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OGSP Procedures

 

Acceptance of Funds

Award Management

Award Management Meeting

Award Negotiation

Budget Amendment or Rebudgeting

Change of PI/PD

Establishing Subawards

Expenditure Review and Approval

GC Grant Account Establishment

Indirect Costs (Facilities and Administration Costs)

No-Cost Extensions

Notification of Award

Off-Campus Designation

Program Income

Programmatic Compliance/Technical Reports

Record Retention

Signatory Authority

Terms and Conditions of the Award

Transfer of Contract or Grant

 

Acceptance of Funds               

Only GC’s authorizing officials, the President or the Provost, can formally accept a grant or sponsored project.  Award notices from federal agencies are usually directed to the authorizing official, with a copy to the PI.  With the exception of the President or her designee, no one is authorized to accept any funds or sign any contract, thereby legally binding the university to the terms and conditions of the grant or contractual document.   Once OGSP receives and reviews the award document, a routing form will be initiated to circulate the agreement and obtain the appropriate department and college signatures before forwarding the agreement to the authorizing official.

PLEASE NOTE: PI/PD, department chairpersons, and deans are not authorized to sign award documents on behalf of the university. All original official award documents, if received by the PI/PD, should be forwarded immediately to OGSP for processing. OGSP 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.

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 Award Management

Once an award is made to GC, responsibility for the administration of the award rests with several different individuals and offices, including the Principal Investigator/Project Director (PI/PD), Office of Grants and Sponsored Projects, department administrators, the Budget Office, and Financial Services. OGSP provides the post-award functions of award negotiations, award acceptance, obtaining sponsor's prior approval when required, establishing subcontracts, transferring an award to another institution, and assistance with closeout requirements.  Financial Services provides the post-award functions dealing with all financial aspects of the award from establishing accounts and sending invoices to processing draw-downs, collecting receivables, completing financial reports, and tracking cost share and effort reporting.

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Award Management Meeting          

Upon receipt of notification and acceptance of awards, an award management checklist will be completed by OGSP and, when warranted, an award management meeting will be held between representatives of the PI, OGSP, Budget, and Financial Services. The focus of the meeting will be to interpret the terms and conditions of the funded award. The session will be conducted by OGSP at a time mutually convenient for the PI and post-award staff.  The extent of the agenda will depend on the type and size of the award, and will provide the following information:
  • Approved budget items
  • Assistance with budget amendment
  • Fiscal accountability and compliance
  • Required technical reporting, including contractually required reporting schedules
  • Procurement requirements, regulations and procedures.


Upon completion of the award management meeting, minutes from the session will be distributed and each attendee will be requested to sign-off on the minutes and acknowledge their understanding of the compliance issues relevant to the award.

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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. OGSP, working with Legal Affairs, is the authorized agent for negotiating such revisions.  If revisions are necessary, OGSP will not make any changes to the project or scope without the consent of the PI/PD.  The acceptance of a revised scope of work, period of performance or budget is a judgment that only the PI/PD 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 with assistance from OGSP and submitted for institutional endorsement prior to forwarding the revisions to the agency.  Revisions, either programmatic or budgetary, which represent substantial changes to the original proposal must be reviewed and approved by OGSP and GC administration in the same manner as a new proposal.

If the grant agency contacts the PI/PD about revisions, please contact OGSP for guidance and the appropriate documents to use.

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Budget Amendment or Rebudgeting   

Re-budgeting within budget line items is usually permitted by most agencies; however, some 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 OGSP. However, many awards allow these changes to occur at the discretion of the PI and institution. In these cases, the re-budgeting section of the GC Prior Approval Form must be completed and sent to OGSP for approval and then shared with Financial Services staff. This form should be completed when any re-budgeting is needed. If re-budgeting affects less than 25% of the award budget, then prior agency approval is not needed on federal grants. All other funding sources will be reviewed based on award terms and conditions.

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 OGSP and the sponsoring agency for clarification and direction.

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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 Provost). A request to a sponsoring agency for designation of a new PI/PD will normally state the reasons for the change and will include the curriculum vitae of the PI/PD-designate. Such requests must be submitted to OGSP for institutional endorsement before forwarding to the sponsor.

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Establishing Subawards

OGSP staff will help facilitate sub-award agreements by assisting with document preparation and forwarding them to the sub-awardee for all the sub-awards indicated in the approved award budget when an award is initially set-up.  If additional sub-awards become necessary, the PI/PD should notify OGSP immediately.  

Once a portion of the prime award is sub-awarded to a sub-recipient, there are substantial post-award issues with which the PI/PD and university are responsible for complying.  Sub-recipient monitoring requires the PI/PD be in frequent contact with the sub-recipient.  The PI/PD is responsible for ensuring the necessary deliverables are met and working with the financial office to coordinate reimbursements to the sub-recipient institution.

A sub-award, also referred to as a sub-contract, is an award issued under a larger sponsored research award for the procurement of specific services or program-related tasks.  Issuance of a sub-award under a federal prime award is subject to compliance with federal law.  All sub-awards are subject to the terms and conditions of the larger sponsored research award and the normal purchasing requirements of Georgia College.

There are two basic types of sub-award arrangements:

  • When Georgia College is the recipient of a sub-award
  • When Georgia College is the grantor of a sub-award

When Georgia College is the recipient: This agreement ties Georgia College to a larger proposal submitted by another institution or group of institutions.  The prime award is made to another institution or group of institutions, then a portion of it is distributed to Georgia College to complete specific tasks as part of the larger proposal.  When Georgia College is part of a larger project, the management of funds is treated as a 'stand alone' project, for financial management purposes.  While the Principal Investigator and Georgia College may have specific technical and financial reports to submit to the larger project, internally the project is viewed financially as an independent project.  Facilities and Administration Cost rates are calculated on the percentage negotiated between Georgia College and the Federal government, not the hosting institution's rate.  Sub-awards to Georgia College are subject to the same internal review process as standard grant and contract proposal submissions.  These agreements must be processed through OGSP, which is the only office authorized to negotiate contractual agreements for compliance with agency, Regents, and Georgia College policies.  All sub-award agreements processed through OGSP are signed by the institutional official.  Faculty are not authorized to sign grants, contracts, or other agreements on behalf of Georgia College.

When Georgia College is the grantor: Work to be completed under the auspices of a Georgia College sponsored research award is contracted out to a third party.  Georgia College awards a portion of a sponsored research award to a third party.  Usually, this third party is brought into the project because resources or skills for completing specific tasks are not readily available at the College.  The intended use of the third party will be articulated in the approved proposal.  Attempts to add new sub-awards to an existing project must have prior approval by the sponsor.  All questions concerning sub-awards should be referred to staff in the OGSP.  Once the proposal is awarded, staff in the OGSP will prepare a sub-award agreement, reflecting the specifics of the proposal (budget, scope of work, etc.), the appropriate sponsor's terms and conditions and the policies and procedures of Georgia College.  Because sub-award agreements are written to assign a portion of the programmatic effort to another organization, they are responsible for managing the technical and administrative aspects of its scope or work and making progress reports to the Georgia College Principal Investigator or Project Director, and financial reports to OGSP.

After an award has been made to Georgia College, it may become necessary to issue a sub-award not outlined in the originally funded proposal.  The Principal Investigator must prepare in written letter to the sponsor that addresses the reasons for selecting a particular sub-award to complete the work.  This letter must be reviewed and signed by the director of grants and sponsored projects, before being forwarded to the sponsor.

Each Notice of Award should be reviewed for sub-awards by the Principal Investigator and the Grants Compliance Manager.  If there is a sub-award present in the sponsor's notice of award the Grants Compliance Manger, with assistance from the Principal Investigator, is responsible for checking all debarred and suspended list to confirm that the sub-award recipient is eligible to receive federal funding, requesting a copy of the most recent financial audit for appropriate, preparing the sub-award agreement and appropriate attachments.

Quick Reference:

  • Grants Compliance Manager reviews proposal for new/existing sub-awards
  • Not in original proposal – prior approval will be needed (agency specific)
  • Grants Compliance Manager checks the following debarred and suspended websites:
  • Grants Compliance Manager will request a copy of the most recently completed financial audit (A-133 if applicable)
  • Prepare sub-award agreement in accordance with Award Terms and Conditions (PI assistance needed)
  • Attach scope of work and budget
  • Grants Compliance Manager enters sub-award recipient/agreement into e-Pro to receive PO number to reference in agreement
    • Request that vendor copy be sent to Grants Compliance Manager
    • Once PO number is assigned – reference in agreement
    • Send agreement to sub-awardee for signatures
    • Set reminder to check status of securing signatures 
    • Send copy of fully executed agreement to Accounting (Susan Demmon) – make sure to reference Requisition and PO numbers at the top of the agreement
    • Send copy fully executed agreement to the sub-recipient and PI including a copy of the PO that was issued

Payments Under Sub-Awards

  • Sub-Awardee should invoice Georgia College for reimbursement monthly (at least)
  • Invoices should be sent the Office of Grants and Sponsored Projects
    • Grants Compliance Manager will review invoice for compliance with award terms and conditions and forward to PI (stamps invoice)
PI will review for appropriate costs and approve for payment if the charges are reasonable and consistent with progress on the project (signs invoice for payment) and forwards to Accounting Office for processing

  

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Expenditure Review and Approval

Georgia College & State University agrees to abide by the terms and conditions of an award upon acceptance of the grant.  It is the responsibility of the Grants Compliance Manager to ensure the policies of the university as well as the regulations of the sponsor are followed.  All expenditures must be monitored to ensure compliance with such policies.

The Office of Grants and Sponsored Projects will review all expenditure requests to help ensure allowable purchases are reasonable and cost-allocatable to the objectives of the project.  All expenditure requests including e-procurement requests, operational expenses, travel reimbursements, and consultant contracts on sponsored projects must be forwarded to the Office of Sponsored Projects by the project director and/or staff.  For any contracted services, OGSP will review the current state and federal clearinghouses to verify the vendor is not suspended or debarred from doing business with the state or federal government.

Office of Research Integrity
Office of Inspector General
FDA
Georgia

Note:  In order for all e-procurement purchases to be reviewed and approved against the award budget and applicable terms and conditions, the Grants Compliance Manager is the signatory authority in PeopleSoft on each grant account.  Since the system will only allow one person to have signatory authority, the project director will need to be added as an ad-hoc approver by the requestor before the requisition is submitted for approval.

The project director is responsible for generating the monthly expenditure sheets from PeopleSoft, reflecting monthly and cumulative expenditures and encumbrances for reconciliation.   The project director is responsible for managing the budget and expending it in accordance with sponsor and university regulations on allowable, allocable, and attributable expenses related to the project, as indicated in the approved budget. The PI/PD must be familiar with and comply with both the sponsor's guidelines and the university guidelines for fiscal management of sponsored programs.

General guidelines for expending sponsored program funds are as follows:

  • Costs must be allocable, bearing a direct relationship to the activities of the program, not to the general needs of the department or university.
  • Costs must be reasonable, reflecting conscientious and prudent financial decision making.
  • Costs must be consistently treated, consistent with the normal costs standards of the university and not exceeding normal limits of similar charges that are not grant supported.
  • Costs must adhere to sponsor-stated restrictions, recognizing and respecting any restrictions on use of funds stipulated by the sponsor.

Please note that all expenditure requests should be made no later than sixty days prior to the project end date.   If expenditures need to occur in the last two months of the award, please confer with the Grants Compliance Manager to discuss the reasons and arrange for prior approval.

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GC Grant Account Establishment          

Establishing an account for an award involves both the Office of Grants and Sponsored Projects and Financial Services. Upon receipt of an official award, OGSP staff will prepare a sponsored project fact sheet (SPFS), an internal form used to communicate essential award and budget details necessary for an account and send a memo requesting a project account number from Financial Services.  Copies will be distributed to the PI/PD, department chair, dean, and other administrative offices. These documents will outline any pertinent award information, including 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 OGSP 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, OGSP will not request an account until the appropriate review board or safety official has reviewed and approved the protocol.
Outlined below are several compliance issues and links to the appropriate information.

  • Human Subjects
Institutional Review Board
  • Animal Subjects
Institutional Animal Care and Use Committee
  • Conflict of Interest
Conflict of Interest Policy
  Conflict of Interest - Disclosure

For compliance information on hazardous materials, radiation, and recombinant DNA, please contact the GC Department of Environmental Health and Occupational Safety.

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Indirect Costs (Facilities and Administration Costs)

Indirect costs are the real costs of university operations which are not readily assignable to a particular project.  These indirect costs are determined by federal auditors under the guidelines of OMB Circular A-21.  Indirect cost rates are negotiated with the Department of Health and Human Services (DHHS)—the cognizant federal audit agency overseeing the administration of sponsored agreements at GC.  These rates are applicable to all federally sponsored projects and, in accordance with university protocol, are also extended to include all other sponsored activities.

GC has a multi-year Facilities and Administration (indirect cost) rate agreement with the federal government. The agreement, dated April 16, 2008, specifies the F&A rates to be applied to awards from federal and non-federal sponsors.   Under the agreement, the rate for on-campus sponsored projects is 29% of MTDC (modified total direct costs) and the off-campus rate is 13.6% of MDTC.

Off-Campus Designation
The actual rate agreement with DHHS simply states:  For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s), the off-campus rate will apply.  If more than 50% of the project is performed off-campus, the off-campus rate will apply to the entire project.

Reductions in the GC indirect cost rate are considered on a case-by-case basis and require appropriate justification from the PI/PD.  This justification must be approved by the Chair and Dean prior to submission for approval of the Provost.

 

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No-Cost Extensions 

A no-cost time extension is a contractual action to extend the time authorized to complete a project without an increase in sponsor funding.

In general, sponsors view a no-cost extension as an admission of either poor planning, such as proposing or agreeing to an unrealistic schedule during contract negotiations, or poor performance in not completing the deliverable within the agreed time. However, when additional time is required, it is better to request a no-cost time extension than to simply be late in completing the project. Requests for a no-cost extension should be submitted as soon as it becomes apparent that the project will not be completed on time. The sponsor may not approve requests that are not submitted in a timely manner or those that have not been adequately justified.

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-cost 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 Institutional Prior Approval Form, obtain the appropriate signatures, and submit the request to the OGSP grants compliance manager.

For those grants that require agency approval, a PI should prepare a separate written request and include a justification for the extension that relates to the completion of the objectives of the award.  (Having money remaining in the grant account does not justify an extension.) These requests must be routed to OGSP using the Institutional Prior Approval Form. Please note that requests to agencies generally take one or two months to process and approve. Therefore, 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 OGSP 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.  All extension requests should be reviewed by the Office of Grants and Sponsored Projects.

The National Science Foundation requires that grantee requests for first-time, no-cost extensions be submitted via Fastlane.  The PI/PD (grantee) may exercise a one-time extension of the expiration date of the grant of up to 12 months, if additional time beyond the established expiration date is required to assure completion of the original scope of work within the funds already made available. At least ten (10) days prior to the expiration date specified in a grant, the grantee must submit a request via Fastlane to the NSF Grants Officer. NSF notifies the OGSP upon receipt. This request must give reasons for the extension and revised expiration date to ensure accuracy of NSF's grant data. This one-time extension may not be exercised merely for the purpose of using the un-liquidated balance.

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Notification of Award                  

The award notice is the first step in the post-award grant management process. The award notice sets the parameters under which the project will be conducted.  An award is not official and binding until the terms and conditions are reviewed and accepted by the university’s authorizing official.  A written notification of award or acceptance of offer should be transmitted to the OGSP by the funding agency.  In the event that an award notice and/or awarding document are received by the PI/PD, it should be transmitted to the OGSP immediately.  OGSP staff will coordinate the internal review and acceptance process.

The award notification will set forth all terms and conditions of the grant or contract. The terms and conditions should include the following information:

  • Agency project identification number
  • Award period
  • Award amount
  • Principal investigators
  • Terms of acceptance
  • Other applicable information whether listed or incorporated by reference
  • Authorized signature of the awarding agency


Upon receipt of the award notification, the OGSP will review the award to ensure that it complies with the original proposal. The office will then confer with the PI and other administrators to discuss and resolve any discrepancies. The award letter is the key to starting the process of obtaining a PeopleSoft Account to expend the funds awarded.

OGSP is responsible for notifying the appropriate administrators (provost, college dean, department chair and or supervisor) when a new award is received.  OGSP will also notify University Communication of all new awards and any required publicity statements or restrictions by the terms of the award.

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Off-Campus Designation

The actual rate agreement with DHHS simply states:  For all activities performed in facilities not owned by the institution and to which rent is directly allocated to the project(s), the off-campus rate will apply.  If more than 50% of the project is performed off-campus, the off-campus rate will apply to the entire project.

Reductions in the GC indirect cost rate are considered on a case-by-case basis and require appropriate justification from the PI/PD with support from the department and unit head.

OGSP staff will help facilitate sub-award agreements by assisting with document preparation and forwarding them to the sub-awardee for all the sub-awards indicated in the approved award budget when an award is initially set-up.  If additional sub-awards become necessary, the PI/PD should notify OGSP immediately.  

Once a portion of the prime award is sub-awarded to a sub-recipient, there are substantial post-award issues with which the PI/PD and university are responsible for complying.  Sub-recipient monitoring requires the PI/PD be in frequent contact with the sub-recipient.  The PI/PD is responsible for ensuring the necessary deliverables are met and working with the financial office to coordinate reimbursements to the sub-recipient institution.        

Once an award is made to GC, responsibility for the administration of the award rests with several different individuals and offices, including the Principal Investigator/Project Director (PI/PD), Office of Grants and Sponsored Projects, department administrators, the Budget Office, and Financial Services. OGSP provides the post-award functions of award negotiations, award acceptance, obtaining sponsor's prior approval when required, establishing subcontracts, transferring an award to another institution, and assistance with closeout requirements.  Financial Services provides the post-award functions dealing with the financial aspects of the award from establishing accounts and sending invoices to processing draw-downs, collecting receivables, completing financial reports, and tracking cost share and effort reporting.

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Program Income

 Sponsors provide funding to cover costs of conducting research, training, and public service-related activities. Program income may be generated as a result of these activities and in some cases must be reported to the sponsor. Federal sponsors have documented in OMB Circular A-110 and the applicable Code of Federal Regulations (CFR) explicit processes to be used to identify, record, report, and monitor income that is generated during the project period. To be consistent in managing program income, the Georgia College extends the requirements to non-federal sponsors.

OMB Circular A-110 (Office of Management and Budget Circular A-110, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations) establishes uniform regulations for each federal agency to follow regarding the administration of projects sponsored by the federal government. In addition, each federal agency has its own regulations that are listed in the CFR and explained in its policy handbook, if available.

Program Income is gross income earned by the recipient that is directly generated by a supported activity or earned as a result of the award (OMB Circular A-110). Examples of program income include:

  • income from fees for services performed, such as laboratory tests.
  • money generated from the use, sale, or rental of equipment purchased with project funds.
  • proceeds from the sale of supplies or equipment purchased or fabricated with project funds.
  • proceeds from the sale of software, tapes, or publications.
  • income from the sale of research materials such as animal models.
  • fees from participants at conferences or symposia.
  • sales of products with an accompanying material transfer agreement (MTA).
  • royalties from patents and copyrights (NOTE:  Royalty income from copyrights, while defined as program income, is not reportable unless the terms and conditions of the award indicate otherwise. Royalties resulting from patents are program income but are reported following the University policy on Intellectual Property Policy and Procedures.

Program income does not include:

  • patient care credits.
  • interest earned on advances of federal funds.
  • receipt of principal on loans, credits, discounts, etc. or interest earned on them.
  • taxes, special assessments, levies, and fines raised by government recipients.

Sponsored Project is an externally funded activity that is governed by specific terms and conditions. Sponsored projects must be separately budgeted and accounted for subject to terms of the sponsoring organization. Sponsored projects may include grants, contracts, and cooperative agreements for research, training, and other public service activities.

 The Georgia College requires Principal Investigators (PI) to identify and document program income on projects from both federal and non-federal sponsors. The nature of this income must be appropriately documented and the resulting revenue properly recorded. This income must be sent to the Office of Grants & Sponsored Projects (OGSP) for deposit into the appropriate account. This policy and its procedures address the definition, management, reporting, and monitoring of program income, in accordance with federal and University requirements.   Excluded from program income reporting requirements are:

  • revenue generated through programs funded by sources other than sponsored projects, royalty income resulting from copyrights unless addressed in the award terms, and royalties or license fees for unpatented, but potentially patentable discoveries that are disclosed to the Office of General Counsel.
  • income received on non-federal awards that are silent on program income.

This policy was implemented to comply with sponsor and University policies and to ensure that program income is managed in a manner consistent with the University's overall missions and goals.

Responsibilities

Principal Investigator
Identify sources of actual and potential program income at the proposal stage and mark 'yes' to the program income question on the GC Grant Approval and Budget Summary Form. Complete required program income sections in application. Determine whether it is reportable to the sponsor and seek advice, if necessary, from the Office of Grants and Sponsored Projects.  Prepare plan for using program income. Provide information regarding budget categories for program income account establishment. Verify program income on reports. At final project termination, address account balance issues.

Office of Grants & Sponsored Projects
Review proposal and GC Grant Approval and Budget Summary Form for anticipated program income, and determine whether it is reportable or non-reportable. Review award terms and conditions from sponsor and develop and action plan in response to program income being 1) deductive, 2) additive, or 3) used as cost share.  Request set up of appropriate restricted program income account.  Monitor levels of program income in account and any limits that are set by the sponsor. Monitor spending to ensure program income is spent first.

Administrative Services and Campus Operations
Set up of appropriate restricted program income account.  Deposit program income checks and prepare necessary budget documents.  Report program income as required by sponsor. At project termination, handle revenue earned after the grant period has ended as a departmental sales and service activity.

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Programmatic Compliance/Technical Reports    

The Principal Investigator is responsible for preparing and submitting all technical/programmatic reports and invention disclosures required by the sponsor. This is an important obligation. Failing to turn in reports in a timely fashion can result in the agency’s delaying or suspending final payments on the grant or contract. It can also jeopardize possible future funding from the agency, not just for the PI involved, but for other GC researchers as well.

For all sponsored projects, PIs must notify the Office of Grants and Sponsored Projects when a technical /programmatic report is sent to the sponsor. This may be accomplished by sending the OGSP a copy of the report.  For all other reports required by the sponsor (except for fiscal/ financial reports), Principal Investigators should send the Office of Grants and Sponsored Projects a copy of the report.  Please Note:  GC considers timely reporting essential to the proper stewardship of sponsored funds. Therefore, the Office of Grants and Sponsored Projects, upon consultation with the appropriate department chair, dean and vice president, may withhold sign-off on any new proposals for faculty who are seriously delinquent in their technical reporting responsibilities.

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Record Retention                    

Retention of all financial and programmatic records, supporting documents, statistical records, and other records of the university is an integral responsibility of grants management.  Grant-related records are required to be kept for specific periods after completion of grant projects.  Record retention requirements can differ by sponsor and by the type of award agreement (grant, cooperative agreement, or contract).

Based on University System of Georgia retention requirements, which are more stringent than Federal regulations, all grant-related records should be kept for a period of seven (7) years from the project’s end date, unless the grant agency requires records be kept for a longer period.

The Office of Grants and Sponsored Projects (OGSP) is the official repository for GC grant-related records.

Grant project directors and Financial Services are responsible for ensuring that copies of technical or program reports are forwarded to the OGSP for inclusion in the official file.

The university is responsible for maintaining the fiscal records for each grant account.  While grant accounts are active, the fiscal records will be maintained by the Office of Financial Services.  Once grant funding ends and final reports are filed, all financial records will be transitioned to the Office of Grants and Sponsored Projects for inclusion in record retention.

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Signatory Authority

A Principal Investigator (PI), Department Head, faculty, or staff of the University should never sign a sponsored project proposal, grant or contract on behalf of Georgia College & State University.  The authority to sign these documents rests with the institution’s authorized official:  the President and those to whom the authority has been delegated.  This procedure does not preclude PIs, Department Heads, and other individuals from signing internal processing documents or the proposal or award if required by the funding agency; however, the proposal or award document must also contain the signature of the authorized official.  All sponsored project documents, including but not limited to proposals, grants, and contracts, requiring the signature of authorized official must be processed through the Office of Grants and Sponsored Projects.

For an agreement to have validity and enforceability, it must be signed by a person with specific statutory delegation to sign on behalf of the university.  As described above, for research grants, contracts, agreements, and proposals, this authority resides with the authorized official. Therefore, if a sponsored program proposal or award is NOT signed by the authorized official, the agreement is void and unenforceable.

Key reasons behind proper signatory authority include: 

  • protecting University and individual university employees from legal liabilities, and
  • maintaining compliance with university, system, state, federal, and private regulations and requirements while performing research and services inherent in sponsored programs.

 

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Terms and Conditions of the Award

Awards come with terms and conditions which frequently accompany 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. re-budgeting, no-cost extensions, carrying funds from one year to the next) and reporting requirements and procedures during the award period. OGSP and Financial Services staff can assist the PI in determining the terms and conditions of their particular award.

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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 OGSP which will then follow agency procedures to relinquish the award.

Transfer from another institution: A faculty member coming to GC from another institution 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.  Prior to submission to the sponsoring agency, a new proposal (or the revised original) with new budgetary information must be processed at GC through the normal routing and approval cycle by using the Approval and Budget Summary Form.

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