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.
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.
Definition: 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.
If the agency requires the submission of a revised work plan or budget, this must be prepared by the PI/PD with the assistance of 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 and procedures to use.
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.
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 Financial Services to coordinate reimbursements to the sub-recipient institution.
A sub-award, also referred to as a sub-contract, is an award issued under a prime 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 prime sponsored research award and the normal purchasing requirements of GC.
There are two basic types of sub-award arrangements:
- When GC is the recipient of a sub-award
- When GC is the grantor of a sub-award
When GC is the recipient: This agreement ties GC to a larger proposal (prime award) 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 sub-awarded to GC to complete specific tasks as part of the larger proposal. When GC is part of a larger project, the management of funds is treated as a 'stand alone' project, for financial management purposes. While the PI/PD and GC may have specific technical and financial reports to submit to the larger project, internally the project is viewed financially as an independent project. Sub-awards to GC 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 federal, Board of Regents, and GC policies. All sub-award agreements processed must be signed by the institutional authorizing official. Faculty are not authorized to sign grants, contracts, or other agreements on behalf of GC.
When GC is the grantor: Work to be completed under the auspices of a GC sponsored research award is contracted out to a third party. When GC awards a portion of a sponsored research award to a third party, the third party is brought into the project because resources or skills for completing specific tasks are not readily available at GC. The intended use of the third party will be articulated in the approved proposal. Adding 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 GC. 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 GC PI/PD, and financial reports to OGSP.
Each Notice of Award should be reviewed for sub-awards by the PI/PD and OGSP. If there is a sub-award present in the sponsor's notice of award the GCA, 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. Appropriate documentation will be saved electronically as evidence for the file.
- GCA reviews proposal for new/existing sub-awards
- Not in original proposal – prior approval will be needed (agency specific)
- GCA checks the following debarred and suspended websites and print evidence for the file:
- GCA 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/PD assistance needed) and attach the scope of work and approved budget
- GCA enters sub-award recipient/agreement into e-Pro to receive Purchase Order (PO) number to reference in agreement
- Request that vendor copy be sent to GCA
- 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/PD including a copy of the PO that was issued
Payments Under Sub-Awards
- Sub-Awardee should invoice GC for reimbursement at least quarterly, but not more than monthly
- Invoices should be sent the OGSP
- GCA will review invoice for compliance with award terms and conditions and forward to PI/PD (stamps invoice)
- PI/PD 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.
The GCA assigned to the project will review all expenditure requests to help ensure allowable purchases are reasonable, allowable, and cost-allocable 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 OGSP by the project director and/or staff. Purchasing and financial services will not process the requests without approval from OGSP staff. For any contracted services, the GCA 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. Appropriate documentation will be printed or save electronically as evidence for the file.
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.
Sponsored program expenditures must adhere to the following general guidelines (see 2 C.F.R. § 200.403 for additional information):
- Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles.
- Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items.
- Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity.
- Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost.
- Costs must adhere to guidance found in Uniform Guidance sections 2 CFR 200.420-.475, and/or sponsor-stated restrictions, while recognizing and respecting any restrictions on use of funds stipulated by the sponsor.
- Be in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part.
- Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period.
- Be adequately documented.
- Be net of applicable credits.
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 Grant and Contract Administrator to discuss the reasons and arrange for prior approval.
During the academic year, the external funding could result in faculty/staff salary savings for the home department. The faculty may choose to use the salary savings to underwrite course buyout(s) where available or to re-budget in support of allowable expenses for the faculty/staff, i.e., travel, supplies, and/or minor equipment. Both of these options must receive written approval of the department chair at time of application.
To protect the PI/PD and the university, expenditures cannot be incurred against a sponsored project until OGSP has received and processed the original award notification from the sponsor, received a fully executed agreement, and a project account number has been assigned. In certain circumstances and when allowed by the sponsor, an advance account can be established.
If compliance issues (human subjects, animal use, biohazards, or radiation) are involved, OGSP will not request an account until the appropriate institutional review board or safety official has reviewed and approved the necessary protocols.
Outlined below are links to the appropriate information.
Human Subjects: Institutional Review Board
Animal Subjects: Institutional Animal Care and Use Committee
For compliance information on hazardous materials, radiation, and recombinant DNA, please contact the GC Department of Environmental Health and Occupational Safety.
When grant funds are received by the university, they are receipted into Banner, and then interfaced to the PeopleSoft financial system.
If funds are received in the form of a check, the transmittal indicates the following:
- Date check received
- Date of check
- Check number
- Amount of check
- Signature of CAO
If funds are received electronically, the transmittal indicates the following:
- Date ACH received
- Copy of bank activity
- Amount of ACH
- Signature of CAO
Most grants require financial reporting. Reports are completed and submitted according to the grant terms and conditions.
GC has a multi-year Facilities and Administration (indirect cost) rate agreement with the federal government. The agreement, dated September 24, 2014, 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 32% of MTDC (modified total direct costs) and the off-campus rate is 13.6% of MDTC.
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.
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 by the project end date. 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 obtain additional sponsor permission. For these grants, PIs should complete the appropriate sections of the GC Prior Approval Form, obtain the appropriate signatures, and submit the request to the OGSP Grant and Contract Administrator.
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 GC 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 and submitted 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.
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
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.
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.
All employees who contribute effort to a grant are required to complete a Personnel Effort Report (PER), an after the fact effort certification, three times per year. To confirm the distribution of activity represents a reasonable estimate of the work performed by the employee during the period, each certification must be reviewed for accuracy and approved by the employee or by a responsible official having first-hand knowledge of the work performed. If someone other than the employee is certifying effort worked, documentation must be retained in accordance with OMB Uniform Guidance, University, and Board of Regents policies and procedures. OGSP reviews completed PERs for compliance with the effort commitments in the funded proposal and to ensure salary paid from sponsored funds does not exceed committed effort.
§200.80 Program Income (2 CFR 200)
Program income means gross income earned by the non-Federal entity that is directly generated by a supported activity or earned as a result of the Federal award during the period of performance except as provided in §200.307 paragraph (f). Program income includes but is not limited to income from fees for services performed, the use or rental or real or personal property acquired under Federal awards, the sale of commodities or items fabricated under a Federal award, license fees and royalties on patents and copyrights, and principal and interest on loans made with Federal award funds. Interest earned on advances of Federal funds is not program income. Except as otherwise provided in Federal statutes, regulations, or the terms and conditions of the Federal award, program income does not include rebates, credits, discounts, and interest earned on any of them. In addition, each federal agency has its own regulations that are listed in the CFR and explained in its policy handbook, if available.
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.
Georgia College requires PIs 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 OGSP for deposit into the appropriate account. This procedure addresses 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.
Identify sources of actual and potential program income at the proposal stage and mark 'yes' to the program income question on the GSCU 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.
For all sponsored projects, PI/PDs must notify OGSP 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 OGSP a copy of the report. Please Note: GC considers timely reporting essential to the proper stewardship of sponsored funds. Therefore, OGSP, 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.
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.
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 OGSP for inclusion in record retention.
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.
Transfer from another institution: A faculty member coming to GC from another institution may have a sponsored project which s/he 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 (based on awarding agency procedures) with new budgetary information must be processed at GC through the normal routing and approval cycle. (http://info.gcsu.edu/4dLink/4DCGI/GrantProposal/approvalquestion.html)