When Georgia Tech accepts a grant or contract from an external sponsor, the Institute assumes responsibility for the proper performance of the stated project, for the fiscal management of the funds received, and for accountability to the sponsor. The Project Director (PD)/Principal Investigator (PI) is responsible for determining the intellectual direction of the research and scholarship, and for the training of graduate students. In addition, the PD/PI is responsible for the design, conduct, and reporting – both scientific or technical and fiscal – of the research.

Therefore, it is the policy of the Institute that the Project Director or Principal Investigator must be a current member of the academic faculty or research faculty of the Institute as found in the approved List of Faculty Titles. Members of these faculty groups who are retired but working on an hourly-as-needed basis may serve as PD/PI provided there is at least one School/Laboratory/Department willing to provide the necessary administrative commitment to permit the program to be carried out. 

For awards whereby the sponsoring agency eligibility criteria require, encourage, or specifically allow for an undergraduate, graduate or postdoctoral individual to serve in the role of a PI or Co-PI, the Institute will request approval from the applicable Chair or Department Head and identification of a faculty mentor prior to submission of the proposal application. Examples include the National Institutes of Health (NIH) Institutional Training Grants or Fellowships and the National Science Foundation (NSF) Doctoral Dissertation Research Improvement Grants (DDRIGs).

There are other requirements for the title of Principal Investigator on studies reviewed by the Institutional Review Board, the Institutional Animal Care and Use Committee, and the Institutional Biosafety Committee. Click here to access the Office of Research Integrity Assurance website: http://researchintegrity.gatech.edu/

The Principal Investigator (PI) is ultimately responsible for both the technical goals of a research project and the fiscal management of such project, in accordance with sponsor and Institute regulations. Such fiscal management responsibilities include, but are not limited to:

• Preparation and submission of proposal budgets, including consideration of allowability of costs, cost sharing, commitment of effort and estimating methods
• Authorizing only those expenses that are reasonable and necessary to accomplish the project goals and that are consistent with the sponsor’s terms and conditions
• Seeking sponsor approval (in conjunction with the Office of Sponsored Programs), if necessary, for any significant change(s) in financial plans, rebudgeting or carryforward of funds
• Spending no more than the amount authorized by the sponsor for the project period
• Charging project costs directly to the project account
• Monitoring and reviewing expenditures in a timely fashion to assure their appropriateness and correctness
• If subrecipients are involved, reviewing the invoices of the subrecipient to ensure that expenditures are in line with performance
• Documenting cost-share commitments
• Identifying and accounting for any program income that accrues to the project
• Ensuring that those to whom authority for expenditure approval is being delegated (for example, on Personnel Service Forms (PSF’s), requisitions, purchase orders, travel expense statements and check requests) be documented by the Principal Investigator in writing on the Sign-Off Form for the individual project or by documenting the department’s award file
• Overseeing proper financial closeout of sponsored accounts, including approval and certification of the draft financial status report prepared by Grants and Contracts Accounting

It is important to emphasize that, while Principal Investigators can delegate their authority, they are still ultimately responsible for the transactions.

Non-employees are not generally eligible to serve as a PD/PI on sponsored projects. Requests for exceptions for a non-employee to serve as PD/PI on a specific project for a limited time may be directed to the Executive Vice President for Research. A without-compensation appointment such as a Visiting Scholar Agreement and associated agreements regarding intellectual property, liability insurance, and compliance with institute policies and procedure and related matters will be required. This exception is generally appropriate for newly hired faculty in transition from another institution and enables research to continue with minimal interruption.

It is the policy of Georgia Tech that the PI/PD must be a currently active faculty member and that a substitute PI/PD be named in the event that a PI/PD is absent from regular duty, including leaves of absence, for 90 days or more. Schools, Labs and Departments must notify OSP when PD/PIs arrange to terminate their employment, take a leave of absence, or are absent for medical or family leave.

Georgia Tech policy is that a Principal Investigator (PI) or other senior researcher must devote at least 1% effort – or a level of effort as required by sponsor – on an ongoing basis over the term of a sponsored project award. After the award is granted and accepted, the PI and key personnel are committed to provide that proposed level of effort over the budget period unless the sponsor permits otherwise. The committed effort, whether mandatory or voluntary, will be separately budgeted and accounted for by way of either the sponsored project or a companion cost sharing account.

What does ongoing basis mean?

Ongoing basis means per budget year over the life of the project.

Why do I need to put at least 1% effort on my projects?

The federal government expects a commitment of some effort on the part of the principal investigator for conducting work, over-seeing students, preparing deliverables, etc. during each project year. This effort may be expended during the academic year or summer and may be charged to the project or paid by the Institute and treated as cost sharing.

Can another investigator on the project satisfy this requirement?

Any senior researcher on the project can satisfy the requirement for the entire project.

Are there any exceptions?

This requirement does NOT extend to:

• equipment grants
• dissertation support
• limited-purpose awards, such as travel grants, conference support, etc.

How are Calendar, Academic, and Summer months treated?

Cost shared effort is calculated the same as sponsor paid effort, so it is very important to use the calculation that pertains to your faculty appointment.

For faculty on academic year contracts, months are expressed as either academic or summer months. The academic year is defined as a nine month period. Summer is defined as a three month period. The monthly rate for AY faculty is their salary divided by 9. One month = 1/9 = 11.11%. (This also explains why faculty can earn up to 33.33% of their AY salary in summer.) To express 1% in academic or summer months, divide 1% by 11.11%, which equals 0.09 academic or summer months.

For faculty on fiscal year contracts, months are expressed as calendar months, never academic or summer. The calendar year is a 12-month period. The monthly rate for 12-month faculty is their salary divided by 12. One month = 1/12 = 8.33%. To express 1% of a 12-month contract in calendar months, divide 1% by 8.33%, which equals 0.12 calendar months.

Are there any special considerations I need to know for NSF?

Unless stated otherwise in the solicitation, cost sharing (match, in-kind, institutional commitment, etc.) is unallowable.

Are there any special considerations I need to know for NIH?

The National Institutes of Health (NIH) Grants Policy Statement notes that “‘zero percent’ effort or “as needed effort” is not an acceptable level of involvement for Key Personnel. Those that may contribute to the scientific development or execution of the project, but are not committing any specified measurable effort to the project, should be described as Other Significant Contributors (OSC) rather than as a co-investigator.

If cost shared, how is this tracked?

If the PI chooses to cost share the 1% minimum effort instead of charging it to the sponsored project, a formal companion cost share account must be established. Voluntary cost sharing of this nature will not be reflected on the invoices or financial reports submitted to our sponsor.

Is the cost share reflected on the effort report?

Companion cost share accounts are established in the official Institute records and are reflected on the employee’s Workload Assignment Report E-mailed each month from the Salary Planning & Distribution Office in Grants and Contracts Accounting.

It is the policy of Georgia Tech that sponsored effort is accounted for on a consistent and reasonable manner.  The PD/PI and key personnel may have other responsibilities that prevent them from devoting 100% of their time to sponsored program activities. Those activities which are deemed unallowable through sponsored programs under the Uniform Administrative Requirements (2 CFR 200), therefore, cannot be paid from sponsored program accounts or included in Georgia Tech’s effort reporting system (Plan Confirmation System – Salary Planning and Distribution). Sponsored activities must be reviewed regularly to ensure that adjustments are made consistently with sponsored terms and conditions.

It is the policy of Georgia Institute of Technology to manage all funds received in accordance with applicable federal, state and local laws and with the specific terms and conditions of any gift, grant and contract. The Institute’s approval, negotiation and agreement processes and mechanisms, accounting, budget practices, and oversight differ depending on whether the funds are categorized as a gift or as a sponsored award.

The Office of the Executive Vice President for Research (EVPR) acts as the clearinghouse and final authority for all Limited Submission funding opportunities. The EVPR may choose to administer the selection of faculty member(s) to represent Georgia Tech as approved applicants or they may delegate this selection authority to other units, based on the scope or scale of the sponsor’s solicitation. Learn more here.

The EVPR proactively identifies as many limited submission opportunities as possible and maintains a list of recurring limited submission funding opportunities.

Principal investigators (PIs) who intend to respond to a limited submission opportunity must notify the EVPR, as early as possible, to allow for time to vet the solicitation and implement an applicant selection strategy, if required.

When a limited submission opportunity arises with an abbreviated response window, the EVPR identifies key partners and stakeholders in areas most likely to be respondent to the solicitation to gauge interest. If it cannot be determined that an interested party exists, or if the timeline is too tight for extensive investigation, the EVPR employs a ‘first come, first serve’ approach to approving a Georgia Tech applicant.

It is the policy of Georgia Tech that when faculty and staff are establishing a working relationship with another company or organization for the preparation of a specific proposal to a potential sponsor of research a Teaming Agreement is utilized. The Teaming Agreement delineates the responsibility of each party in preparing the proposal. Furthermore, the Teaming Agreement establishes the intent of the parties to share the work required under the resulting contract, should the team be successful. Upon award of the contract, contract terms and conditions take effect and the Teaming Agreement expires. Teaming Agreements are exclusive or non-exclusive. In an exclusive Teaming Agreement, Georgia Tech (usually including the Institute, GTRC, and GTARC) can only submit a proposal with the designated prime contractor in response to the solicitation. Georgia Tech restricts its acceptance of exclusive Teaming Agreements and will not accept a campus-wide exclusivity provision and limits the exclusivity provision to a single unit or Project Director/Principal Investigator (PD/PI). Georgia Tech prefers non-exclusive teaming arrangement to maximize opportunities for Georgia Tech researchers in different parts of the Institute to team with additional parties or to submit a proposal independently in response to a Request for Proposal.

It is the policy of Georgia Tech to utilize an Interagency Personnel Act (IPA) agreement to facilitate Federal-State-Local cooperation through the temporary assignment of Georgia Tech academic and research faculty to governmental agencies to provide skills that meet a national need, to engage in policy advice and formation in the area of the faculty member’s scholarship, or gain new research insights or perspectives. Georgia Tech encourages faculty to consider IPA service when such service is consistent with the mission of the Institute.

Appropriate Use: An IPA permits the temporary assignment of skilled career employees to positions with Federal Agencies, State, local governments, Indian tribes, institutes of higher learning and other eligible organizations as defined in 5 CFR 334. The assignment must be for specific work beneficial to both entities. The assignment should be used to achieve one of the following objectives:

1. For the strengthening of management capabilities of the Federal Agency and Georgia Institute of Technology.
2. Assisting with the transfer and use of new technology and approaches to solving governmental problems.
3. Serving as a means of involving non-federal officials in developing and implementing Federal programs.
4. Providing developmental experience to enhance job performance of the IPA Assignees.

Career employees may participate on an IPA provided that they have been employed in a regular career position at Georgia Tech for a minimum of 90 days prior to beginning an IPA assignment and their assignment meets one of the objectives stated above. The Georgia Tech Assignee may not be employed by Georgia Tech for the sole purpose of becoming an eligible participant of the IPA program. Employees hired for a 90 day research contract for a particular federal government agency, to be sent on an IPA assignment to that federal government agency are not career employees for the purposes of this policy. The Provost may waive the provisions of this paragraph as a policy exception as provided below.

During the period of an IPA assignment a Georgia Tech Assignee will remain a regular employee of Georgia Tech, and will remain bound by Georgia Tech policies and procedures and the terms of the employment agreement for all purposes including but not limited to, salary increases, benefits and the assignment of Intellectual Property to GTRC.

An assignment may be for a period of 2 years. The assignment may be extended for up to another 2 years with the approval of all parties. Extensions beyond a 4 year period require additional justification and written approval. In no event shall a Georgia Tech Employee remain on a continuous IPA Assignment for more than 6 years.

An IPA assignment may be terminated upon request of either party upon 30 days advance notice or automatically when the employer/employee relationship ceases to exist between the IPA assignee and his/her original employer as provided in 5 CFR 334.107. At the end of the IPA assignment, the IPA Assignee should return to the career position such employee held at Georgia Tech prior to the IPA.

Employees on IPA assignment are subject to the Ethics in Government Act of 1978, 5 CFR Chapter 735 which regulates employee responsibilities and conduct as well as any agency standards of conduct.

Revised November 2007, Georgia Tech developed and implemented a plan in 1996 named the Graduate Student Tuition Remission Plan (GSTRP). This plan was reviewed and approved by the Office of Naval Research (ONR). Since that time annual rate studies have been provided to ONR that are audited by the Defense Contract Audit Agency (DCAA) to produce approved rates for each fiscal year. The key features of this program are:

1. The Tuition Remission Award is managed through our graduate coordinators in each academic department. Upon approval of the appointment as a Graduate Research Assistant or Graduate Teaching Assistant (GRA/GTA) the home department of the student will enter a waiver code into the student system and then a credit is processed to the student's account for the fee reduction for the academic term (set on an annual basis). All GRA/GTA appointments are processed in this manner. The fee reduction is charged against one of two ledger accounts based on whether the reduction is for in-state or out-of-state tuition.
2. Part of the requirement for the appointment as a GRA/GTA includes the appointment to provide services to GIT at 33% to 50% time, registered for at least 12 credit hours of which 9 are letter grade/pass/fail. GRA/GTA's must be hired in the appropriate job code for a GRA/GTA in Human Resources. These appointments are made by the academic departments and the charges will be made against appropriate benefiting activity.
3. On a monthly basis, the Salary Planning and Distribution (SPD) System identifies the GRA/GTA payroll charges to sponsored projects and charges the sponsored project the approved monthly rate. If the student provides services to multiple projects, the charge is prorated. The charge to the sponsored project is offset by a credit to a Revenue Account- Sponsored Funded Fees.
4. Waivers of GSTRP charges to sponsored projects are considered by the Office of the Provost when required. Any such request should identify the unique features of the sponsored project that might warrant this special accounting treatment.

Tuition Remission Escalation Factor

Based on the proposed Fiscal Year (FY) 2013 Graduate Student Tuition Remission Program (GSTRP) rate proposal, please continue to use the 8% tuition remission escalation factor for fiscal years beyond FY2013.

Direct costs are those that can be specifically identified with a single sponsored project. These costs usually include salaries/wages, fringe benefits, contracted services, supplies, equipment, travel, communication*, tuition remission and participant support costs. In most instances the direct costs should be reflected by major budget categories with an attached narrative detailing how the costs were calculated. The budget narrative should contain enough detail for the sponsor to verify the appropriateness of the costs. (*see definition of communication costs listed below.)

1. Salaries and Wages – The budget detail should include the title, name and percentage of time/number of months summer or academic for each person listed on the budget. If a specific technician, graduate student or other student worker has not been identified at the time of budget preparation the salary amount for those categories should be consistent with those normally paid by the department or if you are unsure of the rate then use the Institute average category.

   ESTIMATING YOUR BUDGET: Salary compensation should be based on the percent of time the employee will spend on the project.
   Example: (monthly salary rate) x (___% of effort) x (no. of months).

   If the project is multi-year, most people include at least a 3% annual increase effective July 1 of every year. Salaries posted to a sponsored program will be based upon actual salaries not projected salaries. All budgets have their limitations! If you budget for a graduate student and end up hiring a post doc instead; keep in mind that there are additional fringe benefits that you MUST pay out of the budget for a post doc!

2. Fringe Benefits (Current Rates) – Ineligibility for Fringes: Undergraduate Students* and Graduate Students.* Fringe Benefits are calculated according to the Rate Agreement for the Georgia Tech Research Corp. negotiated with our cognizant federal agency, the Office of Naval Research and include FICA, unemployment and workman’s compensation, retirement and group health insurance. [*Note: Salaries and wages of employees who participate in all or part of the social security program but do not participate in retirement or group health and life insurance plans. This rate covers (i) temporary classified persons, (ii) temporary academic or research professionals not eligible for the retirement programs or group health or life insurance coverage, (iii) student employees who are registered for less than a full academic load and (iv) part-time employees employed for less than 50 percent of a full work schedule.]
3. Equipment – Only items costing $5,000 or more with a useful life of two years or more should be listed here. Cost estimates should include any installation, tax and shipping costs associated. The need for the equipment should be adequately justified on the budget explanation page. General purpose equipment, such as computer equipment, is not eligible for support unless primarily or exclusively used in the actual conduct of scientific research. [Note: Restriction on General Purpose Office Equipment - The Office of Management and Budget does not allow purchase of general purpose office equipment. According to OMB Circular A-21, "'General purpose equipment' means equipment, the use of which is not limited only to research, medical, scientific or other technical activities. Examples of general purpose equipment include office equipment and furnishings (chairs, file cabinets, etc.), air conditioning equipment, reproduction and printing equipment, motor vehicles, and automatic data processing equipment." These are only allowable if they have been specifically identified and approved by the sponsoring agency in advance of purchase.]
4. Travel – Proposed travel should include number of trips planned, number of persons for each trip, conference name, location, purpose and cost. The purpose of the travel should be adequately justified on the budget explanation page. Many federal agencies require utilization of U.S. Flag Carriers on international flights. Be sure to check your guidelines for details. URL for Federal Per Diem Rates:http://www.state.gov
5. Participant/Trainee Support Costs – Typically used on federal awards for the costs of the travel, meals and lodging of project participants (not GaTech employees); i.e., the trainees at a science education conference or a stipend for participants who complete project survey. Facilities and administration costs are not charged on participant support costs on federal awards.
6. Other Direct Costs – Other Direct Costs include materials and supplies, publication costs, consultant services, long distance telephone/fax and subcontracts. All direct costs should be itemized. The following list explains the most commonly requested ‘other direct costs.’
   1. Materials And Supplies – Indicate in general terms the type of expendable materials and supplies required along with their estimated costs. The breakdown should be more detailed when the cost is substantial. General purpose office supplies are not to be included in this category as they are covered by indirect costs. i.e., local phone calls!
   2. Publication Costs – Funds may be requested for the costs of preparing, publishing, or otherwise making available the findings and products of the work conducted under the research project, including costs of reports, reprints, or page charges.
   3. Consultant Services – Anticipated consultant services should be justified and information furnished on each individuals’ expertise, primary organizational affiliation, daily compensation rate, and number of days of expected services. We recommend that a letter be included in the proposal from the consultant stating their willingness to participate, as well as their actual daily rate with proper documentation. Some federal agencies will limit the maximum daily compensation rate paid to off-campus consultant services – check with your Contracting Officer to verify limitations.
   4. Subawards – Subawards should be disclosed in the technical section of the proposal to show a clear delineation of the work to be performed by each organization. The total amount for proposed subawards should appear under “Other Direct Costs” in the master budget for the project. Each “sub” should follow the following guidelines:
      F&A is charged on the first $25,000 of each subaward.
      Formal proposal signed by authorized representative with a statement of work and budget are required to be submitted to the Contracting Officer. See Interdivisional Transfer for information on issuing subprojects between Georgia Tech Departmental Units & GTRI.
7. Cost Sharing – If cost sharing is to be included in a proposal then the sources of cost sharing and matching must be identified at the proposal stage with appropriate forms identifying such.  Only mandatory cost sharing is tracked by OSP and G&C accounting.
8. Tuition (Link to F&A Rates) – Tuition for graduate students is normally included in the budget.
9. Communication – This includes telephone communication, postage, FedEx, advertising and associated costs that are non-routine and pose an extraordinary need (i.e., a phone bank for a project that includes a survey administered via the telephone.)
10. Repairs and Maintenance – This includes costs of maintaining property, i.e., maintenance contracts for office equipment and repairs of that equipment.
11. Interdivisional Transfers – Interdivisional Transfer is utilized when subprojects are established between Georgia Tech and GTRI. The subproject recipiant details their portion of work and the cost associated with it (both direct and indirect). The cost is then loaded into an “other” category and added to the total budget. Because it is an internal transfer, these costs would not be included in the F&A cost calculation.

Unallowable Costs may not be charged as direct costs on sponsored projects including cost share accounts or as indirect costs. Certain costs incurred by higher education institutions cannot be charged to federally sponsored research projects, either as a direct or F&A cost. These costs are referred to as unallowable costs. The Uniform Administrative Requirements (2 CFR 200), Subpart E - Cost Principles, provides guidance for determining basic considerations such as allowability of costs. The following specific items cannot be included in the F&A rate calculation or charged as direct costs to federal research:

• Advertising (displays, exhibits),
• Alcoholic Beverages,
• Alumni Activities,
• Bad Debts (noncollectable invoices),
• Commencement costs, Donations and Contributions,
• Entertainment Expenses,
• Fund Raising,
• Fines and Penalties,
• Goods and Services for Personal Use,
• Housing and Personal Living Expenses,
• Memberships in Social Organizations,
• Lobbying, Selling/Marketing of Goods and Services

Federal agencies awarding projects to institutions may apply further restrictions on the allowability of certain costs.

Other Unallowable Costs

Trafficking in Persons
In compliance with the International Trafficking in Persons Act, no sponsor funds may be used to engage in or support trafficking in persons, procurement of sexual acts, or forced labor.

Lobbying
No sponsor funds may be used to effect any oral, written or electronic communications to a covered Legislative or Executive Branch Official in an attempt to influence the formulation, modification, or adoption of Federal legislation; the administration or execution of a Federal program or policy; formulation, modification, or adoption of a Federal rule, regulation, Executive order, policy or position of the United States Government; or the nomination or confirmation of a person subject to confirmation by the Senate.

Subrecipients, including subcontractors and consultants, must be identified in the proposal budget to ensure that costs are calculated correctly and so that appropriate documentation can be included in the proposal. Sponsor approval is required prior to entering into a subcontract. If it is a vendor relationship, no sponsor approval is required unless specified in the award terms and conditions.

It is the policy of Georgia Institute of Technology to recover Facilities & Administrative costs on all of its sponsored programs. When estimating the proposal cost of a sponsored activity, the appropriate Facilities and Administrative (F&A) rate is applied. This provides a means for Georgia Tech to recover the F&A (indirect) costs which are incurred by the total sponsored activity but which cannot be directly assigned to an individual project. Georgia Tech and GTRC negotiate Facilities & Administrative Costs rates for research performed by Resident Instruction with the Office of Naval Research which is the cognizant audit agency for the institution. Rates are based on an audited cost proposal. Facilities & Administrative Costs are consistently applied to sponsored projects in accordance with the requirements of the Uniform Administrative Requirements (2 CFR 200), Subpart E.

Except as noted 2.5.3 below, any request to cost share F&A costs either fully or partially must be approved by the Executive Vice President for Research. A justification must be provided for consideration. Cost share request forms can be found at http://www.osp.gatech.edu/forms/costshareform.pdf.

Georgia Tech complies with salary rate limitations in projects funded by agencies of the United States government that are statutorily required to implement such limitations. The amount of salary above the cap for faculty and other researchers except Graduate Research Assistants receiving tuition remission shall be paid by the employing unit.

An agency’s salary cap must be compared to the individual’s Institutional Base Salary (IBS), the compensation paid by Georgia Tech for an employee’s appointment, whether that individual’s time is spent on research, teaching, administration or other activities. IBS includes an individual’s regular salary (e.g. academic appointment) and salary/stipend from any additional assignment (e.g. chair of a department). The IBS does not include incidental, onetime payments. Also excluded from the IBS is salary paid directly to an individual by an organization outside Georgia Tech.

An individual’s IBS, rather than the capped rate, is used when calculating percentage of effort and the difference between the capped rate and the individual’s IBS is accounted for as cost sharing in order for Georgia Tech to meet the requirements of the Cost Accounting Standards incorporated in Uniform Guidance found at 2 CFR 200.

Georgia Tech complies with the salary direct cost limitations in projects funded by agencies of the United States government where such limitations are established in published regulations for the program or agency.

Please see the related policy Minimum PI Effort.

It is the policy of the Georgia Institute of Technology’s RCR Compliance Policy that all graduate students, all students who participate in Georgia Tech's Undergraduate Research Program, and any student receiving research funds or who participates in research activities funded by NIH or NSF shall engage in a program of study in the Responsible Conduct of Research that includes, at a minimum, the following elements (RCR elements):

• Conflicts of interest (personal, professional, and financial)
• Policies regarding the use of human subjects in research
• Policies regarding the use of vertebrate animals in research
• Laboratory safety, biohazard management, chemical safety, and polices regarding the use of radioisotopes and radiation sources in research
• The responsibilities and relationships of mentors and mentees
• Collaborative research
• The peer review process
• Data acquisition and laboratory tools; management, sharing and ownership of data and research tools
• Research misconduct and policies for handling research misconduct
• Authorship and publication
• Science and Engineering in Society: the scientist and engineer as responsible members of society and ethical issues in research and the environmental and societal impacts of scientific research

It is the responsibility of the Principal Investigators of NSF and NIH‐funded projects to ensure that all students engaged in research are informed of the requirement and that the requirement has been met. Moreover, it is the responsibility of the Principal Investigator to provide mentoring in RCR through discussions of RCR topics and through oversight of students’ research.