Standard Number 3.10.5: The institution maintains financial control over externally funded or sponsored research and programs.

Full Compliance

Georgia Southern University’s general environment of financial control is determined by its status as a member institution of the University System of Georgia. A compliance audit in accordance with OMB Circular A-133 Audits of States, Local Governments, and Non Profit Organizations is included in the annual audit of the University’s financial statements that is performed by the Georgia Department of Audit and Accounts. Furthermore, the University’s Office of Audit and Advisory Services performs periodic audits on grant accounts and processes. The most recent of these internal audits was for Contracts, Grants and Sponsored Research representing the period from July 1, 1998, through November 30, 1999, including indirect cost development.

Georgia Southern University encourages its faculty and staff to seek financial support beyond state appropriated resources. External funding from federal, state, local or private sources contributes to the professional development of faculty, advances the mission of the University, and provides meaningful opportunities to engage students in faculty research. At Georgia Southern, the University is designated to receive sponsored program funding, and the principal investigator or project director serves as the steward of the external support. The University accepts responsibility for the oversight, compliance management, and appropriate conduct of sponsored activities on behalf of the principal investigator/project director. Georgia Southern maintains a centralized, coordinated approach to the review, approval, submission and management of all sponsored programs. Review and approval processes are clearly defined and established to provide the University with appropriate controls for compliance and sound management of all sponsored activity. The Office of Research Services and Sponsored Programs (ORSSP) publishes a clear definition of Sponsored Programs. Sponsored programs may support instruction, research and/or public service activities.

Pre-Award/Proposal Development

The Office of Research Services and Sponsored Programs serves as the first point of contact for faculty or staff interested in submitting proposals to external sponsors. This function ensures accurate, comprehensive and coordinated management of all sponsored activities. The guidelines for proposal development established by the ORSSP provide procedures for correct calculation of salaries, fringe benefits, travel and other parts of the budget included in the direct and indirect costs of the program. The ORSSP staff assist in identification of funding, interpretation of guidelines, project/concept development, editing, preparation of forms and budget development. All pre-award processes are handled by this office.

Additionally, the ORSSP oversees notification of all required compliance committees. No award will be accepted unless appropriate review is conducted by the Institutional Review Board (IRB)—for projects involving research with human subjects; the Institutional Animal Care and Use Committee (IACUC)—for projects involving research with animals; and/or the Institutional Biosafety Committee (IBC)—for research involving hazardous materials or recombinant DNA. The ORSSP completes all compliance documents, verifies that cost sharing and/or matching obligations have been documented, approved, and tracked and that other circumstances that may warrant further approval have been addressed.

The ORSSP further serves as a check for compliance with the University’s Intellectual Property Policy. All faculty, staff and students are subject to the University’s policy, which specifically addresses both ownership and responsibility to report the development of intellectual property such as new processes, creative and scholarly works, materials, software, devices and/or other inventions. The creation of such work, particularly under the auspices of a sponsored program, must be disclosed to the Provost on project disclosure forms provided by the ORSSP.

After the proposal package is assembled, which includes the project abstract or summary, budget, and budget justification, it is attached to an Internal Approval Form (IAF) which is routed to the appropriate unit head to initiate the approval process. The IAF and proposal must receive the approvals of the unit head, the respective dean, Grants and Contracts, ORSSP, Office of Legal Affairs (for those with contracts only), and the Provost before submission to the funding agency. Signatures on the IAF correspond to the accountability assigned to each of the approving entities, collectively forming the blueprint for a systemic compliance effort with clearly identified responsibilities in sponsored program management. The roles and responsibilities of each signatory authority in reviewing and approving sponsored activities are defined in the ORSSP Policies and Procedures for Proposal Development and Management. The ORSSP is responsible for submission of all proposals in accordance with the sponsor’s guidelines. Award notifications are received by ORSSP then forwarded to the Office of Grants and Contracts for post-award processing. An award letter is issued to the principal investigator/project director notifying him or her about reporting and management requirements. Copies of the letter are sent to the Provost, respective dean and unit head. Finally, the ORSSP issues quarterly reports identifying sponsored activity by college. These quarterly reports are available on the ORSSP website.

Post Award/Project Management

The Office of Grants and Contracts (OGC) administers and oversees post award project management, holding ultimate accountability for the management of funds received from sponsored program awards. The principal investigator/project director works directly with the contracting officer in the OGC to manage the financial responsibilities of the project as specified in the OGC Grant and Contract Manual. Upon receipt of the award notification, the OGC establishes a Grant ID number and an expense and revenue account in the PeopleSoft Financial Accounting System. The University maintains control over research and instruction funding by separating the two types of funding into different fund accounts. Sponsored Program accounts are established in Fund 20000, designated specifically for restricted funds. This mechanism captures and tracks financial data separate from Education and General Funding (E&G)—accumulated in Fund 10000.

The OGC also establishes a post award grant file in which all award notices, agreements, modifications, invoices, receipts, correspondence and compliance with grant requirements are maintained. Furthermore, the OGC provides the principal investigator/project director with monthly expenditure/budget reports to facilitate the financial decision making process and requires that all expenditure documents be routed through its office for approval before being submitted for payment and/or purchase. This requirement serves as a check on the availability of funds as well as whether the expense is permissible under the terms and conditions of the grant/contract agreement and in compliance with applicable federal and state regulations. Additionally, the OGC requires that the principal investigator/project director provide a budget breakdown for the sponsored program. This budget is maintained by the OGC for the life of the project ensuring that budget control is centrally maintained. Any modifications or revisions to the original budget are handled by the OGC and must strictly follow the granting agency guidelines. The principal investigator/project director, however, is responsible for the actual budget management of the grant or contract. All funds must be expended by the end date specified in the grant or contract. No cost extension requests will be accepted from the principal investigator/project director within 30 days of the grant end date.

In addition, Grants and Contracts invoices the sponsor on a monthly basis. If electronic draw-downs are permitted from federal agencies, these are also completed each month or quarter. Payment terms are net 30. Funds remaining in the grant account for more than 90 days beyond the end of the grant/contract period (including any extensions) will revert back to the granting agency if mandated under the terms of the agreement. Grant and contract accounts are not permitted to run a budget deficit. All budget deficits are charged back to the principal investigator/project director unit’s Education and General (E&G) account.

Furthermore, the OGC performs a quarterly transaction to distribute any indirect cost recovery back to the relevant units, deans, vice president, and principal investigator/project director. Senate Bill 73, passed General Assembly of the State of Georgia, allows institutions to process indirect cost recovery funds in a unique fund account (Fund 15000) separate from sponsored and instruction funding thereby precluding the institution from becoming dependent on indirect cost allowances to support their operating budgets. Finally, the OGC prepares and submits all final financial reports, while the principal investigator/project director prepares any performance reports required by the granting agency. The OGC and the principal investigator/project director work closely to meet all grant/contract closeout responsibilities.