

Medical Center - The Associate VP for Health Research, Compliance, and Technology Transfer must sign all proposals originating from or involving the Medical Center.

The Research Service Coordinator (RSC) must initial before the proposal is received and signed by GW’s Institutional Official (Hal Gollos) in OCRO.

What is Cost Sharing?What is Cost Sharing?

Cost sharing are those costs borne/shared by the University, not the Cost sharing are those costs borne/shared by the University, not the agency, and are proposed up front. There are three types of Cost agency, and are proposed up front. There are three types of Cost sharing:sharing:

MandatoryMandatory – Required by the agency in solicitation or guidelines; – Required by the agency in solicitation or guidelines;

Voluntary CommittedVoluntary Committed – –an implied willingness for the University to bear certain project costs contained in the proposal submitted to the sponsor. The commitment is not a requirement imposed by the sponsor. Requires approval from Anne Hirshfield. Must be tracked in the financial system if specified in proposal.

Voluntary UncommittedVoluntary Uncommitted - - neither a sponsor requirement nor a University commitment but represents additional costs incurred by the University beyond the levels in the proposal and/or award documents. Voluntary cost sharing is not specifically quantified in the proposal submitted to the sponsor. Federal regulations do not require the University to document voluntary cost sharing.

Must Not’s of Cost SharingMust Not’s of Cost Sharing University policy states that no cost sharing is allowed on University policy states that no cost sharing is allowed on

federal sponsored projects unless it’s a mandatory federal sponsored projects unless it’s a mandatory requirement from the agency;requirement from the agency;

Cost shared expenses must not be expenses already Cost shared expenses must not be expenses already included under another sponsored project as cost sharing;included under another sponsored project as cost sharing;

Cost shared expenses must not be paid by any federal Cost shared expenses must not be paid by any federal sponsor under another agreement, unless authorized by sponsor under another agreement, unless authorized by federal statute for that purpose and the sponsor approves federal statute for that purpose and the sponsor approves these costs in writing.these costs in writing.

Federal regulations do not allow admin and clerical staff Federal regulations do not allow admin and clerical staff salaries or wages, inc. fringe benefits and salary dollars in salaries or wages, inc. fringe benefits and salary dollars in excess of the stated NIH salary cap to be cost shared.excess of the stated NIH salary cap to be cost shared.

ADMINISTRATIVE ESTABLISHMENTSADMINISTRATIVE ESTABLISHMENTS

When the program officer has notified a PI that the proposal has When the program officer has notified a PI that the proposal has been funded but there will be a delay from the grants been funded but there will be a delay from the grants management office in sending out the official paperwork, what management office in sending out the official paperwork, what can I do???can I do???

– Request an Administrative Establishment via email from your Request an Administrative Establishment via email from your Research Service Coordinator.Research Service Coordinator.

This will allow the University sets up an award in the financial system This will allow the University sets up an award in the financial system before the official notice of award is received in order to allow the work before the official notice of award is received in order to allow the work to begin.to begin.

– Compliance approvals for the project must be in place before work Compliance approvals for the project must be in place before work begins (IRB, IACUC, etc.). These approvals are the PI’s begins (IRB, IACUC, etc.). These approvals are the PI’s responsibility.responsibility.

– Administrative Establishments are generally set for a three month Administrative Establishments are generally set for a three month period and may be extended. Your RSC can provide additional period and may be extended. Your RSC can provide additional guidance.guidance.

Administrative Extensions and Administrative Extensions and FundingFunding

Once approved, the RSC sets up the award as an Once approved, the RSC sets up the award as an Administrative Establishment in the financial system for a Administrative Establishment in the financial system for a period of up to 90 days.  period of up to 90 days. 

– If the award is not forthcoming, then at least two-weeks before the If the award is not forthcoming, then at least two-weeks before the expiration of the Administrative Establishment period, the Principal expiration of the Administrative Establishment period, the Principal Investigator should discuss the matter with the Chair and/or Dean Investigator should discuss the matter with the Chair and/or Dean and determine whether to recommend that the Administrative and determine whether to recommend that the Administrative Establishment be extended for an additional period. Establishment be extended for an additional period.

Should an extension be desired, requests for existing Should an extension be desired, requests for existing Administrative Establishments must be processed and Administrative Establishments must be processed and approved through same process as the originating approved through same process as the originating Administrative Establishment. Administrative Establishment.

Authorized SignatoriesAuthorized Signatories

Officials Authorized to Commit the University: Officials Authorized to Commit the University: Donald Donald Lehman, Executive Vice President for Academic AffairsLehman, Executive Vice President for Academic AffairsCarol Sigelman, Chief Research OfficerCarol Sigelman, Chief Research OfficerRobert Donnally, Managing Director, Research Services & Robert Donnally, Managing Director, Research Services & OperationsOperations*Hal Gollos, Managing Director, Research Support & *Hal Gollos, Managing Director, Research Support & AnalysisAnalysis

(*Hal Gollos is the primary signature authority, however if (*Hal Gollos is the primary signature authority, however if he is unavailable for any reason then RSCs are notified he is unavailable for any reason then RSCs are notified about who will sign in his absence.) about who will sign in his absence.)

PART IIPART IIPost Award Activity Post Award Activity

I’ve received my award: what happens now?I’ve received my award: what happens now?

Review the award document very carefully and read embedded links to Review the award document very carefully and read embedded links to terms and conditions or attached terms and conditions thoroughly. terms and conditions or attached terms and conditions thoroughly. These terms will dictate to you what prior approvals are required These terms will dictate to you what prior approvals are required should you anticipate the following:should you anticipate the following:

– Request additional time to complete your project; Request additional time to complete your project;

– Request a leave of absence or substitute a change in key/senior personnel;Request a leave of absence or substitute a change in key/senior personnel;

– Move funds between budget categories (most re-budgeting is allowed Move funds between budget categories (most re-budgeting is allowed unless it exceeds 25% of the total amount awarded) check the terms first unless it exceeds 25% of the total amount awarded) check the terms first though to ensure sponsor specific criteria.though to ensure sponsor specific criteria.

– Request a sub-award (collaborator) or independent contractor for services Request a sub-award (collaborator) or independent contractor for services not originally anticipated or budgeted for in the initial proposal submission;not originally anticipated or budgeted for in the initial proposal submission;

– Request to purchase equipment not originally proposedRequest to purchase equipment not originally proposed

– Request for foreign travelRequest for foreign travel

How is my award processed?How is my award processed?

All awards shall ultimately be received by All awards shall ultimately be received by Hal Gollos, OCRO; Hal Gollos, OCRO;

Award terms and conditions are reviewed Award terms and conditions are reviewed and negotiated, if necessary by the Pre-and negotiated, if necessary by the Pre-award managers;award managers;

Upon completion of negotiation, we have a Upon completion of negotiation, we have a fully executed agreement and the award is fully executed agreement and the award is set up in Oracle.set up in Oracle.

Proposal/Award ComboProposal/Award Combo

Occurs when award arrives and a proposal Occurs when award arrives and a proposal was never submitted. was never submitted.

OCRO will request retroactively that a OCRO will request retroactively that a proposal be prepared to support the award.proposal be prepared to support the award.

Process is not encouraged, award set-up Process is not encouraged, award set-up can be delayed. can be delayed.

Terms may be unacceptable and will impact Terms may be unacceptable and will impact start date of project.start date of project.

Fixed Price AwardsFixed Price Awards Fixed price awards are risky. One price is set for the work, Fixed price awards are risky. One price is set for the work,

generally not recommended for research;generally not recommended for research; Costs resulting in over runs cannot be recovered. Costs resulting in over runs cannot be recovered. Work performed should be at a level where predictability is Work performed should be at a level where predictability is

accurate.accurate. No financial reporting, audit requirements, any reference to No financial reporting, audit requirements, any reference to

costs being “reimbursable”, are not subject to cost costs being “reimbursable”, are not subject to cost accounting standards or federal circulars except A-133 and accounting standards or federal circulars except A-133 and no references to allowable expenditures or prior approval no references to allowable expenditures or prior approval related to expenditures.related to expenditures.

Excess funds must be Excess funds must be Caution: Over-pricing and large remaining balances create Caution: Over-pricing and large remaining balances create

huge red flags to auditors.huge red flags to auditors.

Cost Reimbursable AwardsCost Reimbursable Awards

Standard method of contracting with Standard method of contracting with universities;universities;

Work performed is by reasonable efforts;Work performed is by reasonable efforts; Costs proposed are estimated;Costs proposed are estimated; Provide payment for Provide payment for allowable allowable incurred incurred

costs.costs. Federal Funds are usually drawn down by Federal Funds are usually drawn down by

letter of credit.letter of credit.

PI responsibilitiesPI responsibilities Review terms and conditions of award;Review terms and conditions of award; Conduct project according to SOW proposed;Conduct project according to SOW proposed; Notify your CFA, SRA or RSC of any changes such as a change in Notify your CFA, SRA or RSC of any changes such as a change in

scope, leave of absence, addition of subcontractor, equipment scope, leave of absence, addition of subcontractor, equipment purchase, etc.purchase, etc.

Monitor your expenditures closely;Monitor your expenditures closely; If committed cost sharing was proposed, ensure commitments are If committed cost sharing was proposed, ensure commitments are

fulfilled and reported to GCAS in a timely manner;fulfilled and reported to GCAS in a timely manner; Complete effort reports;Complete effort reports; Provide care and maintenance of any property procured;Provide care and maintenance of any property procured; Write and submit progress reports, fulfill deliverables as proposed;Write and submit progress reports, fulfill deliverables as proposed; Review monthly payroll reports (ensure the person charged in the Review monthly payroll reports (ensure the person charged in the

payroll report is the actuall person on project –six digit account codes payroll report is the actuall person on project –six digit account codes may cause error);may cause error);

Ensure subecipients perform in accordance with statement of work, Ensure subecipients perform in accordance with statement of work, complete deliverables on a timely basis.complete deliverables on a timely basis.

Submit invoices on timeSubmit invoices on time

Know how to interpret the reports sent to Know how to interpret the reports sent to you and who to contact for questions:you and who to contact for questions:

Payroll Reports Payroll Reports

BPRs – GM-139/GM-140BPRs – GM-139/GM-140

Invoices – Invoices – Thorough review of invoices are crucial in meeting Thorough review of invoices are crucial in meeting the monitoring requirements of Contractors and Subrecipients. Effort the monitoring requirements of Contractors and Subrecipients. Effort proposed, potential cost sharing proposed, and review of other items proposed, potential cost sharing proposed, and review of other items proposed in the budget to ascertain work was performed to satisfaction proposed in the budget to ascertain work was performed to satisfaction is important before payment is approved. Issues with performance is important before payment is approved. Issues with performance should be addressed immediately to avoid potential litigation. should be addressed immediately to avoid potential litigation.

Travel & EntertainmentTravel & Entertainment

http://http://my.gwu.edu/files/policies/TravelEntertainmentFINAL.pdfmy.gwu.edu/files/policies/TravelEntertainmentFINAL.pdf

Charges $35 and under (meals and incidentals) do Charges $35 and under (meals and incidentals) do not require backup, however it is always preferred.not require backup, however it is always preferred.

All charges must state relevance to the project’s All charges must state relevance to the project’s scope (what, where, who, how?)scope (what, where, who, how?)

P-card use is subject to your departments rules.P-card use is subject to your departments rules.

Travel Advances & ReimbursementTravel Advances & Reimbursement Advances may be issued for up to $100 per day up to a maximum of $500 per Advances may be issued for up to $100 per day up to a maximum of $500 per

week for reasonable out-of pocket expenses. week for reasonable out-of pocket expenses.

The preferred method for obtaining advances is via ATM withdrawal using the The preferred method for obtaining advances is via ATM withdrawal using the P-Card (Medical Center does not permit P-Cards for travel and entertainment).P-Card (Medical Center does not permit P-Cards for travel and entertainment).

ATM advances may not be taken more than three (3) days before the expected ATM advances may not be taken more than three (3) days before the expected travel. Cash advances at ATMs overseas are dispensed in local currency and travel. Cash advances at ATMs overseas are dispensed in local currency and travelers may check with the P-Card Office to determine the availability of travelers may check with the P-Card Office to determine the availability of ATMs in their destination country.ATMs in their destination country.

Travelers may request travel advances in the form of direct deposit or GW Travelers may request travel advances in the form of direct deposit or GW check (depending upon their payroll setup) issued by AP within two (2) weeks check (depending upon their payroll setup) issued by AP within two (2) weeks of travel dates. Only one (1) outstanding advance is permitted at any time.of travel dates. Only one (1) outstanding advance is permitted at any time.

The IRS requires that travel reimbursement requests be submitted in sixty (60) The IRS requires that travel reimbursement requests be submitted in sixty (60) days. Reimbursements submitted later will become reportable and will be days. Reimbursements submitted later will become reportable and will be grossed with income and taxed. 30 day submittal at end of travel is strongly grossed with income and taxed. 30 day submittal at end of travel is strongly encouraged.encouraged.

Fly America ActFly America Act Federal Travel Regulations require that U.S. carriers must be used for Federal Travel Regulations require that U.S. carriers must be used for

travel that is to be reimbursed from federal grants and contracts. This travel that is to be reimbursed from federal grants and contracts. This policy is called the Fly America Act. policy is called the Fly America Act.

Compliance with the Fly America Act is our responsibility.Compliance with the Fly America Act is our responsibility.

Exceptions to the Fly America Act: Exceptions to the Fly America Act: – When the use of U.S. carrier service would extend travel time by 24 hours or more When the use of U.S. carrier service would extend travel time by 24 hours or more – When the costs of transportation are reimbursed in full by a third party, such as a foreign When the costs of transportation are reimbursed in full by a third party, such as a foreign

government or an international agency government or an international agency – When U.S. carriers do not offer nonstop or direct service between origin and destination. When U.S. carriers do not offer nonstop or direct service between origin and destination.

However, a U.S. carrier must be used on every portion of the route where it provides However, a U.S. carrier must be used on every portion of the route where it provides service unless, when compared to using a foreign air carrier, such use would:service unless, when compared to using a foreign air carrier, such use would:

Increase the number of aircraft changes outside the United States by two or more Increase the number of aircraft changes outside the United States by two or more Extend travel time by at least six hours or more Extend travel time by at least six hours or more Require a connecting time of four hours or more at an overseas interchange point. Require a connecting time of four hours or more at an overseas interchange point.

Note:Note: When one or more of the above circumstances apply, an When one or more of the above circumstances apply, an explanation indicating the appropriate exception must be provided on explanation indicating the appropriate exception must be provided on the Travel Report. the Travel Report.

Know how to purchase items (travel and Know how to purchase items (travel and supplies) for your project using the P-cardsupplies) for your project using the P-card

The GW Procurement Card (P-card) is to be used to The GW Procurement Card (P-card) is to be used to make low-dollar purchases (<=$2,500). Any make low-dollar purchases (<=$2,500). Any procurement request >$2,500, or those that have procurement request >$2,500, or those that have special purchasing restrictions, must be processed special purchasing restrictions, must be processed through Procurement via a purchase order. Three through Procurement via a purchase order. Three categories: Goods only, goods plus travel & categories: Goods only, goods plus travel & entertainment, goods, travel & entertainment and entertainment, goods, travel & entertainment and cash.cash.

It is the PI’s and department’s responsibility to monitor It is the PI’s and department’s responsibility to monitor the uses of their P-cards. (Please note that the the uses of their P-cards. (Please note that the Medical Center doesn’t allow P-cards for travel.)Medical Center doesn’t allow P-cards for travel.)

Charges must be within the award period, and they Charges must be within the award period, and they must be allowable on the Award per sponsor’s must be allowable on the Award per sponsor’s guidelines. All charges must be allocated through guidelines. All charges must be allocated through GW’s Pathway system (p-card system online)!GW’s Pathway system (p-card system online)!

P-card charges and backup documentation must be P-card charges and backup documentation must be approvedapproved by a supervisor.by a supervisor.

HonorariumsHonorariums Honoraria are non-routine, monetary payments given to Honoraria are non-routine, monetary payments given to

individuals in appreciation for their willingness to contribute individuals in appreciation for their willingness to contribute to University events or projects of short duration, such as:to University events or projects of short duration, such as:– presenting a lecture or speechpresenting a lecture or speech– serving as a discussant of or reviewing papers for a conferenceserving as a discussant of or reviewing papers for a conference– attending an advisory board meetingattending an advisory board meeting– carrying out other short-term academic activities carrying out other short-term academic activities

Requests for payments of honoraria must be accompanied Requests for payments of honoraria must be accompanied by a Form W-9, or the equivalent information, and by by a Form W-9, or the equivalent information, and by documentation regarding the nature of the event in which documentation regarding the nature of the event in which the recipient of the honorarium will be participating (such the recipient of the honorarium will be participating (such as a program or agenda). as a program or agenda).

A Supplier Registration Form and 20 Factors Test are not A Supplier Registration Form and 20 Factors Test are not required for payments of honoraria. required for payments of honoraria.

Procurement In-A-PageProcurement In-A-Page

http://www.gwu.edu/~research/files/Procurement%20in%20a%20Page.pdf

Independent ContractorsIndependent Contractors Formerly referred to as Service Agreements.Formerly referred to as Service Agreements. ICs operate as vendors, sell services to the general public during ICs operate as vendors, sell services to the general public during

normal business hours; are not subject to Compliance requirements. normal business hours; are not subject to Compliance requirements. Perform a service as part of the award, necessary but ancillary to the Perform a service as part of the award, necessary but ancillary to the

research being performedresearch being performed Fully burdened with FACFully burdened with FAC Subject to Procurement regulationsSubject to Procurement regulations Chart of Account codes are 55561 – Contract Service “Other” Chart of Account codes are 55561 – Contract Service “Other”

(Commercial Independent Contractors), and 55111 – Consultants (Commercial Independent Contractors), and 55111 – Consultants (Individual Independent Contractors)(Individual Independent Contractors)

Requisitions must reference these accounts. Documents necessary Requisitions must reference these accounts. Documents necessary for processing can be referenced in the Procurement-in-a-page chart.for processing can be referenced in the Procurement-in-a-page chart.

RSCs prepare agreements, Individual Independent Contractor Agmt/ RSCs prepare agreements, Individual Independent Contractor Agmt/ Commercial Independent Contractor Agmt.Commercial Independent Contractor Agmt.

Hiring an Independent ContractorHiring an Independent Contractor

http://www.gwu.edu/~research/forms/RequestICA-10.20082.doc

SubawardsSubawards

Agreements issued to subrecipients (e.g., Georgetown, MIT) Agreements issued to subrecipients (e.g., Georgetown, MIT) when GWs prime award is a grant or cooperative agreement.when GWs prime award is a grant or cooperative agreement.

Subrecipient performs a portion of GWs scope of work and Subrecipient performs a portion of GWs scope of work and its performance is measured by GWs PI. PI approval of its performance is measured by GWs PI. PI approval of invoice = acceptance of workinvoice = acceptance of work

Intent is to work collaborativelyIntent is to work collaboratively Dissatisfaction of work should be communicated to RSC Dissatisfaction of work should be communicated to RSC

immediately. (Stop work, termination)immediately. (Stop work, termination) Any change in scope should be communicated to RSC in Any change in scope should be communicated to RSC in

order to modify the agreement.order to modify the agreement. Subrecipient may disclose invention, publish in journalsSubrecipient may disclose invention, publish in journals Subrecipients are subject to terms and conditions of GWs Subrecipients are subject to terms and conditions of GWs

awardaward

Program Officers Acting as Program Officers Acting as Contracting OfficersContracting Officers

PI contact with Program Officers should occur only PI contact with Program Officers should occur only on a technical basis. on a technical basis.

While Program Officers authorize funding While Program Officers authorize funding commitments, they do not formally issue commitments, they do not formally issue agreements/task orders/delivery agreements/task orders/delivery orders/modifications.orders/modifications.

Contracting Officers/Grants Management Contracting Officers/Grants Management Specialists are the formal administrative contacts Specialists are the formal administrative contacts for RSCs to communicate with.for RSCs to communicate with.

Recruitment and Hiring Recruitment and Hiring on Sponsored Research Projectson Sponsored Research Projects

Sponsored Research Projects may be staffed through internal transfers or new hires.Sponsored Research Projects may be staffed through internal transfers or new hires.

In preparing the research proposal, the PI must consider how the research project will be In preparing the research proposal, the PI must consider how the research project will be performed and the types of staff, schedule, and effort required to accomplish the project’s performed and the types of staff, schedule, and effort required to accomplish the project’s technical goals. technical goals.

– Staff Categories:Staff Categories:• FacultyFaculty• Research Employees (includes Research Assistants/Graduate Students)Research Employees (includes Research Assistants/Graduate Students)• Regular Graded Employees/ AdministrativeRegular Graded Employees/ Administrative• StudentsStudents

Regular graded employees/faculty may be employed to work on sponsored research Regular graded employees/faculty may be employed to work on sponsored research projects as long as their work is necessary, allowable, and directly related to the projects as long as their work is necessary, allowable, and directly related to the Statement of Work.Statement of Work.

Upon award, the PI consults with the RSC and CFA to determine actual staffing Upon award, the PI consults with the RSC and CFA to determine actual staffing requirements and detailed descriptions of duties.requirements and detailed descriptions of duties.

The RSC outlines the relevant actions to complete the hiring and/or transferring of staff, The RSC outlines the relevant actions to complete the hiring and/or transferring of staff, the CFA provides assistance to the PI in processing proposed personnel actionsthe CFA provides assistance to the PI in processing proposed personnel actions

ALL PERSONNEL ACTION MUST BE COMPLETED BEFORE THE EFFECTIVE DATE ALL PERSONNEL ACTION MUST BE COMPLETED BEFORE THE EFFECTIVE DATE OF HIRE/TRANSFEROF HIRE/TRANSFER

Recruitment and Hiring of Research Recruitment and Hiring of Research EmployeesEmployees

GW has established eight research staff positions GW has established eight research staff positions – Research Assistant Research Assistant – Senior Research Assistant Senior Research Assistant – Research Associate Research Associate – Senior Research Associate Senior Research Associate – Post-Doctoral Scientist Post-Doctoral Scientist – Research Scientist Research Scientist – Senior Research Scientist Senior Research Scientist – Lead Research Scientist Lead Research Scientist

These titles may not accurately describe all possible positions These titles may not accurately describe all possible positions associated with the conduct of research. Alternative “working titles” associated with the conduct of research. Alternative “working titles” may be used for internal program purposes in addition to these eight may be used for internal program purposes in addition to these eight official titles.official titles.

GW research position descriptions and salary ranges are outlined in GW research position descriptions and salary ranges are outlined in the Handbook on Sponsored Programs, sections 8.1.1 the Handbook on Sponsored Programs, sections 8.1.1 http://www.gwu.edu/~research/handbook/develop.htm#resahttp://www.gwu.edu/~research/handbook/develop.htm#resa

Recruitment and Hiring of Research Recruitment and Hiring of Research Employees (cont.)Employees (cont.)

ProcessProcess

1.1. Complete the Request to Establish a New (Fill Existing) Full Time Research Staff Complete the Request to Establish a New (Fill Existing) Full Time Research Staff PositionPosition

2.2. Recruitment Steps (waivers of certain recruiting requirements are available in Recruitment Steps (waivers of certain recruiting requirements are available in appropriate circumstances) appropriate circumstances)

a.a. Recruitment Plan Recruitment Plan b.b. AdvertisingAdvertisingc.c. SelectionSelectiond.d. Approving the Hire RequestApproving the Hire Requeste.e. Extending Job OfferExtending Job Offer

3.3. Completing Administrative Hiring ProcessesCompleting Administrative Hiring Processesa.a. PI initiates Hire DocumentationPI initiates Hire Documentationb.b. CFA enrolls the final candidate who is an external hire, upon acceptance CFA enrolls the final candidate who is an external hire, upon acceptance

of the job offer, in the first available New Employee Orientation sessionof the job offer, in the first available New Employee Orientation sessionc.c. Upon completion of hire process, OCRO prepares Appointment Letter. If Upon completion of hire process, OCRO prepares Appointment Letter. If

additional information is to be added to the appointment letter, PI/CFA additional information is to be added to the appointment letter, PI/CFA notify the RSCnotify the RSC

Recruitment and Hiring of Research Recruitment and Hiring of Research Employees (cont.)Employees (cont.)

New part-time or temporary positions may be established using New part-time or temporary positions may be established using simplified procedures which do not require a recruitment plan:simplified procedures which do not require a recruitment plan:

Recruitment and Hiring of Regular Part-Time Research Staff (FTE 35% - Recruitment and Hiring of Regular Part-Time Research Staff (FTE 35% - 99%)99%)The recruitment process for regular part-time research positions is The recruitment process for regular part-time research positions is under the PI and Department discretion. Once the candidate is under the PI and Department discretion. Once the candidate is identified, proceed with Completing Administrative Processes (step 3 identified, proceed with Completing Administrative Processes (step 3 of Hiring Full-Time Research Staff)of Hiring Full-Time Research Staff)

Hiring of Temporary Research Staff (less than 35% FTE)Hiring of Temporary Research Staff (less than 35% FTE)Temporary wage employees are limited to 700 hours or less per Temporary wage employees are limited to 700 hours or less per fiscal year. Usually, an appointment for a period of less than six fiscal year. Usually, an appointment for a period of less than six months is done on a wage basis payable bi-weekly. The hiring of months is done on a wage basis payable bi-weekly. The hiring of temporary wage employees does not require recruitment or waiver temporary wage employees does not require recruitment or waiver of recruitment. Wages should be consistent with Research Position of recruitment. Wages should be consistent with Research Position Classification Descriptions and salary ranges (hourly rate is Classification Descriptions and salary ranges (hourly rate is calculated by dividing the annual salary by 2088).calculated by dividing the annual salary by 2088).

Recruitment and Hiring Recruitment and Hiring Special CasesSpecial Cases

Research Faculty – How to Recruit Research FacultyResearch Faculty – How to Recruit Research FacultyResearch Professors are often hired with a waiver of search. To hire a Research Professor when a 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 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 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 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 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 CV should be attached. Additional information may be required at the discretion of the relevant Dean or in the Medical Center.or in the Medical Center.

Special Hiring CasesSpecial Hiring Cases1.1. Foreign Nationals – Hiring is similar to the process above, but the appointment letter reflects the Foreign Nationals – Hiring is similar to the process above, but the appointment letter reflects the

need for acquiring the appropriate visa to be eligible to work in the US. The International Services need for acquiring the appropriate visa to be eligible to work in the US. The International Services Office (ISO) is available to consult on issues associated with hiring foreign nationals. Plan in Office (ISO) is available to consult on issues associated with hiring foreign nationals. Plan in advance. Some federal projects have special terms and conditions on foreign nationals.advance. Some federal projects have special terms and conditions on foreign nationals.

2.2. Visiting Research Scholars – International visiting scholars are typically hired for short periods Visiting Research Scholars – International visiting scholars are typically hired for short periods following part time hiring processes, but with the added requirement for verifying eligibility to work in following part time hiring processes, but with the added requirement for verifying eligibility to work in the US. ISO is available to assist with these as well.the US. ISO is available to assist with these as well.

Human Resources WebsiteHuman Resources WebsiteTo recruit and hire a regular staff position for a research program, go to the Human Resources To recruit and hire a regular staff position for a research program, go to the Human Resources website Guidelines for Recruiting at http://www.gwu.edu/~hrs and follow the links from website Guidelines for Recruiting at http://www.gwu.edu/~hrs and follow the links from Staffing and Staffing and CompensationCompensation to to Recruitment Process for Staff PositionsRecruitment Process for Staff Positions. Where the process indicates “Budget . Where the process indicates “Budget Office,” refer to your RSC for review and approval. Office,” refer to your RSC for review and approval.

Change in Status (CIS) formsChange in Status (CIS) forms CIS form must be initiated in order to transfer project personnel to/from sponsored CIS form must be initiated in order to transfer project personnel to/from sponsored

programs, to change the allocation of personnel effort and to request other changes of programs, to change the allocation of personnel effort and to request other changes of employee status: change FTE, LOA, reclassification, etcemployee status: change FTE, LOA, reclassification, etc

Proper processing of CIS forms is essential in order to ensure that the University is Proper processing of CIS forms is essential in order to ensure that the University is correctly recording and charging labor on sponsored programs and for Effort Reporting correctly recording and charging labor on sponsored programs and for Effort Reporting purposes in accordance with the University’s Effort Reporting Policypurposes in accordance with the University’s Effort Reporting Policy

GW is partially implementing the CIS process on an electronic basis. This electronic GW is partially implementing the CIS process on an electronic basis. This electronic processing is currently limited to a program for CIS forms involving Terminationsprocessing is currently limited to a program for CIS forms involving Terminations

Terminations should be processed electronically in advance of the effective date of Terminations should be processed electronically in advance of the effective date of termination. To avoid any overpayments PI should notify CFA and RSC on termination termination. To avoid any overpayments PI should notify CFA and RSC on termination actions as soon as PI has made determination on terminationactions as soon as PI has made determination on termination

Payroll processing dates are very important to keep in mind for successful outcomes of Payroll processing dates are very important to keep in mind for successful outcomes of data entry for Hire forms and CIS forms. data entry for Hire forms and CIS forms.

There will be instances in which circumstances prevent the processing of CIS forms There will be instances in which circumstances prevent the processing of CIS forms according to established guidelines. In these cases, the initiator should contact either the according to established 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 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 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 processing of these forms so that sponsored research personnel can be paid correctly and in a timely manner as soon as possible.and in a timely manner as soon as possible.

Recruitment and Hiring Recruitment and Hiring QuestionsQuestions

Equal Employment Opportunity /Affirmative Action Statement Policy information can be Equal Employment Opportunity /Affirmative Action Statement Policy information can be found at http://my.gwu.edu/files/policies/EqualEmploymenOpportunityStatement.pdf; on found at http://my.gwu.edu/files/policies/EqualEmploymenOpportunityStatement.pdf; on the Equal Employment Opportunity Office website http://www.gwu.edu/~eeo, or by the Equal Employment Opportunity Office website http://www.gwu.edu/~eeo, or by contacting the EEO Office at 4-9656. contacting the EEO Office at 4-9656.

For research staff, employment is "at will" similar to other regular staff, i.e., employees For research staff, employment is "at will" similar to other regular staff, i.e., employees may be terminated at any time for performance issues or other reasons even if program 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 funding is otherwise available, in addition to termination due to program changes or lack of funding.of funding.

For additional information about recruitment and employment related policies and For additional information about recruitment and employment related policies and guidelines, including information on employee salary, merit increases, benefits, guidelines, including information on employee salary, merit increases, benefits, employment, disciplinary action and terminations, please see:employment, disciplinary action and terminations, please see:– Faculty Code and Faculty Handbook Faculty Code and Faculty Handbook

http://www.gwu.edu/~academic/Resources/main.htmhttp://www.gwu.edu/~academic/Resources/main.htm– Online Guide for Supervisors http://www.gwu.edu/~hrs/manual/Online Guide for Supervisors http://www.gwu.edu/~hrs/manual/– Employee Handbook http://www.gwu.edu/~hrs/handbook/contents.htmlEmployee Handbook http://www.gwu.edu/~hrs/handbook/contents.html– Office of Human Resource Services website http://www.gwu.edu/~hrs. Office of Human Resource Services website http://www.gwu.edu/~hrs. – Other University employment-related policies may be found in the University’s Other University employment-related policies may be found in the University’s

Policies, Section III, Human Resources, http://my.gwu.edu/mod/upolicy/index.cfm?Policies, Section III, Human Resources, http://my.gwu.edu/mod/upolicy/index.cfm?thisTab=2&indsho=0,95,114. thisTab=2&indsho=0,95,114.

– You may also contact HRS at (202) 994-9610. You may also contact HRS at (202) 994-9610.

Award Close-out Award Close-out

90 Days Prior to Award End Date90 Days Prior to Award End Date The award close-out process begins 90 days prior to the award end The award close-out process begins 90 days prior to the award end

datedate PI receives automatic system alert via e-mail; RSC forwards copy of PI receives automatic system alert via e-mail; RSC forwards copy of

the alert to CFA the alert to CFA PI receives 90-day review from GCAS RAPI receives 90-day review from GCAS RA PI/CFA runs Budget Performance Detail Report (GM139) PI/CFA runs Budget Performance Detail Report (GM139) Review expenditures and any encumbrancesReview expenditures and any encumbrances Bring any discrepancies to RSC’s attention including any other Bring any discrepancies to RSC’s attention including any other

comments on CGAS 90-day reviewcomments on CGAS 90-day review Ensure that all contractual agreements are fully executed, funds are Ensure that all contractual agreements are fully executed, funds are

encumbered and contractors/subrecipients are notified for deadlines encumbered and contractors/subrecipients are notified for deadlines on reports and final invoice submissionon reports and final invoice submission

Initiate actions needed for resolving identified discrepancies: process Initiate actions needed for resolving identified discrepancies: process any outstanding orders, personnel actions, and direct payments.any outstanding orders, personnel actions, and direct payments.

PI and CFA should review suspense and funds check failure reports PI and CFA should review suspense and funds check failure reports and take corrective actions to clear all itemsand take corrective actions to clear all items

Consider requesting a no-cost extension, if appropriateConsider requesting a no-cost extension, if appropriate

Award Close-out (cont.)Award Close-out (cont.)

60- and 30- Days Prior to Award End Date60- and 30- Days Prior to Award End Date

Continue to identify and process actions needed Continue to identify and process actions needed for resolving identified discrepancies: process any for resolving identified discrepancies: process any outstanding orders, personnel actions, and direct outstanding orders, personnel actions, and direct payments with special emphasis on items in payments with special emphasis on items in suspense and funds check failuresuspense and funds check failure

At the 30-day notice verify that all corrective At the 30-day notice verify that all corrective actions submitted have been processedactions submitted have been processed

Ensure that all contractual agreements are Ensure that all contractual agreements are encumberedencumbered

Award Close-out (cont.)Award Close-out (cont.) Award End DateAward End Date

PI receives “award ended today” automatic system alert via PI receives “award ended today” automatic system alert via e-mail; RSC forwards copy of the alert to CFAe-mail; RSC forwards copy of the alert to CFA

PI/CFA run Budget Performance Detail Report (GM139) PI/CFA run Budget Performance Detail Report (GM139) and perform final verification of expenditures and any and perform final verification of expenditures and any encumbrancesencumbrances

Ensure that all invoices for outstanding obligation and Ensure that all invoices for outstanding obligation and reimbursement requests are processed including final reimbursement requests are processed including final invoices for contractual agreementsinvoices for contractual agreements

Liquidated any encumbrances as neededLiquidated any encumbrances as needed

Notify GCAS of any remaining issues that must be resolved Notify GCAS of any remaining issues that must be resolved prior to the preparation of the final financial reportprior to the preparation of the final financial report

Award Close-out (cont.)Award Close-out (cont.)30-, 60-, 90-day After 30-, 60-, 90-day After Award End DateAward End Date

30-, 60-, 90-day close-out as applicable based on the 30-, 60-, 90-day close-out as applicable based on the period allowed for submission of final financial report (close period allowed for submission of final financial report (close date)date)

Verify that there are no outstanding issues and all Verify that there are no outstanding issues and all corrective actions previously submitted have been corrective actions previously submitted have been processedprocessed

Review draft financial reports prepared by GCAS and Review draft financial reports prepared by GCAS and respond within 5 working daysrespond within 5 working days

For fixed-price awards with residual funds, PI signs the For fixed-price awards with residual funds, PI signs the certification and forwards to OCROcertification and forwards to OCRO

GCAS submits the final financial report to the sponsor with GCAS submits the final financial report to the sponsor with copies to the PIs and RSCscopies to the PIs and RSCs

No Cost ExtensionNo Cost Extension

No Cost Extensions (NCEs) should be requested only if there is should be requested only if there is need for additional time to complete the SOWneed for additional time to complete the SOW

Processing NCE NCE varies depending upon whether a formal modification to the grant or contract is required

A. Informal (i.e., approved by email)1. In the event the NCE has already been requested by the PI, the RSC

shall obtain a copy of such correspondence together with any reply received from the sponsor.

2. Once the RSC receives an approval from the sponsor, the revised End Date/Close Date established pursuant to the approved NCE is entered in the EAS system to extend the period of the award and any applicable cost sharing awards associated with that award.

B. Formal NCEs: When the sponsor requires formal signatures or modification of the award to approve the NCE request

1. PI initiates NCE request per award terms and conditions2. The NCE shall be forwarded to the RSC for review and forward the

OCRO Managing Director for signature