SET-UP PROCESS

Once an award has been fully contracted, it progresses to the project set-up stage. Much of the work is done behind the scenes in the Office of Sponsored Projects (OSP), however the principal investigator and research team should be prepared to clarify issues if they arise during this process.

Administrative Establishment

When certain conditions are met an award can be set-up prior to the final award agreement being executed.

1. The proposal has been routed through OVPR and submitted.
2. There is correspondence or documentation that stipulates the sponsor will award the project.
3. The PI's department chair and the finance manager have confirmed they will take the risk of covering any expenditures whether or not the funding materializes.
4. This allows spending to begin on the award. The routing for department chair and finance manager approvals is handled using an online form in SharePoint.

All necessary compliance approvals have been met (if any).

If a project is awarded with a different amount than was budgeted, it is contingent on the research team to supply an updated budget for the purpose of being entered into the Oracle system. In most cases, the sponsored project analyst (SPA) will reach out for this new budget.

Once the project has been finalized by the OSP, the PI and research team will receive a generated email notification with a Project/Task/Award number (PTA) and a Banner Index. These are unique identifiers, with the PTA being used primarily for financial reporting and the Banner Index for HR and student data.

For cross-disciplinary or multi-school/department projects, separate PTAs are generated for each unit's principal investigator. If two or more of the PIs are in the same school, however, award set-up will often default to creating a single shared PTA. The additional PIs may have to request permissions to access the account on PI Dashboard from OVPR.

Principal investigators will primarily review their project status using PI Dashboard. Research administrative staff should have access to all of the following systems in order to maintain their grant portfolio.

PROJECT HIRES & PURCHASING

Once the project has been successfully set-up and is active in EAS and Banner, you can begin hiring and purchasing materials/equipment as required to initiate the research. Here you will find resources and standard operating procedures (SOPs) for these functions. Effort for principal and co-investigators is handled in its own section.

Hiring Non-Student Personnel

The hiring of personnel generally marks the start of the largest ongoing expenditures on a research project. This category includes positions such as collaborators, research scientists, and post-doctoral researchers. Consultants are hired through a different mechanism and are usually budgeted as direct costs; you can refer to the expense report section for details.

Collaborator

What distinguishes a collaborator from a co-investigator can be difficult to define, but a general rule of thumb is that collaborators bring complementary expertise, whereas a co-investigator is aligned with your area of thought and approach. In practice, these terms are often interchangeable. Collaborators and co-investigators at a different institution are usually paid through a subaward. Collaborators within GW will generally be established faculty and their effort will be handled by their department administrators.

Research Scientist

The process for hiring a research scientist is as follows:

Principal investigator shares the job description with the department research administration. The job listing is posted to the GW Jobs portal for a minimum of three days. Once applicants start applying, the pool is reviewed by the PI. Three candidates are chosen for interviews.

There are certain conditions that allow for a non-competitive hire to be made. Post-docs and research scientists can be recruited directly if they are specifically named in a grant. Faculty who are transferring a grant from a previous institution can also transition existing staff.

Link: GW Jobs Portal

Link: Human Resources

Questions: Keidra Lazard, Director of Human Resources; [email protected] 

• A disposition sheet is sent to Human Resources with information about who was interviewed and the outcomes.
• A candidate is selected and HR is informed.
• HR will extend a verbal job offer. If accepted, they will follow up with a written letter.
• The new hire supplies employment documentation (an I-9 and W-4 for domestic hires).

Post-Doctoral Researcher 

The process for hiring a post-doctoral researcher is as follows:

Principal investigator shares the job description with the department research administration. The job listing is posted to the GW Jobs portal for a minimum of three days. Once applicants start applying, the pool is reviewed by the PI. Three candidates are chosen for interviews.

There are certain conditions that allow for a non-competitive hire to be made. Post-docs and research scientists can be recruited directly if they are specifically named in a grant. Faculty who are transferring a grant from a previous institution can also transition existing staff.

Link: GW Jobs Portal

Link: Human Resources

Questions: Keidra Lazard, Director of Human Resources; [email protected] 

• A disposition sheet is sent to Human Resources with information about who was interviewed and the outcomes.
• A candidate is selected and HR is informed.
• HR will extend a verbal job offer. If accepted, they will follow up with a written letter.
• The new hire supplies employment documentation (an I-9 and W-4 for domestic hires).

Hourly Paid

The process for hiring a wage position is as follows:

Principal investigator shares the job description with the department research administration. The job listing is posted to the GW Jobs. Once applicants start applying, the pool is reviewed by the PI. Three candidates are chosen for interviews.

Exempt GW employees may take on additional hours as a wage position, but it cannot interfere with their primary duties and this option should be limited if utilized at all. Non-exempt GW employees who are at or near the 40 hour/week limit may not take an additional wage position or they risk pulling overtime. This position can receive some benefits and you can hire students using this track if you want them to receive those minor benefits.

Link: GW Jobs Portal

Link: Human Resources

Questions: Keidra Lazard, Director of Human Resources; [email protected] 

• A disposition sheet is sent to Human Resources with information about who was interviewed and the outcomes.
• A candidate is selected and HR is informed.
• HR will extend a verbal job offer. If accepted, they will follow up with a written letter.
• The new hire supplies employment documentation (an I-9 and W-4 for domestic hires).

Hiring Students

When hiring students on a research project, there are several considerations to make at the proposal stage about their position on the project. There are three different mechanisms available to hire students on research and one mechanism at the department level. Graduate research assistantships (GRA), graduate research fellowships (GRF), and wage hires can be posted to an award, while Graduate Assistantships (GA) are generally funded by the department. Each has specific functions and requirements of the PI.

Graduate Research Assistantship

In order to be highly competitive, it may be best to extend an offer of a research assistantship to a student. It ensures the student receives consistent monthly support, benefits, and most assistantships also include tuition remission. As a result, this is the most expensive option when building a budget. GRAs are 50% full-time equivalent (FTE) and are only allowed to work 20 hours per week in order to balance their academic courseload. However, as exempt employees, they are given some flexibility in how they schedule their time and they are not required to clock in and out. Additionally, there is the option to hire a GRA at a 100% FTE during the summer.

GRAs may split their appointment across multiple awards, either as a percentage of each month, or in blocks of full months (eg. 33% on project A and 66% on project B or 3 months on project A and 6 months on project B). GRAs are included on effort reports and must submit them alongside their PI.

The general process for hiring a GRA is as follows:

Principal investigator shares a job description with the department administrator. Include any special requirements for this particular position in the description. The department administrator will post the position using the student hire portal (link below). PI will review the applicant pool and choose candidates to interview.

Link: Office of Graduate Student Assistantships & Fellowships (OGSAF)

Questions: [email protected]; 202-994-6822

• After interviews have been conducted, Student Employment is informed.
• A verbal offer can be extended from the department or the PI directly.
• Student Employment supplies a formal job offer letter after the candidate accepts.
• The new hire provides work documentation (generally an I-9 and W-4 for domestic hires).

Graduate Research Fellowship

When hiring a GRF, the main distinction is that the student is not allowed to work in the same capacity as a GRA or wage hire, it is training opportunity. The PI must have provided some justification for the training component during submission of the proposal. GRFs are paid via a monthly stipend and they do not receive benefits. Moreover, foreign students paid as fellows will find the stipend is taxable.

Link: Student Employment

Questions: [email protected]; 202-994-8046

Non-Benefitted Hourly Paid

A non-benefitted hourly paid position allows the most flexibility in terms of hours worked, and can be the most economic option to choose on a budget with a tight limit. It does not confer the same level of funding support to a student as a research assistantship position since the hourly rates are usually much lower, and coupled with reduced benefits is comparatively less competitive. As a non-exempt position, a student hired as non-benefitted hourly will have to clock in and out, and will be eligible for overtime pay. On most federal awards, overtime pay is not an allowable charge, therefore, emphasize to any wage hires that they must carefully monitor their hours worked.

This position receives no benefits except sick leave and is handled through the Student Employment office. Additionally, there is a detailed matrix of acceptable salaries provided by Student Employment along with position descriptions and it is highly recommended to follow the guidance. The DC Wage Theft Prevention Act and Fair Labor Standards Act both have strict requirements regarding employment. A student must be fully hired before he or she can start working. The Department of Homeland Security requires that all new hires complete an I-9 form within three (3) days starting work.

Link: Student Employment

Link: Wage Matrix

Link: Position Descriptions

Questions: [email protected]; 202-994-8046

ColonialTemps is the internal temporary employment service provided by the George Washington University. It can be used to quickly fill a gap and candidates come from a wide background. Outside services can be used, but ColonialTemps is both free and has insider knowledge about the institution and academia that can lead to better placements.

Link: ColonialTemps

Questions: [email protected]; 202-994-0898

Expense Reporting

Many expenditures will be paid via expense report through the iBuy+ Concur system. This section will explain the basics for several common types of expenditures.

Link: iBuy+ Concur

Materials & Supplies

In general supplies will be handled using an expense report and covers purchases of materials below the capitalization threshold of $5,000 or with a useful life expectancy of less than one year. Additional information about equipment and fabrication can be found in the Equipment section of this page. General use office supplies and other materials that can be broadly used on multiple projects are not allowed as direct charges on a federally sponsored project and would fall in the overhead category to be expensed to the department. For example, a printer or workbench would not be allowed to post to an award. In some cases, if there is sufficient documentation to show that an item is being used on multiple projects, the cost can be split proportionally.

Link: Goods and Services

Questions: [email protected]; 202-994-0728

Equipment

Any purchase that exceeds the capitalization threshold of $5,000 with a life expectancy of greater than one year is classified as equipment and is exempt from indirect costs. Therefore, a $10,000 single use item and a $4,000 object expected to last 10 years would both be considered materials and supplies. If there are numerous item purchases under the capitalization threshold that are going to be turned into a single object that meet the qualifications for being equipment, those expenditures together will be considered fabrication and follow the same rules as regular equipment. The Fixed Asset Department regularly tags and tracks equipment. In fringe cases, if a piece of equipment or fabricated equipment is damaged or destroyed, the replacement parts will be considered materials and supplies regardless of price.

Link: Goods and Services

Questions: [email protected]; 202-994-0728

Domestic Travel

Any travel that occurs within the United States is classified as domestic travel. GW has a detailed guidance for travel, link below. There are, however, a few considerations for travel that should be mentioned up front.

• Travel packages that bundle airfare and hotel can cause issues if the service cannot provide an itemized receipt that shows the breakdown of costs. Caution travelers who may think they are getting the best deal as they may find their reimbursements are unallowable on the award. In most cases sponsors prefer transparency at the cost of more expensive airfare and lodging.
• While GW does not have a restriction on the cost per night of lodging, the GSA guidance can prove valuable in determining whether the cost is reasonable per the uniform guidance. A simple metric to use is the following. If the room is 200% the GSA base rate or less OR the hotel is listed as a recommended location by the conference, it should post to the award without a problem. If the room is more than 200% but less than 300% the GSA base rate, it would be prudent to have a justification on file provided by the traveler that indicates what circumstances required such expensive accommodations. Sometimes all the local hotels are full, but having some screengrabs from a hotel booking site that confirms this is helpful. Lastly, lodging more than 300% the GSA base rate should be considered unreasonable.
• Some hotels will offer a reduced or GSA rate if the traveler states s/he is using federal funds. It never hurts to ask.
• GW allows its employees to submit individual expenses under $35 without a receipt. For non-GW individuals traveling on a GW held grant, all expenditures require a receipt regardless of amount.

International Travel

When planning international travel, outside the United States, it can be extremely beneficial to get pre-approval for options like airfare upgrades and per diem, which both dramatically streamline the expense reporting process. Additionally, for flights, it is imperative to keep in mind the Fly America Act, which requires that international travel taken on federally sponsored funds must use or book through an American airline. There are numerous exceptions, but it is advised to use the in-built iBuy+ Concur tools for purchasing international flights as the university will take on the risk if they suggest a flight that is non-compliant.

Link: GW Fly America Guidance

Per diems for international travel will grant a certain amount of flat funds each day for meals and incidentals. Therefore, the traveler is not required to keep copies of all meal receipts to submit with the expense report. The per diem rate is established by GSA and must be authorized by the appropriate GW vice president or designee before travel has occurred. All the steps are detailed on the Office of Sponsored site.

Link: Per Diem Request

Services

Any services (single-use or ongoing) can generally be covered by an expense report. Services is a broad category of expense types, but common examples include: subscription to teleconferencing software, cloud computing server costs, and transcription services.

Procurement Guidelines

The Procurement & Travel Services Division at GW has a number of guidances available on their site. Their role is to ensure that GW receives goods and services responsibly and at a reasonable rate.

The Procurement Guidelines Matrix breaks down dollar amount thresholds on projects (sponsored and intramural) that require quotes and competition. Please refer to the full process guide for detailed instructions.

Questions: [email protected]; 202-994-2500

Award Administration & Management 

CONDUCTING RESEARCH

In the course of conducting the research, the principal investigator and research team will have to fulfill several functions to maintain the project. The following resources outline the most commonly encountered processes for day-to-day award management.

Effort

A principal investigator’s effort on a research project can be expressed in a number of different ways and reflects the amount of work the PI has performed. Research institutions and government sponsors have come to an agreement to allow personnel on their funded projects report effort a few times a year, rather than forcing timekeeping. GW has three effort reporting cycles, Spring, Fall, and Summer. It is fundamental to learn how to calculate effort to ensure that the report is both correct and compliant.

Most GWSPH and Medical School faculty are 12-month or calendar year appointments. However, most of the university uses a 9-month, or academic year appointment. Research faculty paid completely on research also exist. It is important to know the distinction between the appointment types and to have flexibility when building budgets that have personnel with different classifications.

Calendar Year Faculty

CY faculty are exempt, meaning they receive the same amount per month regardless of the amount of work hours (thus, they cannot be paid less if they work less except under very specific circumstances, and they do not receive overtime). When they receive salary support from research, it offsets funds the department would otherwise pay them.

Academic Year Faculty

AY faculty are also exempt, but they receive their 100% of their salary over the nine academic months (September through May). They may receive supplemental pay during the summer contingent upon research support. Summer salary can equal three additional months of salary should there be sufficient research to sustain it.

Research Faculty

Research faculty do not receive any salary support from their department. 100% of their salary is paid on research. Their level of effort can therefore fluctuate month to month depending on their projects and can dip below their baseline salary.

Invoices

An invoice will generally be received for services rendered or for equipment purchases. Smaller acquisitions are handled through expense reports and subaward invoices are covered under the subaward section in more detail due to having a different workflow.

Consultants

It is important when hiring consultants to ensure they are classified correctly. Consultants are generally hired in an advisory role, for their subject matter expertise, or for technical support. While they may be engaging in the research directly, it is usually more narrowly focused. While there are situations where a consultant who has an expanded role may be classified as a key personnel, in most cases, it would better suit the project to classify the individual as a collaborator.

Consultants will bill for their services by submitting an invoice to be paid on the grant. In order to be entered into the GW system, the consultant will need to register as a vendor using the New Supplier Registration site, which is part of the iSupplyGW portal. If the consultant has done business with the university before, tax documents may still need to be updated if they are over a year old. This can be done on the Supplier Maintenance site.

Link: Vendor Registration Instructions

Link: New Supplier Registration

Link: Supplier Maintenance

Questions: [email protected]

If an invoice cannot be provided, or if the invoice has insufficient information, the department can utilize a Payment Request form to cover or supplement. Once the department reviews the invoice and gets principal investigator approval, it can be submitted via the iBuy+ Concur invoice system.

Link: Invoice Processing Policy

Link: Payment Request Form

Link: iBuy+ Concur

Human Subjects

The George Washington University uses Advarra for its human subjects payments. This system is designed to replace the use of gift cards for the sake of expense reporting. Since it is handled in house, there are fewer issues surrounding how to handle the payment.

Forte payments are issued either directly to the participant’s bank account, or via a refillable card. Additional information about the Forte system can be found on the Accounts Payable website.

Link: Advarra Participants Payment Solution 

SUBAWARDS

Subawards are portions of a project that are granted by the prime institution to another, with the prime acting as a flow through entity (FTE) for sponsor funds. The subaward is given more autonomy than a subcontractor to fulfill the scope of work and research objectives.

Subaward vs. Subcontractor 

Subcontractors are not deeply involved in the research beyond what is needed to complete their portion of the scope of work. They will be given discrete deliverables or they provide a service and their involvement in the project will conclude after they fulfill those objectives. They are not subject to the same risk assessment and compliance requirements as a full subaward.

Subrecipients are given a portion of the project (the subaward) and will work with the prime’s research team. They are granted flexibility and creative control over the direction of their scope of work and will contribute to the overall project in a substantive capacity. It is imperative to correctly classify a subaward recipient versus a subcontractor, otherwise costs may be disallowed in a subsequent audit.

Subaward Set-up

All subawards are given a project number that consists of the setup year followed by “M” and a number (ex. 19-S15, 20-S08). Subawards designated as high-risk by GW’s Grants and Contracts Accounting Services (GCAS) will have an additional suffix “R” added to the end of the project number (ex. 18-S21R). GCAS does yearly assessments of all subawards and can change the classification of a subaward as needed. High-risk subawards will have additional invoicing requirements outlined in the contract.

Reviewing Subaward Invoices

For projects that include subawards, it is imperative to maintain oversight of their scope of work, output, and invoicing. GW’s standard invoicing procedure requires subawards to submit a certified invoice every one to three months. The exact requirements will be laid out in the subaward contract. The following certification statement required by the 2 CFR 200 must be included somewhere on the invoice.

“By signing this report, I certify to the best of my knowledge and belief that the report is true, complete, and accurate, and the expenditures, disbursements and cash receipts are for the purposes and objectives set forth in the terms and conditions of the Federal award. I am aware that any false, fictitious, or fraudulent information, or the omission of any material fact, may subject me to criminal, civil, or administrative penalties for fraud, false statements, false claims, or otherwise. (U.S. Code Title 18, Section 1001 and Title 31, Sections 3729-3730 and 3801-3812.)”

The following are some considerations when reviewing a subaward invoice:

• Are the expenditures lining up with the budget? Request justifications for cost overruns or underspent line items and receive approval from the PI.
• In the case a new expense type appears (eg. travel on an award that did not include travel previously), does the PI approve the charges?
• Note any non-compliant charges (eg. equipment purchases under the capitalization threshold of $5000, indirect costs on categories that are normally exempt such as participant support or tuition) and request clarification from the subaward.
• Is the subaward on track to spend to their budget? Alert the PI if the subaward appears dramatically over or underspent at important milestones. This can be difficult if the subaward invoices sporadically.
• If this is a high-risk subaward, have they complied with the restrictions put forward in the contract (high-risk subawards usually have to supply backup documentation for expenses, such as payroll or itemized receipts)?

After finishing a review, the subaward invoice will need to be approved and signed by the principal investigator before it can be entered into Concur for routing to the subaward analyst for central office review.

CHECK FINANCIALS & RUN REPORTS

As an award runs it course, it will be necessary to keep tabs on the finances and to occasionally generate reports. Using the PI Dashboard, you can monitor the current status of the award. For the majority of the lifespan, that project should be ACTIVE, however, there are certain conditions that can cause the status to change.

Award Status

Active

This is a default state for an award after it has been set up. Expenditures can post, there are no actions required.

On Hold

When an award in ON HOLD, GW will still generate invoices to send to the sponsor, however, no further expenditures can post to the award. The PI and research team will need to work with OVPR to assess the reason the award is in this state and submit documentation to return it to ACTIVE as needed.

At Risk

An award is put AT RISK when the university is covering the costs incurred until the sponsor can begin disbursing the funds. This state generally occurs when an administrative establishment has been requested in the absence of an active contract. An administrative establishment can set up spending before an award has been fully finalized as long as a package with relevant documentation has been submitted to OVPR. More details can be found in the Administrative Establishment section.

While AT RISK, spending can continue, however all invoicing to the sponsor is halted. It is prudent to avoid heavy spending if there is a possibility the sponsor may not be able to finalize contracting because the school or department will then bear the burden of covering the costs. An award will naturally exit this state when the contract is in effect.

Closed

When an award has completely closed out, the principal investigator has approved all charges, and GCAS has submitted the final invoice, an award will enter this final state. In general, there should be no more changes to the award at this point, but in rare instances, an award can reopen if requested by the sponsor.

Transaction Status

A transaction on an award can also have a status. If a transaction has not cleared, action will need to be taken.

Suspense

When a transaction falls into SUSPENSE, that transaction cannot post to the award. In general, either the transaction is of a type that is disallowed on the award, or more often it falls outside the period of performance.

In the former case, it must be moved off the award using a Department Correction Form (DCF) or a Labor Redistribution (LR) if the expenditure is related to effort. In the latter, if the period can be adjusted, for example by requesting pre-award spending, then the transaction can clear. Otherwise, a DCF will be required.

Failed Funds

When a transaction falls into failed funds, there is an insufficient balance on the project to cover the cost. Be aware that smaller expenditures that can still fit may post to the award while a transaction is still in failed, meaning less opportunity to move a portion onto the grant. Part or all of the transaction will have to move onto a different funding source unless additional funds are added to the award.