OGSP Procedures

Only GCSU’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 Principal Investigator/Project Director (PI/PD).  With the exception of the President or their 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 an award notice is received, OGSP will coordinate the acceptance and signature process. 

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.

Once an award is made to Georgia College & State University, 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.

Upon receipt of notification and acceptance of awards, an award management checklist will be completed by OGSP and 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 convey the terms and conditions of the funded award. The session will be conducted by OGSP and the extent of the agenda will depend on the type and size of the award. The following information will be covered:

• Approved budget items
• Assistance with budget amendment
• Fiscal accountability and compliance
• Required technical reporting, including contractually required reporting schedules
• Procurement requirements, regulations and procedures.

OGSP will review the Award Setup Checklist with the project director, provide additional supporting documents, and answer questions to assist with award management.

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 the award terms and conditions of their project. For example, 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. OGSP and Financial Services staff can assist the PI in determining the terms and conditions of their particular award.

In some cases, an award may be issued by the agency after a series of negotiations that could 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 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 GCSU 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.

Re-budgeting within budget line items is usually permitted by most agencies; however, some agencies have 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. Some may allow these changes to occur at the discretion of the PI/PD and institution. In these cases, the re-budgeting section of the Institutional Prior Approval Form must be completed and sent to the assigned GCA. 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.

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/biosketch of the PI/PD-designated. Such requests must be submitted to OGSP for institutional endorsement before forwarding to the sponsor.

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 GCA-PA and 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 GCSU.

There are two basic types of sub-award arrangements:

• When GCSU is the recipient of a sub-award
• When GCSU is the grantor of a sub-award

When GCSU is the recipient: This agreement ties GCSU 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 GCSU to complete specific tasks as part of the larger proposal.  When GCSU 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 GCSU 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 GCSU 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 GCSU 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 GCSU.

When GCSU is the grantor: Work to be completed under the auspices of a GCSU sponsored research award is contracted out to a third party. When GCSU 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 GCSU.  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 OGSP staff.  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 GCSU.  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 GCSU 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: and preparing the sub-award agreement with appropriate attachments.  Appropriate documentation will be saved electronically as evidence for the file.

Quick Reference:

• 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 prints evidence for the file:
  • SAM:  View SAM Website
  • DHHS: PHS Administrative Action Report
  • Georgia:  Suspended and Debarred Suppliers
• 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
• PI/PD or designee enters sub-award agreement into e-Pro to receive Purchase Order (PO) number
  • Request that vendor copy be sent to GCA​
  • GCA_PA assigns subaward number
  • Send agreement to sub-awardee for signatures​
  • Send copy of fully executed agreement to Accounting Services – make sure to reference 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 GCSU for reimbursement at least quarterly, but not more than monthly
• Invoices should be sent the GCA-PA
  • GCA-PA will review invoice for compliance with award terms and conditions and forward to PI/PD for review and approval (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 Services for processing.

GCSU agrees to abide by the terms and conditions of an award upon acceptance of the grant.  It is the responsibility of the PI/PD and the Grant and Contract Administrator (GCA) 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 GCA assigned to the project will review all expenditure requests to help ensure 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 are routed to the GCA for review prior to expenditure.  Purchasing and financial services will not process the requests without approval from the GCA. 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.

SAM:  View SAM Website
DHHS: PHS Administrative Action Report
Georgia:  Suspended and Debarred Suppliers

The project director is responsible for generating the monthly expenditure reports from PeopleSoft and reviewing expenditures for accuracy.   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.

Allowability of Expenditures

Georgia College follows Federal guidelines determining the allowability of charges to a Federal grant. In accordance with 2 C.F.R. § 200.302 and 2 C.F.R. § 200.403 factors affecting allowability. It is the policy of Georgia College to adhere to all fiscal management compliance requirements set forth by Federal guidelines and funder terms & conditions. All program requisitions and expenses are reviewed and approved by the Program Director and a Grant and Contract Administrator in the Office of Grants and Sponsored Projects in order to assure expenses meet the following criteria.

• Are necessary and reasonable for the performance of the Federal award and be allocable:
  • All requested expenditures must be reviewed and approved by the Program Director and a Grant & Contract Administrator in the Office of Grants and Sponsored Projects to ensure that costs are necessary, reasonable and allowable under the federal award and to meet program goals.
• Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. 
  • The Program Director closely monitors the budget of each award to ensure that costs are within limits and in accordance with the budget awarded.
  • The Director also works with Sponsor’s Fiscal Analyst and the Office of Grants and Sponsored Projects to ensure costs follow guidelines set forth by award terms and conditions.
• Are consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity.
  • Program Director and the Grant and Contract Administrator review all expenses to ensure that costs not only adhere to Federal guidelines but also adhere to non-federal such as State, Local, or institutional policies.  Sometimes State or institutional policies may be more restrictive and must be followed.
• Are accorded consistent treatment.
  • A cost may not be assigned to a direct cost if any other cost incurred for the same purposes in like circumstances has been allocated to the Federal award as an indirect cost.
  • All costs are reviewed before reimbursement is requested to ensure that the costs are consistent from month to month and are being charged appropriately and consistently across all awards.
• Are in accordance with generally accepted accounting principles (GAAP).
  • Georgia College is required to use GAAP and our financial records are audited annually to ensure adherence.
• Are Not included or used to meet a cost sharing or matching requirement of any other federally-financed program in either the current or a prior period.
  • The Program Director, in conjunction with the Office of Grants and Sponsored Projects, ensures that federal awards are not used as matching/cost share for in other federal or non-federal grant.
  • All matching/cost share reporting is coordinated, reviewed, and submitted by the Office of Grants and Sponsored Projects.
• Are adequately documented.
  • All costs are adequately documented in accordance with Federal Award. Only allowable and approved costs are charged to the award(s) and our General Ledger provides sufficient detail to categories and track all expenditures.
  • The Program Director reviews the General Ledger each month.  If an expense does post in error, a journal entry is initiated to move the expense off the award with appropriate supporting documentation – outlining how it occurred and any system that has be put in place to ensure it does not happen again.
• Are net of applicable credits.
  • All costs charged to any Federal grant will be the net of all applicable credits.  Any credits/refunds will be credited back to the Federal Grant Award.  Credits will be maintained with the original documentation in the Financial Services office and made available to Sponsor as requested.

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.

All faculty/staff are strongly encouraged to pursue outside funding to support their research, creative endeavors, and/or outreach.  In the situation where this funding allows for support of faculty salary, it should be first applied to summer pay, which is limited to the BOR Policy 8.3.12.3 of no more than 33-⅓% of regular academic year salary.  For consistency, and based on federal regulations (200.430(h)(2)), in no event will academic year salary charged to all externally funded awards, irrespective of the basis of computation, exceed the proportionate share of the IBS (institutional base salary) for that period. This principle applies to all members of faculty (12 or 10 month contracts). IBS is defined as the annual compensation paid by an IHE (Institution of Higher Education) for an individual's appointment, whether that individual's time is spent on research, instruction, administration, or other activities.  To reiterate, during regular contract periods, faculty or full-time staff may not receive additional pay above their IBS/annual salary from externally funded sources. 

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. 

NOTE:  Effective 2/1/2022, stipend payments to faculty, for additional work that is performed during the academic year for the University System of Georgia (USG) are exempt from the above policy. Examples: USG Chancellor’s Learning Scholars and HIPs Champions.

It is the Office of Grants & Sponsored Projects (OGSP) ongoing goal to support  research/sponsored activities free of conflict, bias, and foreign influence and to comply with the Georgic College (GCSU) Financial Conflict of Interest Policy. Principal Investigators/Program Directors (PI/PDs) and Senior/Key Personnel must be fully transparent about their personal financial affairs (including those of the Investigator's spouse and dependent children), financial support and resources from and affiliations with international institutions, and ensure this information is updated throughout the life of an award.

To this end, all PI/PDs and Senior/Key Personnel are required to complete a Financial Conflict of Interest (FCOI) Disclosure form.  These forms should be submitted:

• at the time of application
• at the time of award notice and acceptance
• annually each January
• within 30 days of discovering or acquiring a new SFI
• when new investigators are added to ongoing research projects

Training

To assist with the understanding of a conflict of interest, individuals are required to complete the CITI Program training module; Conflicts of Interest once every four years.  A link to the CITI website and instructions to setup a GCSU linked CITI account can be found here.

Financial Conflict of Interest Disclosure Form

Establishing an account for an award involves both the OGSP and Financial Services. Upon receipt of an official award notice and after review of the award terms and conditions, OGSP staff will prepare a sponsored project fact sheet (SPFS), an internal form with award and budget details, and request a project account number from financial services. Copies of the request, SPFS, and award documents will be distributed to the PI/PD, department chair, and other relevant offices. These documents will outline any pertinent award information, including the project period, approved budget, any cost-sharing obligations, and how the university will receive funding (advanced payment, installments based on deliverables, or cost reimbursable).

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
• Conflict of Interest: Conflict of Interest Policy
• Conflict of Interest: Conflict of Interest - Disclosure

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

Grant Accounting is performed by the Director of Accounting Services and the Grant and Contract Administrator for Post-Award (GCA-PA).  Grants are invoiced monthly, quarterly or as established by the individual grant terms and conditions.  PeopleSoft reports and queries are generated to view general ledger activity on each grant.  The reports are reconciled to determine the indirect cost rate, if applicable, and the receivable amount for reimbursement purposes.  Some grants require invoicing, while others may have an electronic funds request system.  All invoices and draw down requests are initiated by the GCA-PA or Bursar. 

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:

1. Date check received
2. Date of check
3. Check number
4. Amount of check
5. Signature of the GCA-PA and/or Bursar                     

If funds are received electronically, the transmittal indicates the following:

1. Date ACH received
2. Copy of bank activity
3. Amount of ACH
4. Signature of  GCA-PA and Bursar

Most grants require financial reporting.  Reports are completed and submitted by the GCA-PA in accordance to the grant terms and conditions .

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 Uniform Guidance (2 CFR 200).  GCSU's 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 GCSU.  These rates are applicable to all federally sponsored projects and, in accordance with university protocol, are also extended to include all other sponsored activities.

GCSU has a multi-year Facilities and Administration (indirect cost) rate agreement with the federal government. The agreement 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 38% of MTDC (modified total direct costs) and the off-campus rate is 16% 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. Also, if more than 50% of the project is performed off-campus, the off-campus rate will apply to the entire project.

Reductions in the GCSU 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 to the Provost for a decision.

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

When additional time is required, it is better to request a NCE than to simply be late in completing the project. Requests for a NCE 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. In general, sponsors view a NCE 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.

A NCE 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 NCE 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 GCSU Prior Approval Form, obtain the appropriate signatures, and submit the request to OGSP at grants@gcsu.edu.

For those grants that require agency approval, a PI should prepare a written justification for the extension that relates to the completion of the project objectives. A request to expend remaining funds is not a valid justification for an extension. NCE requests must be routed to OGSP using the GCSU 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 obtain timely approval from the sponsoring agency. 

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 prior approval is required.  Official extension requests should be reviewed and submitted by OGSP to the sponsoring agency.

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 investigator(s)
• 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 Communications of all new awards and any required publicity statements or restrictions by the terms of the award.

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 GCSU 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 GCSU, 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.

Participant Support Costs (PSC) are stipends, subsistence allowances, travel allowances, and registration fees paid to help defray the costs of personal maintenance while participating in a conference or training activity. Participants may be paid a stipend, per diem, travel expenses, or subsistence allowance, based on the type and duration of the activity, as outlined in the applicable sponsored program announcement and in the grant award notice or terms and conditions. Such allowances must be reasonable and conform to University policies.

A Participant is someone whose function is to learn something. Participants may be students, national scholars and scientists, private sector representatives, teachers, and others who attend and participate in the conference, workshop, or training activity supported by a particular award. Georgia College employees may not receive participant support from a grant [2 CFR 200.75].
Participants perform no work or services for the project or program other than for their own benefit. A participant is not involved in providing any deliverable to the University or a third party.

Participant support costs are only allowed on an award when Participant Support is defined by the sponsor in the Request for Proposal/Funding Announcement, or specifically identified in the award document [2 CFR 200.456]. F&A is not allowed on Participant Support Costs [2 CFR 200.68]. Examples of costs that are typically unallowable as Participant Support are:

• Speaker fees
• Trainer or facilitator fees
• Meal costs for non-Participants
• Human subject payments
• F&A/Indirect costs

Proposal Preparation

• Review guidelines carefully to determine whether PSC can be included in the budget
• F&A costs are not allowed on PSC expenditures
• Inclusion of PSC in the budget requires a detailed justification
  • Describe purpose of the costs, how they are calculated, and how they will directly benefit the project

Award Management

• PSC should be identified within the award
  • NFS will identify such funds specifically as PSC
  • Other agencies may use another cost category such as stipends
• PSC must be accounted for separately from the remainder of the award budget
  • Specific Account Codes must be used to identify PSC expenses
    • 651400 Non-Employee Grant PSC Travel
    • 751111 Grant PSC – Subsistence
    • 751112 Grant PSC – Other
    • 783200 Stipends - Grant PSC
    • 781101 Scholarships/Grants
• Re-budgeting from the PSC category into other categories must have prior sponsor approval.
• OGSP will coordinate with the Bursar’s office to ensure no F&A is charge on PSC.

PI Responsibility
The PI and his/her project staff must be familiar with the specific requirements set forth by the sponsor, and is expected to insure compliance with those requirements. In addition to the financial restrictions noted above, the PI/department is also required to retain records detailing:

• Criteria by which participants in the program are selected
• Copies of applications of selected participants, with documentation as to how they meet the selection criteria
• List of program participants and documentation of their participation in the program

Re-budgeting PSC
Most federal sponsors restrict re-budgeting of participant support costs. For this reason, Participant Support is set up as a sub-budget under the Parent Award.

NSF, through implementation of the Research Terms & Conditions, specifies prior approval requirements for re-budgeting participant support funds. Participant Support funds are restricted and require approval of the cognizant NSF program officer to reallocate funds out of the Participant Support sub budget. Re-budgeting costs into Participant Support does not require NSF approval unless funds are moving into the “other” category of participant support.

Generally, recipients may not re-budget funds from Participant Support to other categories without prior written approval of the sponsor. However, this is not the case for all sponsors. As always, read the award document, along with any applicable terms and condition or agency specific regulations, for guidance on re-budgeting Participant Support funds.

Participant Support Reimbursement of Expenses
Travel costs of participants in research of instructional training programs may be allowable as outlined in the applicable program announcement, the grant notice, and terms and conditions. The participant should retain original receipts for submission with the reimbursement request.
Procedures:
Participant Support Payments to Students. Participant Support payments can be made using one of the following methods:                                                 

1. Payment through Financial Aid. This process is coordinated by OGSP in conjunction with the PI and Bursar, who establishes the Disbursement Code so that expenses are paid from the appropriate grant and account code, and the Financial Aid office who places the stipend on the student’s account.
2. Payment through payroll if the participant is being paid a stipend and is already on the University’s payroll as a student employee. The stipend for students must be set up using a Personnel Action Form (PAF). This process is coordinated by the PI in conjunction with OGSP, Human Resources, and Payroll.

Participant Support Payments to Non-Students
In the electronic Payment Request Center, initiate a Payment Request Form and attach a completed W-9 and MEMORANDUM OF UNDERSTANDING - PARTICIPANT
SUPPORT STIPENDS OR SUBSISTENCE ALLOWANCES (Attachment 1). The following corresponding Account Codes should be used when the department enters the Payment Request:

• 751111 Grant Participant Supp - Subsist
• 751112 Grant Participant Supp - Other
• 783200 Stipends - Grant Part Supp

Some grant awards permit for a subsistence allowance or per diem to be paid to Participants to use for meals as Participant Support. If a meal is provided to a Participant at the conference or training, then the Participant may not also receive the per diem for that meal.

Reimbursements of Non-Employee Travel will follow the State of Georgia travel regulations and will be processed using the Travel Expense Statement form. Non-Employee - Grant Participant Travel will be charged to the respective grant project # and expensed using Account Code 651400.

IRS Regulatory Requirements
The University will report participant support payments that exceed $599 to the individual on IRS Form 1099-Misc at the end of each year or W-2 if the student/participant is paid through payroll. An IRS Form W-9 must be submitted in order for the participant to receive payment.

Contact the Office of Grants and Sponsored Projects at grants@gcsu.edu for specific guidance related to managing PSC on sponsored projects at Georgia College.
 

Summary

Georgia College & State University has a stewardship responsibility for compliance with the standards outlined in 2 CFR 200.430 Compensation - personnel services.  This process provides guidance which will allow Georgia College (GCSU) personnel charging salaries and wages to sponsored projects to be based upon records that accurately reflect work performed and certifying payroll.

Payroll Certification Procedures

Payroll Certification Instructions for PD/PI

The project director (PD) is responsible for completing the appropriate Personnel Action Form (PAF) in order to hire or distribute the proposed portion of salary to the externally funded project. The PAF must have OGSP written approval to confirm that the personnel expense is allowable and reasonable for the work proposed, prior to processing by HR, Budget, and Payroll. The PAFs track all personnel expenses related to Federal or other grants, and that they are tracked using project identifiers within the chart strings. It is also the PD’s responsibility to generate a Grant Budget Report regularly to confirm that the appropriate personnel expenses are being charge to the grant. OGSP also receives a detailed payroll file at the end of each month showing all personnel paid with sponsored funds to verify the expenditures.

Georgia College is the legal recipient of all grants and contracts received by its employees. When an award is received, Principal Investigators and the Office of Grants and Sponsored Research assume the administrative, compliance, and fiscal responsibility on behalf of the university to manage the grant award.

Only full-time, regular employees are eligible to be designated as Principal Investigators and to submit applications for external funding. This includes faculty and staff. Students are not permitted to submit applications for external funding.

Limited-term, part-time, or visiting employees are not eligible to submit proposals for external funding unless they:

1. are designated as a co-investigator and have an eligible PI as described above
2. have provided written justification to and received approval for each submission from their department/unit head, dean or director, and the Provost’s office.

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 the Uniform Guidance (2 CFR 200) 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, Georgia College extends the requirements to non-federal sponsors.

§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.

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 GCSU 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 GCSU 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.

Financial 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.

The PI/PD is responsible for preparing and submitting all technical/programmatic reports and invention disclosures required by the sponsor. This is an important obligation. OGSP requires copies of all technical/programmatic reports for the official file. PI/PD should send reports to OGSP at grants@gcsu.edu.

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 GCSU researchers as well. Please Note:  GCSU 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.

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.

OGSP is the official repository for GCSU grant-related records. 

Grant project directors and Financial Services are responsible for ensuring that copies of technical/program and financial 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. 

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.

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.

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.) Any arrangements to transfer a grant must be coordinated through OGSP who will then follow agency procedures to relinquish the award.

Transfer from another institution: A faculty member coming to GCSU from another institution may have a sponsored project which s/he wishes to transfer. 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 budgetary information must be processed at GCSU using the internal approval process.