GVSU Principal Investigator Handbook

Index

Getting Started

The Submission Process

Budgetary Considerations

Award Management

Getting Started

What is a Sponsored Program?

A Sponsored Program or Project is a project that is funded by an external source, or in other words, not by Grand Valley State University (GVSU). External sources include those from government programs or foundations. The process of writing, submitting, accepting, and managing a sponsored program is coordinated by GVSU's Office of Sponsored Programs (OSP), and we're always here to help!


What We Do at the Office of Sponsored Programs

We work with principal investigators (PIs) during all of the steps needed to find, obtain, and manage external awards. Most importantly, under current university procedure, proposals to external sponsors must be submitted through the OSP. Since we assist the PI at all steps of the process, it's a good idea to contact us as early as possible when considering applying for external funding for a project.
For a directory of OSP staff, including email addresses and telephone numbers, click here.


Frequently Used Acronyms

B&F - Business and Finance, Office of
COI - Conflict of Interest CSCE - Center for Scholarly and Creative Excellence F&A - Facilities and Administration FAR - Federal Acquisitions Regulations FFATA - Federal Funding Accountability and Transparency Act FOA - Funding Opportunity Announcement FOAP - Fund Organization Account Program GVSU - Grand Valley State University HRRC - Human Research Review Committee HRSA - Health Resources and Services Administration IACUC - Institutional Animal Care and Use Committee IRAF - Internal Review and Approval Form IRB - Institutional Review Board LOI - Letter of Intent NIH - National Institutes of Health NSF - National Science Foundation OMB - Office of Management and Budget OSP - Office of Sponsored Programs PA - Program Announcement PD - Program Director PI - Principal Investigator RANF - Request to Add New Fund RCR - Responsible Conduct of Research RFI - Request for Information RFP - Request for Proposals TTO - Technology Transfer Office For a complete glossary, click here.


What's Required before Submission

There are some forms that must be completed and submitted to OSP prior to submitting a grant: a signed and completed Internal Approval and Review Form (IRAF), a copy of the proposal and budget, and a signed Conflict of Interest and Financial Disclosure Form.

Registration for Cayuse424, as well as training for the program, is also necessary before submitting a grant. Cayuse424 is a web-based system-to-system application to submit proposals to federal sponsors through Grants.gov and Research.gov. It is extremely user-friendly, providing easy navigation between multiple proposal forms, and Autofill capability, which eliminates multiple entries, and automatic error tracking and correction. Cayuse424 is both PC and Mac compatible.

Most PIs at GVSU have been preloaded as a user in Cayuse424. If you aren't, please contact the OSP.

Login at: gvsu.cayuse424.com At the Cayuse 424 login page, enter the following information.
Username: First part of GroupWise email address. Example: GroupWise email = chambech@gvsu.edu, therefore Cayuse424 username = chambech.
Password: For training class, password is set to "cayuse." Otherwise, click on the link: First time signing-in & need password? If your username is not in Cayuse424, please contact the OSP.

Cayuse424 runs entirely in a web browser. Firefox is recommended, but Internet Explorer with a PC is also compatible. Please set your browser configuration settings as follows:

JavaScript: On
Cookies: Enabled Pop-ups: Allowed

The Office of Sponsored Programs offers training each semester on how to create proposals in Cayuse424. Please check the Cayuse section of our website for the next training date, or check our website for links to Cayuse FAQ's, user manual, PowerPoint demos, and other instructional materials.

Some government sponsors also require that a PI register with their grant electronic research administration. Two examples are NIH, which requires registration with their eRA Commons, and NSF, which requires registration with FastLane.

GVSU Proposal Commitments

Proposals to external funding sources create infrastructure, technical, and financial commitments, some of which are stated and others implied. If the proposal is awarded, it is critical that GVSU and the PI are able to fulfill these commitments. These commitments include time and effort, which is the percentage of time the PI will spend devoted to the specific project as well as laboratory/work space, whose availability must be verified before the application is submitted. Further examples of direct commitments follow:

Direct Commitments:

The first type of direct commitment is related to time and effort, and it includes:

  • Principal investigator
  • Other key personnel
  • Post docs
  • Graduate students
  • Undergraduate students

The second type of direct commitment is related to facilities, including:

  • Laboratory space
  • Office space
  • Classroom space

The third type of direct commitment is related to equipment, including:

  • Computer use
  • Scientific equipment use
  • Machine or other shop use

Other Commitments:


The Submission Process
Key Steps to be Taken

  • Contact OSP as soon as possible
  • Determine the scope of your project, which includes duration, participants, estimated cost, etc.
  • Get the preliminary approval and support of your department head and dean for any required resources, which include release time, facilities, graduate students, etc.
  • Make sure the project you're planning will meet the sponsor's requirements
  • Determine if IRB/IACUC approval is required prior to proposal submission.
  • Confirm application procedures and program guidelines for your particular project
  • Different sponsors have different application and program guidelines. If you have question, please contact the OSP

Things to Look for When Reading the Sponsor Guidelines

The following are examples of important items to note in sponsor guidelines. This is not intended to be a comprehensive list.

  • Submission deadline
  • Project Length (project start and end dates)
  • Award amounts
  • Limitations to the number of applications per institution or department
  • Restrictions on an applicant's years of experience, position, or years in position
  • Whether PI salary can be included in the project budget
  • Page limitations and whether appendices may be included
  • Restrictions on concurrent applications to other programs, sponsors, or overlapping support for proposed project
  • Letter of intent (LOI) or other pre-proposal requirements
  • Cost-sharing or matching funds requirements
  • Restrictions on indirect cost rates
  • Restrictions on participation of foreign nationals
  • Publication restrictions
  • Requirements of data, resource, or intellectual property sharing
  • Export controls: requirements of federal licenses for sharing information or materials abroad
  • Method of submission (email, paper copy, Grants.gov, or other)
  • Reporting requirements

All guidelines are subject to change, and if you have questions, please contact the OSP
Internal Review and Approval Form (IRAF)

As stated by the Sponsored Agreement Procedures:

All proposals to be submitted to an external sponsor must undergo internal review and approval. This review ensures that a proposal meets with the Department Chair/Unit Head approval, as well as that of the Dean of the College. Proposals may also require additional resources, facilities/space, release time, overload, or commitments on the part of the University. This review and concurrence ensures that the University will be able to meet those requirements.

The internal review also addresses key compliance issues such as the protection of human subjects, care and use of animals in research, laboratory safety training, hazardous materials and controlled substances, and export controls.

The IRAF also serves to meet the Financial Disclosure/Conflict of Interest requirements of the National Science Foundation and the National Institutes of Health, which is required at the time of submission. The disclosures provided on this form are signed off by both the Department Chair/Unit Head and the Dean of the College. Signed original copies of this form are kept with each proposal application and subsequent award.

Signatures required on this form include: Principal Investigator/Co-Principal Investigator, Department Chair/Unit Head, Dean, Office of University Development (for proposals submitted to private foundations), the University Controller, and the University Authorizing Official. If the proposal includes a Graduate Assistant (GA) Request, an authorization and signature from the Office of Graduate Studies will also be required.

A copy of the Internal Review and Approval form and the complete proposal must be submitted to the OSP at least 5 days prior to the sponsor's proposal deadline. While routing the IRAF, please remember that the OSP accepts electronic copies as long as the original form follows in the campus mail. If you have questions concerning the IRAF or its routing, please contact us.
For a copy of the form, click here.


Recommended PI and Proposal Timeline Considerations

90 Days Prior to the Deadline:
The PI informs the appropriate departments and OSP of their intent to submit. As soon as the PI decides to submit a proposal, they should inform their unit head, dean, and the OSP. This prior notification is especially important in the following instances:

  • If the project is particularly large or complex
  • Unusual terms and conditions referenced in the funding announcement
  • Limitations on the number of institutional applicants
  • Requests for deviations from School or College policies or practices
  • New initiatives involving significant resources requiring approvals
  • Interdisciplinary proposals requiring approvals from multiple units or colleges
  • Partnerships with other agencies/Universities which may result in subawards or contracts

OSP Review Process:
The OSP proposal review process assists the PI to ensure compliance with sponsor and institutional policies

5 Business Days Prior to the Sponsor Deadline:
The PI/Department submits proposal review materials, including the signed IRAF to OSP, which must include:

  • Signed and completed IRAF
  • Sponsor guidelines, funding announcement
  • Final proposal narrative
  • Proposal abstract narrative
  • Budget, including commitments for any matching funds
  • Budget justification
  • List of key personnel
  • Special administrative documents (if applicable) required by sponsor
  • All other proposal components

3 Days Prior to submission:

The completed proposal must be released to the OSP two business days prior to the deadline. This allows for one last check by the OSP to resolve any errors or further corrections that need to be made, followed by successful submission. The PI then monitors the submission until the Sponsor accepts the proposal for review.

Late Submission to Internal Deadlines:

If the proposal materials do not reach the OSP by the internal deadlines (listed above), the proposal is considered late. The proposal will still be submitted as soon as possible, but the PI assumes the risk that he/she may need to correct errors in electronic submission and that the final proposal deadline might be missed.

Other Proposal Considerations

Personnel:

  1. Is the PI clearly identified?
  2. Is the PI eligible to submit proposals? (Must be full-time faculty or AP)
  3. Are the PI and all project personnel familiar with the GVSU Responsible Conduct of Research (RCR).
  4. Does the PI have an actual or perceived conflict of interest in their relationship with the sponsor?
  5. Are any Co-PIs or other key personnel involved in the project?
  6. Are the levels of effort stated in your proposal reasonable?
  7. Has the appropriate approval been given for the proposed level of effort, commitment of space and resources, etc., for every person with effort listed on the application?
  8. Is a Graduate Assistant requested? And if so, has the Office of Graduate Studies been contacted?

Remember: Proposals should adequately represent the estimated total time commitment of the key personnel that are committing to the project. In preparing proposals, PIs must be careful not to over commit themselves or others. In determining percentage of effort, the PI must take into account the time required for teaching, meetings, campus events, etc.

Institutional Assurances:

  1. Have the appropriate forms, including required assurances and certifications, been used?
  2. Will there be subcontractors/consortium sites conducting off-campus activities? If so, are letters of intent, scopes of work, and budgets in hand?
  3. Is a letter of intent/scope of work included for each consultant?
  4. Are current space and facilities resources adequate for the project?
  5. Does the proposal promise any institutional commitments beyond the proposed period of performance? If so, this must be approved by all appropriate authorities.
  6. Will there be the use of animals or humans in the project? If so, has Institutional Animal Care and Use Committee (IACUC) or the Institutional Review Board (IRB), which is part of GVSU's Human Research Review Committee (HRRC), approval been granted?
  7. Does the project involve the use, or will it result in the creation, of any research risks, such as: hazardous materials, chemicals, recombinant DNA?
  8. Does the proposal contain any proprietary material? If so, are these sections of the proposal labeled appropriately?
  9. Do any known publishing, intellectual property, or other sponsor restrictions exist for which negotiation may be necessary?

Administrative:

  1. Is all required proposal content included, accurate, and in the proper order as the sponsor expects to see it?
  2. Have the proposed start and end dates been clearly stated? Are these dates reasonable, given the submission date?
  3. Is the proposal formatted in accordance with the sponsor guidelines? Examples: number of pages, page formatting, spacing, margins, etc.

Financial Management:

  1. Is the proposed budget accurate, complete, and reasonable?
  2. Are all budget costs allowable and allocable? Can costs be supported under audit by the government?
  3. Have currently approved rates for fringe benefits and indirect costs been used?
  4. Have annual increases been calculated for the "out" years, which are the project years beyond year 1?
  5. Are the proposed costs necessary to conduct the project?
  6. Are travel costs based on sponsor guidelines or the GVSU travel policy?
  7. Have tuition costs for graduate students been requested?
  8. If the project will involve the use of institutional facilities (animal care, machine shop, computing), have these costs been included in the proposal at currently approved rates?
  9. Is cost-sharing required by the sponsor? If so, have the appropriate institutional approvals been obtained?
  10. Is any "hidden" cost-sharing mentioned in the body of the proposal (that could become mandatory cost sharing, if funded)?
  11. Is your anticipated effort, and that of your co-PI and Key Personnel, accurately reflected in both budget and justification? Has the percentage of effort been derived prudently?
  12. If you, your co-PI, or Key Personnel are not requesting salary, have you discussed with OSP whether or not cost-sharing is required?
  13. Do any matching funds need to be raised during the life of the project? If so, does this activity need to be coordinated with the University Development Office?
  14. Is a budget included for each subcontractor? Is it accurate and reasonable and has it been approved by the subcontractor's institutional authorized official?
  15. Are F&A Costs computed correctly based on the GVSU's federally negotiated rate and the sponsor guidelines?

If you have questions concerning these or any other proposal considerations, please email us by clicking here.

Electronic Submissions

  1. Does the PI have the required access and knowledge of how to use the electronic submission system, Cayuse424, or any other sponsor submission systems? Refer to the Cayuse information at the beginning of this document for training and details about the system.
  2. Is the format preserved accurately when viewed by the sponsor?
  3. Can the proposal be submitted in sufficient time to allow for electronic interruptions, like internet or network problems?

OSP Proposal Services

For a staff directory, click here.

  • Identification of funding opportunities (grant searches) and interpretation of sponsor requirements
  • Registration with sponsor's electronic systems if necessary
  • Assistance with preparation of forms (assurances, certifications)
  • Liaison activities with sponsor administrative contacts
  • Annual grant writing workshops

Conflict of Interest Disclosure

Conflicts of interest must be disclosed.

Budgetary Considerations

Direct Costs

Direct costs are defined by the Federal Government in the Office of Management and Budget Circular A-21 as "costs that can be identified specifically with a sponsored project, an instructional activity, or any other institutional activity, or that can be directly assigned to such activities relatively easily with a high degree of accuracy." In other words, direct costs are those that, if not for the existence of the grant, would not be incurred. They must also be allowable, as described by federal cost principles, and reasonable or consistent with the amount a prudent person would spend.

The following direct cost categories are typically used on most proposals:

Personnel:

Salaries, Wages, and Student Stipends - Starting with the PI, list the names and positions of all "key personnel." Then list the names and positions of all support personnel. Determine the "level of effort" or other measure of time commitment to the program for each individual.

Salary support for administrative and clerical staff is usually not requested (or allowed) in a grant budget, unless the project's requirement for these personnel far exceeds that the level of routine services the academic department provides.

Time spent on proposal preparation may not be allocated to a grant as a direct cost.

Fringe Benefits - Indicate the total amount of fringe benefits, based upon GVSU's approved rate structure.

Equipment:

Separately list each item of equipment with a unit cost greater than $5,000. Always provide an adequate justification of the need for each item requested. If a specific brand name and/or model of equipment is requested, work with Procurement Services and provide actual estimate from manufacturer.
Travel:

Describe the purpose and destination, when known, for the trip(s) and the individual(s) for whom travel funds are being requested. First class airfare is not allowed and all foreign travel using federal funds must be on US flag carriers whenever possible.

Consultant or Professional Services:

Indicate the name, when known, of each consultant and itemize costs including number of days, daily rate of pay, travel, and other related costs. A letter of intent to participate in the project should be appended to the proposal. Please note that some agencies, like NSF, have limits on fees.
Consortium/Contractual Costs:

  • Direct Costs: Costs allowable under sponsor regulations
  • Indirect Costs: Determined by applying the federal or sponsor-negotiated rate for the collaborating institution

Proposals that include consortium sites (subcontracts) must include: letter of intent to establish a consortium site's institutional official, budget, and statement.
Materials and Supplies:

Includes items such as chemicals, electronics, and laboratory materials used in the project. Do not include general office supplies, such as notebooks, paper, and pens.
Other Direct Costs:

Itemized by category, such as publications, graphic services, photography, maintenance, and service agreements, computer charges, rentals and leases, service centers, and tuition/fees.

Indirect Costs

Indirect costs are also known as Facilities and Administrative costs (F&A), and are defined as those costs that are incurred for common or joint objectives and therefore cannot be identified readily and specifically with a particular sponsored project, instructional activity, or any other institutional activity.

Indirect costs include expenses that cannot be charged directly such as lights and heat, snow removal, building maintenance, general office supplies, telephone line charges, postage, and the services of administrative costs such as those of the OSP.

GVSU has a federally negotiated indirect cost rate of 41% (calculated using a base of the GVSU salaries, wages, and fringe directly charged to the project), however some federal agencies limit this rate. Foundations also have varying indirect cost rates, which can be found in the program description.

Examples of Costs Covered by Indirect Costs:

  • General administration, which includes accounting, payroll, administrative offices, and procurement services
  • Sponsored Project Administration
  • Departmental administration, which includes business managers and department administrators
  • Plant operation and maintenance, which includes utilities, janitorial serviced, and repairs
  • Depreciation, which includes buildings and equipment
  • Library expenses

Budget Justifications

Generally, a cost without a reasonable justification invites elimination by the sponsor. There are a variety of methods used to justify amounts requested and many sponsors require that their guidelines are followed.

For a simple budget justification example, click here. For a complex justification, click here.

Cost-Sharing or Matching

While OMB Circular A-110 defines cost-sharing or matching interchangeably as meaning "that portion of project or program costs not borne by the federal government," many institutions commonly differentiate between the two, as follows:

Cost-Sharing:

The portion of the project or program costs funded with institutional funds.

Note: Uncompensated effort on a project is considered cost-sharing and must be addressed. See division-specific sections for further information.

Matching:

Funds raised by the institution from external sources for the purpose of supporting a portion of project or program costs, including cash and in-kind contributions of time and effort, equipment etc.

In-Kind Contribution:

Donated materials or services in support of a supported research project. A further breakdown by type of cost-sharing will be tracked for all proposals and awards. Regardless of what terminology is used, these cost-sharing/matching contributions must meet all of the following criteria in order to qualify as cost-sharing or matching under federally-funded programs or projects subject to OMB Circular A-110:

  1. Verifiable from the recipient's records.
  2. Not included as contributions for any other project or program that is federally assisted, aka "double dipping."
  3. Necessary and reasonable for proper and efficient accomplishment of project or program objectives.
  4. Allowable under the applicable cost principles, which are outlines in OMB Circular A-21. (Is that true?)
  5. Not paid by federal government under another award, except where authorized by federal statute to be used for cost-sharing or matching.
  6. Provided for in the approved budget when required be the federal awarding agency.

Upon receipt of an award, documentation of cost sharing and/or matching fund is the responsibility of the OSP grant manager. The recipient department must be able to reconcile and justify the type of expense throughout the life of an award, and ensure that all cost-share obligations, including uncompensated time, are met.

Obtaining Cost-sharing Approval at GVSU

Contact OSP pre-award to discuss sponsor requirements (programmatically-required cost-sharing levels, budget caps, etc.) and any other cost-sharing, like uncompensated effort.

Determine your level and source of cost-sharing and communicate your plan with the appropriate dean or designee.

All cost-sharing must be approved in advance by the appropriate dean or designee on the IRAF. The commitment to provide in-kind cost-sharing by other organizations should be documented in writing in a letter signed by an authorized official of the organization and attached to the IRAF.

Negotiations

Negotiations between OSP and the potential sponsor are sometimes necessary, especially if the award is a contract, in order to attain terms and conditions for conduct of the project which preserve the needs of the sponsor, the College, and the investigators.

Negotiating points may resolve issues such as:

  • intellectual property rights
  • licensing
  • patents
  • provisions for payments (up front, scheduled, cost reimbursement)
  • deliverables (what will the sponsor expect to receive during the life and upon the completion of the award?)
  • indemnification (who's responsible when something goes wrong?)
  • publications (prior review by the sponsor required)
  • confidentiality (what can be disclosed)

Any concerns on the part of the investigator should be conveyed to OSP. (Do we have institutional policies for some of these negotiation points?)

Site Visits

Occasionally, proposals involving large scale or complex scopes of work will result in a site visit by the sponsor. The purpose of these visits is to reassure the sponsor that the program will be completed successfully. These visits may occur prior to funding or during the project period. Issues involved in site visits include programmatic clarification, project timetables, staffing, reviews of financial and organizational controls, and tours of facilities. They can and often do take as many as three days to complete and require participation by faculty and administrative staff. Many agencies are substituting teleconferences for site visits to reduce costs.

Please inform OSP as soon as you have been contacted about scheduling a site visit. OSP is frequently included in these visits to provide information on the institution's administration structure and all communications with external parties, like funding agencies.

Follow-Up on Pending Human/Animal Approvals

Please read sponsor guidelines carefully regarding human and animal research subject approvals. Some sponsors require institutional approval letters at the time of application submission. Many sponsors are adopting NIH's "just-in-time" mechanism for final IRB/IACUC approvals to reduce the burden on institutional boards for projects that might not be funded. Because there might be little time between notification that a proposal might be funded and the award, it is recommended to prepare the IACUC and IRB approval ahead of time.

Please contact the HRRC (Human Research Review Committee) at an early stage about the status of your project in terms of human subjects. Projects involving surveys, human cells, or medical records may require IRB approval. The HRRC staff will provide advice about the level of review required (expedited, full committee, etc.) and the associated fees.

Award Management

Award Types

The following are the most typical award instruments used by the federal government and other sponsors.

Grant:

  • PI-initiated project
  • PI defines project
  • No substantial involvement between sponsor and recipient during project performance
  • More flexible award; allows the PI control over the project
  • Budget and performance monitoring required

Cooperative Agreement:

  • Substantial involvement in the project by both sponsor and recipient

Contract:

  • Project conceived by sponsor
  • Used to acquire product or services for the direct benefit of or use by sponsor
  • Requires strict adherence to budget and performance measurements
  • Sponsor exercises total direction or control

Award Processing

When awards are received, the following steps are subsequently completed:

  1. OSP reviews and negotiates award terms and conditions to ensure they are appropriate for the University
  2. OSP reviews the amount of effort proposed and awarded to ensure it is in compliance with GVSU policy and procedures
  3. Once fully executed award is received, OSP creates RANF with instructions for the PI
  4. OSP, PI, and Grants Accounting work together to open an FOAP
  5. OSP then transmits Notice of Award to departmental Grant Managers, OSP Grant Managers, and the PI
  6. OSP prepares and transmits reports of new awards to various offices; the offices of the Provost and the dean of the PI's department

Pre-Award Spending

Bridge Fund:

"Pre-award spending" of up to 90 days prior to the start date may be allowed by the sponsor, but requires not only written approval of the sponsor, but also OSP approval.

It is important to understand that any expenses incurred prior to the receipt of an actual award place the University at risk. If expected award does not materialize. Contact OSP with any questions regarding pre-award spending.

Post-Award Requirements

The PI, as Project Manager, has three primary responsibilities:

  • Managing the resources of the project
  • Planning and controlling the work of the project
  • Communicating with individuals and groups about the project

Each award received can have a variety of reporting requirements with which GVSU must comply during the life (project period) of the award and beyond. OSP transmits copies of all awards to the PI and other relevant offices to make them aware of the terms and conditions of awards, including which reports will be due and report deadlines.

Closeout memos will be sent to the PI and all other relevant parties as reminders that the grant is ending. These memos will be sent out 120, 90, 60, and 30 days prior to the closeout date of the award, and will include the reporting requirements that must be completed by the closeout date.

Upon receipt of an award transmittal, investigators must become familiar with these award terms and conditions. Any questions about what will be required should be addressed immediately by contacting OSP. Below are the typical characteristics that apply to the various types of reporting requirements.

Programmatic Reporting and/or Other Deliverables:

  • Completion is the responsibility of the PI, or in the absence of the PI, the Key Personnel
  • Reports include technical, narrative, or progress/performance reports. Other deliverables could include software, manuscripts, fabricated equipment, etc.
  • Reports can be required as often as monthly or as infrequently as once during or after the award period
  • If not completed to the sponsor's satisfaction, an inadequate report may give rise to termination, withholding of funds, freezing of sponsored funds to the institution, etc.

Financial Reporting:

  • Grants Accounting has responsibility for completion and submission
  • Assistance from the OSP, PI, the Business and Finance Office, and others to reconcile expenses/cost-sharing may be necessary
  • Reports may be required quarterly, semi-annually, or annually; invoicing may also be required, and are submitted through the Business and Finance Office

Subaward Management:

The PI is responsible for monitoring periodic progress reports and invoices for compliance with the terms of the subaward. As a result, the PI is expected to:

  • Maintain good communication with the subrecipient
  • Review subrecipient institution's reports and incorporate them into the project's progress reports
  • Review all invoices to ensure that expenses are appropriate and aligned with technical progress. Only the PI can approve payment of subrecipient invoices

Non-compliance with technical reporting requirements or dissatisfaction with level of subrecipient progress should be reported immediately to OSP. If there are issues with costs and/or work progress, the PI should not sign off on the invoice in question. A revised invoice will be requested from subrecipient or the invoice will be suspended until issues are resolved.

Other Reporting:

  • Assistance from the PI may be required to reconcile property records with award expenditures
  • Invention and Patent Reporting - Requirement varies from sponsor to sponsor; potential inventions should be brought to the attention of the Technology Commercialization Office

PI Closeout Responsibilities

The following is a checklist of the PI's responsibilities at the time of closeout.

90 Days before Budget/Project End Date:

  • Review report schedule and reporting requirements
  • Ensure subaward recipients have met goals
  • If a no-cost extension will be required, notify OSP
  • Determine if cost-sharing requirements have been met

At Budget/Project End Date:

  • Review all charges, including salary and benefits

Within 60 Days after Budget/Project End Date:

  • Ensure subaward recipients have met goals
  • Notify OSP if subaward is subject to de-obligation
  • Sign final labor verification by grant account form
  • Prepare/submit timely final reports: technical, invention, property, contractor's release, subcontract, Contractor's Assignment of Refund, Rebates, Credits, and other amounts (reporting requirements are sponsor-specific)

All financial reports are prepared and submitted by Grants Accounting.

Within 90 Days after Budget/Project End Date:

  • Contact OSP when project is complete and ready for closeout

Provide OSP With Copies of All Final Reports:

Ultimately, the PI is responsible for ensuring that all requirements have been met.

The Regulatory Environment for Federal Awards

Depending on the type of award and the sponsor, there can be a number of regulations with which GVSU must comply. This section covers some of the key compliance requirements that are consistently applied to most GVSU business transactions with a sponsor.

Relevant Regulations Affecting GVSU

US Office of Management & Budget (OMB), Circular A-21:

Covers cost principles, which are applicable to grants, contracts, and cooperative agreements.

http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#j

Defines and expands upon:

  • Allowable: An "allowable" cost is one that is eligible for reimbursement by the federal government. Generally it is not the type of cost that determines allowability; it is the purpose and circumstance of the expenditure
  • Allocable: The cost, or a group of costs, must be assignable to the project in a reasonable and realistic proportion that directly benefits a sponsored research award
  • Reasonable: The cost must be able to withstand public scrutiny, i.e. objective individuals not affiliated with the institution would agree that a cost is appropriate on a sponsored research award

It is important to refer to guideline updates on allowable costs.

US Office of Management and Budget (OMB), Circular A-110:
Covers administrative requirements, which apply to grants and cooperative agreements.

http://www.whitehouse.gov/omb/circulars/a110/a110.html

Defines and expands upon:

  • Definitions, standard forms, etc.
  • Standards for financial systems, written policies, cash management, cost-sharing or matching, program income, more forms, etc.
  • Required approvals, revision of budget/program plans, expanded authorities (e.g., to issue no-cost extensions, carry forward unobligated balances from year to year, etc.)
  • Audit requirements, allowability of costs, period of performance, etc.
  • Property standards, intangible property, intellectual property, etc.
  • Incorporation of Freedom of Information Act (FOIA)
  • Procurement standards, codes of conduct, competition, cost and price analysis, costing of proposals, etc.
  • Contract provisions to be included in subawards
  • Reporting requirements, record retention, etc.
  • Termination, award close out, etc.

US Office of Management and Budget (OMB), Circular A-133:

Covers audits, which apply to grants, contracts, and cooperative agreements.

http://www.whitehouse.gov/sites/default/files/omb/assets/a133/a133_revised_2007.pdf

Defines and expands upon:

  • Specifies 14 separate compliance requirements, including allowable costs, activities, cash management, equipment, level of effort devoted, programmatic, financial and other reporting, sub-recipient monitoring, etc.
  • Prescribes method for determining "Major Programs"
  • Specifies sub-recipient monitoring and audit report requirements

Federal Acquisition Regulations (FAR):

Covers principles relating to contracts only.

https://www.acquisition.gov/far/

Defines and expands upon:

  • Used on contracts (procurements), rather than on grants, which provide financial assistance
  • Part of the Code of Federal Regulations (CFR)
  • Incorporates OMB Circular A-21 above for purposes of determining allowable costs

Agency Implementing and Supplementing Guidelines:

  • Examples include NSF Grant Policy Manual, NIH Grant Policy Statement, NASA Grant and Cooperative Agreement Handbook, etc.

As a GVSU Investigator, What do I need to know about all of these regulations?

Keep in mind that the terms and conditions of each award refer to specific regulations that you should be familiar with as the PI of the project. However, in general you should know that:

  • Your level of responsibility is determined and defined by the terms and conditions of your individual award. You must read the award document and any appendices thoroughly and carefully.
  • If you submit a proposal to the federal government, any representations made are subject to a possible review and/or audit before or after receiving an award, even if you don't receive an award
  • Awards are made to GVSU, not to individual PIs
  • Evaluation of an allowable expense is followed by a determination of this expense as both allocable and reasonable (i.e., will an auditor feel the same way as you do about it in a year or two?)
  • You must create a realistic budget with sufficient justification in relation to the scope of your project
  • Costs, such as secretarial/administrative support, membership dues, subscriptions, office supplies, postage, telephone line charges and the like are not allowable as direct charges to federal awards and should not be included in proposal budgets
  • Proposals involving the use of either human subjects or animals require the approval of your protocol by the GVSU IRB or IACUC prior to award receipt and commencement of a study
  • The level of effort you are devoting to a project must be consistent with what was proposed and approved in your award (this becomes more important if you expect to devote LESS effort than was indicated in your proposal)
  • Should you decide to rebudget compensation associated with your effort, this becomes a cost-sharing issue and requires prior approval
  • Should you increase your effort and wish to be paid for the additional effort, this becomes a rebudget issue and requires prior approval
  • If you travel to a foreign country, you must use a U.S. flag carrier for the cost to be allowable on federal awards; otherwise, the cost of the air portion of the trip may become a personal liability. When making travel arrangements through the College Travel Office, notify the agent that the travel is associated with a sponsored project
  • The title to equipment purchased on federal grants can vest with GVSU, but requires sponsor's approval
  • There will be reports and/or some other deliverable required under each award, you should know what they are and when they will become due

PI General Responsibilities

The PI assumes several responsibilities, such as compliance with award terms and conditions, responsible management of their grant, and certifying time and effort of the personnel paid by the grant. A full list of these responsibilities are listed in the GVSU Principal Investigator General Responsibilities Form.