Â鶹ÊÓƵ

MGA’s federally negotiated Facilities & Administration (F&A) rate is 45% for on-campus and 15% for off-campus projects. It is to be applied to all proposals regardless of the funder unless the funder states in the announcement or within their written terms and conditions that a reduced or zero rate is required. All other situations regarding waiving or reducing F&A must be approved by the Provost.

All grant proposals must be routed for internal approval before submission may occur. Our office is here to assist you in completing the internal review and approval process.  After your proposal has been approved internally, our office will also assist you with submission of your grant proposal to the funding agency. It is important to include this internal process when developing your proposal preparation timeline.  Please complete the at least 10 days prior to the submission deadline, preferably sooner.

Only MGA’s authorizing officials, the President or his designee, can formally accept a grant or sponsored project.  Award notices from federal agencies are usually directed to the authorizing official, with a copy to the PI.  With the exception of the President or his/her designee, no one is authorized to accept any funds or sign any contract, thereby legally binding the university to the terms and conditions of the grant or contractual document.   Once an award notice is received, ORSP will coordinate the acceptance and signature process.

PLEASE NOTE: PI/PD, department chairpersons, and deans are not authorized to sign award documents on behalf of the university. All original official award documents, if received by the PI/PD, should be forwarded immediately to ORSP for processing. ORSP will consult with a PI/PD if the award differs from the submitted proposal, so that the award may be accepted, modified through negotiation with the sponsor, or rejected.

Negotiations:  In some cases, an award may be issued by the agency after a series of negotiations that may involve revisions to the scope of the project, period of performance, and/or proposed budget. ORSP, working with Legal Affairs, is the authorized agent for negotiating such revisions.  If revisions are necessary, ORSP will not make any changes to the project or scope without the consent of the PI/PD.  The acceptance of a revised scope of work, period of performance or budget is a judgment that only the PI/PD can make; it is not a judgment or condition that may be unilaterally imposed by the granting agency.

If the agency requires the submission of a revised work plan or budget, this must be prepared by the PI/PD with assistance from ORSP and submitted for institutional endorsement prior to forwarding the revisions to the agency.  Revisions, either programmatic or budgetary, which represent substantial changes to the original proposal must be reviewed and approved by ORSP and MGA administration in the same manner as a new proposal.

If the grant agency contacts the PI/PD about revisions, please contact ORSP for guidance and the appropriate documents to use.

Establishing an account for an award is managed by the Office of Finance. Upon receipt of an official award, ORSP staff will communicate essential award and budget details necessary for an account and send a memo requesting a project account number from the Office of Finance. To protect the PI/PD and the university, expenditures should not be incurred against a sponsored project until ORSP has received and processed the original award notification from the sponsor and a project account number has been assigned by the Office of Finance.

Reallocating funds within budget categories is typically allowed by most agencies, but certain agencies may impose limitations on changes to the approved budget. When seeking approval for re-budgeting from sponsoring agencies, it will be necessary to submit a formal written request along with a valid justification to ORSP (copy Office of Finance). Some agencies may grant the PI/PD and institution discretion to make such changes. In these instances, it is essential to communicate any changes to ORSP (copy Office of Finance) whenever re-budgeting is required. Federal grants typically do not require prior agency approval for re-budgeting if it affects less than 25% of the award budget. However, all other sources of funding will be assessed according to the terms and conditions outlined in the award agreement.

The award agreement's terms and conditions will outline any budgetary constraints imposed by the sponsoring entity. In cases where re-budgeting conditions are not explicitly addressed or are unclear in the award agreement, the PI/PD should seek guidance and clarification from ORSP and the sponsoring agency.

In certain situations, it may become necessary to appoint a new PI/PD. Prior to designating a new PI/PD, the sponsoring entity must be contacted and their approval obtained. If the PI/PD deems it necessary to nominate a replacement, such requests should be accompanied by endorsements from the department chairperson and the dean. In cases where the PI/PD holds the position of dean, the request should be endorsed by the Provost. When seeking the sponsorship agency's approval for the appointment of a new PI/PD, the request should typically include the rationale for the change and the curriculum vitae/biosketch of the designated PI/PD. These requests need to be submitted to ORSP for institutional endorsement before being forwarded to the sponsor.

ORSP, working with the Office of Finance, plays a crucial role in expediting sub-award agreements by aiding in document preparation and forwarding them to the sub-awardee for all sub-awards specified in the approved award budget during the initial award setup. In case additional sub-awards become necessary, it is imperative for the PI/PD to promptly inform ORSP.

Once a portion of the prime award is sub-awarded to a sub-recipient, various post-award obligations arise, which both the PI/PD and the university must adhere to. Monitoring the sub-recipient entails regular communication between the PI/PD and the sub-recipient. The PI/PD bears the responsibility of ensuring that the required deliverables are met and collaborates with Financial Services to facilitate reimbursements to the sub-recipient institution.

A sub-award, often referred to as a sub-contract, is essentially an award issued under a prime sponsored research award to procure specific services or program-related tasks. The issuance of sub-awards under federal prime awards is subject to compliance with federal regulations. All sub-awards must adhere to the terms and conditions outlined in the prime sponsored research award, as well as the standard purchasing requirements of MGA.

There are two fundamental types of sub-award arrangements:

1. When MGA is the recipient of a sub-award: In this scenario, MGA is linked to a larger proposal (prime award) submitted by another institution or group of institutions. The prime award is granted to another institution or group, with a portion of it subsequently sub-awarded to MGA for the fulfillment of specific tasks within the broader proposal. Financially, the management of funds in such cases is treated as an independent project, even though the PI/PD and MGA may have specific technical and financial reporting obligations to the larger project. Sub-awards to MGA undergo the same internal review process as standard grant and contract proposals and must be processed through ORSP and the Office of Finance. Faculty members do not have the authority to sign agreements on behalf of MGA.

2. When MGA is the grantor: When work to be carried out under an MGA-sponsored research award is outsourced to a third party, MGA becomes the grantor. This occurs when resources or expertise for specific tasks are not readily available at MGA. The intended use of the third party is typically outlined in the approved proposal. Adding new sub-awards to an ongoing project requires prior approval from the sponsor. Any inquiries regarding sub-awards should be directed to ORSP staff. Once the proposal is awarded, ORSP staff will draft a sub-award agreement that reflects the proposal's specifics (budget, scope of work, etc.), the sponsor's terms and conditions, and MGA's policies and procedures. Since sub-award agreements delegate a portion of the programmatic effort to another organization, they are responsible for managing the technical and administrative aspects of their scope of work and providing progress reports to the MGA PI/PD, along with financial reports to ORSP.

Each Notice of Award should be reviewed by the PI/PD and ORSP for the presence of sub-awards. If a sub-award is specified in the sponsor's Notice of Award, MGA with assistance from the Principal Investigator, is responsible for verifying the sub-award recipient's eligibility to receive federal funding. All necessary documentation will be electronically stored as evidence for the record.

MGA acknowledges its commitment to uphold the terms and conditions of an award upon accepting the grant. Ensuring adherence to university policies and sponsor regulations falls under the purview of the PI/PD and the Office of Finance. A diligent monitoring of all expenses is imperative to maintain compliance with these established guidelines.

The Office of Finance will evaluate all expenditure requests to verify that purchases align with the project's objectives and are reasonable, allowable, and cost-allocable. This process applies to various expenditure categories, such as e-procurement requests, operational expenses, travel reimbursements, and consultant contracts on sponsored projects, all of which necessitate MGA approval before processing by purchasing and financial services. Furthermore, when contracting services are involved, the MGA will conduct due diligence by checking state and federal clearinghouses to ensure that the vendor is not subject to suspension or debarment from government business. Adequate documentation will be maintained either in printed or electronic format as evidence for the project record.

The project director assumes responsibility for monitoring expenditures through PeopleSoft and conducting reviews for accuracy. Managing the budget in strict accordance with sponsor and university regulations regarding allowable, allocable, and attributable expenses, as specified in the approved budget, is also a key task for the project director. The PI/PD is required to be well-versed in and compliant with the fiscal management guidelines of both the sponsoring entity and the university.

Allowabilty of Expenditures: MGA  follows Federal guidelines determining the allowability of charges to a Federal grant. In accordance with 2 C.F.R. § 200.302 and 2 C.F.R. § 200.403 factors affecting allowability. It is the policy of MGA to adhere to all fiscal management compliance requirements set forth by Federal guidelines and funder terms & conditions.

This procedure outlines the relationship of Â鶹ÊÓƵ (MGA) and that of a third party to which we have entered into a legal relationship via a grant award agreement and certifications, a contract, a memorandum of agreement, memorandum of understanding, or another document drafted for a similar purpose, whereby funds are entrusted between the parties for a specific purpose and intent based on a prior representation of the purpose and use of the funds requested. The cost principles and procedures outlined in this section pertain to all third-party Grants and/or Contracts from Federal, State, Local or Private sources for which Â鶹ÊÓƵ has received funds or an agreement obligating funds.

These cost principles are based on the following premises that: Â鶹ÊÓƵ, as a fiduciary, is responsible for the efficient and effective administration of Federal, State, Local and/or Private awards through the application of sound management practices.

MGA assumes responsibility for administering Federal, State, Local and/or Private funds in a manner consistent with underlying agreement, program objectives, and the terms and conditions of the award.

MGA, in recognition of its unique combination of staff, facilities, and experience, is responsible for utilizing sound organization and management processes necessary to assure proper and efficient administration of every award.

Application of the cost principles will require no significant changes when applied to the Federal, State, Local and/or Private awards in the internal accounting policies and practices of MGA. However, MGA's accounting practices must be consistent with the cost principles and support the accumulation of costs as required by the granting entity and must provide adequate documentation to support costs charged to the award.

Indirect (facilities and administrative (F&A)) costs. The University’s federal cognizant agency receives an indirect cost rate proposal, which is reviewed, negotiated and approved with a cost allocation plan that assures to granting entities that MGA is applying these cost principles on a consistent basis. When wide variations exist in the treatment of a given cost item by MGA, the reasonableness and equity of such treatments will be fully considered. (as cited in 2 CFR 200.56)

MGA as an Institution of Higher Education (IHE) and as a University we are tasked with educating and engaging students in research, internships, and external cultural and professional development opportunities, that provide students with a dual role as a student and as a trainee and/or employee (including pre- and post-doctoral staff) contributing to the completion of Federal, State, Local or Private grants/contracts awarded for research and must be recognized in the application of these principles.

MGA may not earn or keep any profit resulting from Federal financial assistance (grants/awards), unless explicitly authorized by the terms and conditions of the Federal award (per 2 CFR 200.307 Program Income). This provision will equally be applied to the State, Local and/or Private awards/agreements with MGA.

Should there be any disagreement with the Policies and Procedures of the Cost Principles the issue will be referred to MGA's Vice President of Finance-Administration and Reporting for a final decision in the matter questioned. They may in their capacity and position refer the issue to the Vice President Finance, Business & Operations for further discussion and final determination, if deemed appropriate, as the individual ultimately responsible for the fiscal health and financial liability of the institution.

The State of Georgia and University System of Georgia (USG) regulations and guidelines provided to MGA and for which we are accountable will be used in the application of cost principles to third party Grants and/or Contracts from Federal, State, Local or Private sources, unless the Terms and Conditions of the Federal, State, Local or Private awards are more restrictive or deviate from those of the state of Georgia or USG. In a case where the Terms and Conditions of the third-party grant and/or contract deviate from the guidance of those of the State of Georgia's or USG and are more restrictive the Federal USG Cost Principles guidelines found in 2 CFR 200.400, or terms provided by the Local or Private grantor will supersede, as applicable.

These principles will be used to determine the allowable cost of work performed for grant and contract awards; and used by MGA as a guide in pricing fixed-price contracts and sub-contracts where costs are used in determining the appropriate price. However, the principles do not apply to:

o  Agreements under which funds (federal or otherwise) are in the form of scholarships, loans, fellowships, traineeships, or other fixed amounts based on such items as education allowance or published tuition rates and fees.

o  Capitation awards, based on case counts or number of beneficiaries according to the terms and conditions of the award.

o  Fixed Amount awards per federal 2 CFR 200.45 and 200.21. Use of grant agreements, cooperative agreements, and contracts.

o  Federal awards to hospitals.

o  Other awards under which MGA is not required to account to the Federal Government or other grantor for actual costs incurred.

Federal Contract: Should a federal contract be awarded to MGA and is subject to the Cost Accounting Standards (CAS), it incorporates the applicable CAS clauses, Standards, and CAS administration requirements per the 48 CFR Chapter 99 and 49 CFR part 30 (FAR Part 30).

CAS applies directly to the CAS-covered contract and the Cost Accounting Standards at 48 CFR parts 9904 or 9905 takes precedence over the cost principles in 2 CFR 200 Subpart E - Cost Principles with respect to the allocation of costs. Therefore, pertaining to CAS and application of Federal requirements only one set of accounting records needs to be maintained for the allocation of costs by MGA. The Terms and Conditions of the Federal Contract will need to be referred to in reference to CAS application to ensure compliance with the contract.

There are some factors and issues to consider with Federal, State, Local and Private Contracts and Grants costs that we may or may not need to address when working with MGA funds and their applications. Some of these basic considerations are:

Composition of Costs: What is the total cost of the contract? The total cost in a federal award is comprised of the sum of the allowable direct and allocable indirect costs less any applicable credits.

An award could also require a cost sharing or matching requirement that could be "in-kind,'' an actual "monetary expenditure," or both by MGA or another third party to the project/program. This could also be required with other types of awards.

Cost Allowability Factors: Costs must meet the following general criteria in order to be considered "allowable" for Federal awards, except where authorized by statue. Other contracts and grants could also have stipulations on what is "allowable," which will require referral to the terms of the grant award. The cost must:

o  Be necessary and reasonable for the performance of the Federal award and allocable to the award.

o  Conform to any limitations or exclusions set forth in the mandated principles or award as to types or amount of cost items.

o  Be consistent with policies and procedures that apply uniformly to both Federally funded and other activities and programs of MGA.

o  Apply consistent treatment. A cost may not be treated as direct cost to a Federal award if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as indirect costs.

o  Be determined to be in accordance with generally accepted accounting principles (GAAP).

o  Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program (double dipping - counting it twice) in either the current or prior period. Ref: 2 CFR 200.306

Documentation -All costs must be adequately documented per statutory and national policy requirements. Ref: 2 CFR 200.300-200.309

Reasonable Costs: A cost is reasonable if, in its nature and amount, it does not exceed that which could be incurred by a "reasonably prudent person" under the circumstances prevailing at the time the decision was made to incur the cost. As a state entity we have a responsibility to apply this consideration to all purchases and/or services contracted by MGA, for the use of federal or other funds and contracts. Consider the following when determining reasonableness of a given cost (Ref: 2 CFR 200.404): Is the "cost or expense" generally recognized as ordinary and necessary for the operation of MGA or proper for efficient performance of the award (federal or another type)?

 State purchase restrictions and guidelines are to be used in all purchases to ensure Sound Business Practices, Arm's-Length Bargaining, mandatory sources, purchase card restrictions, and other federal, state and local restrictions and laws, and other terms and conditions of the award are met to be compliant.

The Georgia State Purchase procedures and guidelines ensure that fair market prices for comparable goods or services for the geographic area are paid.

Individuals with a responsibility to MGA for authorization/approval of costs associated with awards must act with prudence, and for its: employees, students, the citizens of Georgia, and federal government.

MGA may not deviate from its established purchase restrictions, procedures and policies regarding incurring costs for the award to ensure they do not unjustifiably increase the federal or other grantor's costs.

Allocable Costs: It is important that costs are charged appropriately in direct relation to the award or other unit of the institution, and in some cases split/shared costs, relative to direct benefits received. This is the case for all types of awards, and units of the institution, Federal, State, Local and Private.

A cost is allocable to a particular award or other cost objective if the goods or services received are assignable to the award in direct relation to the benefits received. This standard is met if the cost:

o  Is incurred specifically for an individual award.

o  Is of benefit to both an award and function/work of another MGA department/unit and can be distributed in proportions that may be approximated using reasonable methods (prorated based on benefit received); and

o  Is necessary to the overall operation of MGA and is assignable in part to the award, based on the requirements of this section.

All activities of MGA will receive an appropriate allocation of MGA's indirect (F&A) cost, those with direct benefit in addition to unallowable activities and donated services by MGA or third parties. Costs allocable to a particular award, federal or otherwise, under the principles of this section may not be charged to other awards:

o  To overcome fund deficiencies/shortfalls,

o  To avoid restrictions imposed by federal/state statues, regulations, or an award's terms and conditions, or

o  For other reasons.

However, this does not mean that a cost that is allowable under two or more awards could not be shifted, in accordance with statues, regulations, and/or terms and conditions of the awards.

Should a cost benefit two or more projects/activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit.

 If a cost benefit multiple projects/activities in proportions that cannot be determined easily because of the nature of the cost, the cost may be allocated to benefited programs/awards using any reasonable documented basis.

When there is the purchase of a piece of Equipment or other capital asset that has specifically been authorized under the award (federal, state, local or private), the costs are assignable to the award, in full, regardless of the use that may be made of the equipment or other capital asset, when no longer needed for the purpose for which it was originally required.

CAS Contracts. Costs must be allocated to the contract pursuant to the Cost Accounting Standards. The allocation of costs in accordance with CAS takes precedence over the allocation principles of this section.

Applicable credits refer to those receipts or reduction-of-expenditure-type transactions that offset or reduce expense items allocable to the award (federal, state, local or private) as a direct or indirect (F&A) cost. Examples of these type of transactions are:

o  Purchase discounts,

o  Rebates or allowances,

o  Recoveries or indemnities on losses,

o  Refunds,

o  Adjustments or overpayments, or

o  Erroneous charges.

To the extent the credit is accrued or received by MGA relates to the allowable costs, they must also be credited back to the award where the cost was originally allocated, as a cost reduction or cash refund to the actual expense account where the expense was charged and not posted to award revenue or income. Some instances occur where the amounts received from a Federal Government award to finance activities or service operations of MGA should be treated as applicable credits. The concept of netting such credit items (including any amounts used to meet cost sharing or matching requirements) must be recognized in determining the rates or amounts charged to the Federal award. In this case - Ref. 2 CFR200.436 Depreciation or 2 CFR 200.468 Specialized Service Facilities.

There may be situations under any given award (federal, state, local or private) when the reasonableness of allocability of certain items of costs may be difficult to determine. To prevent any dispute or disallowance of the expense (costs) based on unreasonableness or non-allocability, after the fact, MGA should seek advice and direction in advance of the incurrence of special or unusual costs via prior written approval from the awarding grantor/agency, or in the case of a federal award when an indirect cost is affected the cognizant agency. The absence of prior written approval on any element of cost will not affect the reasonableness or allocability of that element, unless prior approval is specifically required for allowability as described under certain circumstances for awards. It is always best to seek the advice of the grantor. In the case of federal awards Ref. 2 CFR 200.407 for a list of some specific sections and situations in which written approvals are required.

The award (federal, state, local and possibly private) may be subject to statutory requirements that limit the allowability of costs. When the maximum amount allowable, under these limitations, is less than the total determined amount/cost, in accordance with the applied principles, that amount in excess of the recoverable amount may not be charged to the award. Federal Ref. 2 CFR 200.408

Special Considerations: In addition to the basic considerations regarding the allowability of costs, there are some special considerations and requirements that are applicable to states and IHE's that may pertain to MGA the indicated award. Special Considerations for Institutions of Higher Education - 2 CFR 200.418 Costs Incurred by States and Local Governments and 200.419 Cost Accounting Standards and Disclosure Statement.

When costs, either direct or indirect, are charged to your award (federal, state, local or private) and payments have been received by MGA from the grantor, and they are then later determined, via audit or other methods, to be unallowable by either the grantor (awarding agency), cognizant agency for federal indirect costs, or a pass- through entity, they must be refunded to the grantor. This will include interest for federal grants per instructions from the federal agency that determined the costs to being unallowable. Ref. 2 CFR 200.410.

Adjustment of Previously Negotiated lndirect (F&A) Cost Rates - Unallowable Costs (FEDERAL Awards ONLY) Ref. 2 CFR 200.411: Previously negotiated Federal indirect (F&A) cost rates can be adjusted should it be determined that it was based on a proposal later found to have included unallowable costs, for one reason or another, that: Are unallowable as specified by Federal statutes, regulations or the terms and conditions of a Federal award; or are unallowable because they are not allocable to the Federal award(s), must be adjusted, or a refund(s) must be made, per the requirements of Ref. 2 CFR 200.411. The adjustments/refunds are designed to correct the proposals used to establish the rate and do not constitute reopening of the rate negotiation. These adjustments are made regardless of the type, method used, or (indirect) rate negotiated. Rates covering a future MGA fiscal year - the unallowable costs will be removed from the indirect (F&A) cost pools and the rate adjusted appropriately. Rates covering a prior period/year - the Federal share of the unallowable costs will be computed for each year/period involved and a cash refund(s) will be made to the Federal Government. Rates covering the current period/year- either a rate adjustment or a refund, as described in the two previous paragraphs of this section, must be required by the cognizant agency, who negotiated the rate, for indirect costs. The choice of method used is at the discretion of the cognizant agency based on what would be the "most practical".

The calculation, of the amount or proportion, of unallowable costs included in each year's rate will be based on the assumption that the same amount or proportion of unallowable costs included in the base year proposal and used to establish the rate was consistent.

Classification of Costs: There is no universal rule for classifying certain costs as either direct or indirect (F&A) under every accounting system. A cost may be direct with respect to some specific service or function, but indirect with respect to Federal awards or other final cost objective. Therefore, it is essential that each item of cost incurred for the same purpose be treated consistently in like circumstances either as a direct or an indirect (F&A) cost to avoid possible double charging of awards (federal, state, local and private). Ref. 2 CFR 200.412

MGA currently uses a Federally negotiated indirect cost rate, where applicable. MGA may also apply, from time to time, this same rate to awards (state, local and private) as allowable during the proposal, budgeting and negotiation phase of a contract or grant. This rate may also be negotiated at a lower rate, at the discretion of the Vice President Finance, Business & Operations, and/or Provost of MGA.

Direct Costs: Direct costs are those costs/expenditures that can be identified specifically associated with a particular award (federal, state, local or private grant or contract) or can be directly allocated to the activities of the award relatively easily with a high degree of accuracy. Costs incurred for the same purpose must be treated consistently as either direct or indirect (F&A) costs. Ref. 2 CFR 200.413            :

Application to Award. Identification of the expense to the award rather than the nature of the expense is the determining factor between a direct and indirect (F&A) cost for federal awards.

Salaries of administrative and clerical staff may be treated as either a direct or federal indirect (F&A) cost. Direct charging of these personnel costs is appropriate when the following conditions are met:

o  administrative or clerical services directly serve the project or activity

o  individuals are specifically identified in the project or activity

o  personnel positions are specifically included in the program budget or in the case of a federal award and prior written approval has been obtained of the Federal awarding agency; and

o  the costs are also not recovered as indirect costs (federal awards).

Minor Cost Items. Any direct cost of a minor amount may be treated as an indirect (F&A) cost for reasons of practicality when the cost in accounting is treated consistently to all Federal and non-Federal cost objectives.

Non-allowable costs. Certain activity costs are not allowable as a direct charge to Federal awards. However, they nonetheless must be treated as direct costs in determining indirect (F&A) cost rates and be allocated their equitable share of MGA's indirect costs, if they represent activities which,

o  include salaries of personnel,

o  occupy space, and

o  benefit from MGA's indirect (F&A) cost.

Indirect Costs: For major IHEs, for which MGA is not as defined in Appendix Ill to 2 CFR Part 200, indirect (F&A) costs are classified within two broad categories: "Facilities" and "Administration". “Facilities” is defined as depreciation on buildings, equipment and capital improvements, interest on debt associated with certain buildings and operations and maintenance expenses. "Administration" is defined as general administration and general expenses such as director's office, accounting services, personnel and other types of expenditures not listed under Facilities. (Ref. 2 CFR 200.414) The following sections pertain to MGA and will be referenced and followed for Federal awards, as applicable:

Acceptance of Negotiated Indirect Cost Rates: Negotiated rates must be accepted by all Federal awarding agencies. However, a federal awarding agency may use a different rate from that negotiated. Refer to Funding Opportunity Notices relating to policies relating to indirect cost rate reimbursement, matching or cost share. Ref. 2 CFR 200.306

Institutions of Higher Education - Special Considerations: Costs incurred by states and local governments. 2 CFR 200.418: In regard to Federal awards, and will be consistently applied to the State, Local and Private awards of MGA, costs paid or incurred by the state or local government on behalf of its IHEs for fringe benefit programs, such as pensions/retirement costs, FICA, health care, etc. and any other costs specifically incurred on behalf of, and in direct benefit to the IHEs, are allowable costs of such IHEs whether or not these costs are recorded in the accounting records of the institutions, subject to the following:

o  the costs meet the (Federal) requirements of sections 2 CFR 200.402 Composition of Costs through 200.411 Adjustment of previously negotiated indirect (F&A) cost rates containing unallowable costs,

o  the costs are properly supported by approved cost allocation plans in accordance with applicable Federal cost accounting principles, and

o  the costs are not otherwise borne directly or indirectly by the Federal Government or another awarding entity.

An IHE that receives aggregate Federal awards totaling $50 million or more in Federal awards subject to this section in its most recently complete fiscal year must comply with the Cost Accounting Standards Board's cost accounting standards located at 48 CFR 9905.501, 9905.502, 9905.505, and 9905.506. MGA is not currently receiving sufficient awards sufficient to meet this condition of the Federal awarding agencies. However, when MGA's Federal awards meet this threshold MGA will be compliant as required, and MGA will disclose our accounting practices by filing: a Disclosure Statement (DS-2) when we receive aggregate Federal awards totaling $50 million or more during our most recently completed fiscal year. The Disclosure Statement (DS-2) is located in Appendix Ill to Part 200 -Indirect (F&A) Costs Identification and Assignment, and Rate Determination for Institutions of Higher Education (IHEs) with the cognizant agency for indirect costs.

This section provides principles and guidance to be applied in establishing the allowability of certain items involved in determining cost regarding Federal awards, and State, Local and Private awards of MGA, as they may be applicable.

Basic Considerations: These principles apply whether a particular item of cost is properly treated as direct cost or an indirect (F&A) cost. To determine if a cost is allowable, in each case, the decision should be based on the treatment provided for similar or related items of cost and based on the principles described in 2 CFR 200.402 Composition of Costs through section 200.411 Adjustment of previously negotiated Indirect (F&A) Cost rates containing unallowable costs. The criteria outlined in 2 CFR200.403 Factors affecting allowability of costs must be applied in determining allowability.

Should there be a case of a discrepancy between the provisions (terms and conditions) of a specific Federal award and the provisions cited in the regulation below, the Federal award governs. However, at MGA it is prudent to contact the Program Officer assigned to the award in question to discuss and confirm the allowability of a particular cost when there appears to be a discrepancy between the cost principles and the award document.

General Provisions for Selected Items of Cost: There are several sub-sections in 2 CFR200.420 - 200.475 of the Federal cost principles pertaining to various specific types of Costs/Expenditures associated with an award. At MGA it is the Project Director's/Principal investigator’s responsibility to become familiar with and refer to these provisions that outline the types of costs that may or may not be considered an allowable use of federal funds before any expense is initiated or authorized for which they are responsible. The approved Program Budget for which funds have been awarded details what was proposed as necessary expenditures for the grant/contract. It also provides a time frame in which the Federal Award Agency is anticipating certain expenditures. The budget also outlines if any indirect costs are allowable and at what rate.

There are some very specific cost categories that cannot be charged to federal awards, nor to MGA's State, Local and Private awards, as either direct or indirect costs and are considered "Unallowable".

Although this list is not all inclusive, please note a few examples of these costs:

o  Alcoholic beverages (2 CFR 200.423)

o  Advertising, certain types (2 CFR 200.421)

o  Entertainment/amusement (2 CFR 200.438)

o  Bad debts (2 CFR 200.426)

o  Contributions and donations (2 CFR 200.434)

o  Fines and penalties (2 CFR 200.441)

Expenditure of award (grant and contract) funds: Whether the award is Federal, State, Local or Private, all expenditure of funds must be allocated in the approved Program Budget. Then, expenses must be initiated, in compliance with Federal cost requirements and 2 CFR 200, using:

o  Goods and Services: The State of Georgia Purchasing Rules and Regulations purchase procedures for the purchase. This includes P.O.'s, Purchase Cards, and direct payments.

o  Personnel Requests: Personnel requests are processed using MGA's Personnel Action Request Form (PARF) to be submitted to the Budget Office.

o  Personnel Supplemental Payments: Submit Time & Effort reports and/or Memorandum request for supplemental payments or stipend payments for services rendered on behalf of the grant or contracts activities to the Office of Finance.

o  Travel Payments: All travel reimbursements are processed using USG's/MGA's online submission system in Peoplesoft Financials where payments are analyzed per State of Georgia travel guidelines for allowability by the Finance Office - Travel Accounting personnel for payment.

 o  Contract Services/Subawards: A request for contract/consultant services or a subaward will be initiated with the Office of Finance to be coordinated with the Procurement/Purchasing Office and/or Legal Office, as necessary.

All these processes and procedures require the initiation, authorization, and approval by several different individuals with various authority levels and departments to maintain adequate cross controls and prevent any undue conflict of interests in expense and purchase decisions. Under no circumstance will an expenditure whether that be personnel hiring action or payment, purchase request, travel authorization and reimbursement or another type of cost be processed without the approval signatures of the Principal Investigator/Project Director and the Director of Research & Sponsored Projects assigned to oversee the award. The Office of Finance will assign the Financial Account - Chart String to be charged and confirm that budget funds are available, and the expense is authorized and allowable per program guidelines, the award's Terms and Conditions, and Federal financial principles in 2 CFR 200.400.

This guidance may be added to or edited as necessary to maintain Â鶹ÊÓƵ's (MGA) compliance with Federal and or State award regulations and guidelines.

MGA strongly encourages all faculty and staff to actively seek external funding for their research, creative projects, and outreach efforts. When such funding includes provisions for supporting faculty salaries, the first priority is to allocate it toward summer pay, as stipulated by BOR Policy 8.3.12.3, which limits summer pay to no more than 33-⅓% of regular academic year salary. In line with federal regulations (200.430(h)(2)), it is essential to maintain consistency across externally funded awards, ensuring that academic year salary charged does not exceed the proportionate share of the Institutional Base Salary (IBS) for that period. This principle applies universally to all faculty members, regardless of whether they hold 12 or 10-month contracts. IBS is defined as the annual compensation provided by an Institution of Higher Education (IHE) for an individual's appointment, irrespective of their allocation to research, teaching, administration, or other duties. To reiterate, during the regular contract periods, faculty or full-time staff are not eligible to receive additional pay beyond their IBS/annual salary from external funding sources.

In the academic year, external funding may lead to savings in faculty and staff salaries within their home department. Faculty members have the option to utilize these salary savings for course buyouts (where applicable) or for reallocating resources to support allowable expenses such as travel, supplies, and minor equipment. Both of these alternatives require written approval from the department chair and Dean at the time of application.

Please note that stipend payments to faculty members for additional work conducted during the academic year for the University System of Georgia (USG) are exempt from the aforementioned policy. The following information outlines more specific details of grant-award compensation.

Compensation for personal services is governed by the Federal Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards CFR200. Section 200.43 specifically addresses Compensation - Personal Services. Compensation includes wages, salaries, stipends and extra service pay, and fringe benefits. It requires that compensation: 

1. Is reasonable for services rendered and conforms to the established written policy of the institution consistently applied to both federal and non-federal activities;
2. Follows an appointment made in accordance with policies and/or guidelines and meets the requirements of the federal statute; and
3. Is determined and supported as provided for "Standards for Documentation of Personal Expenses."

"Reasonable" when working on federal or non-federal projects means it is consistent with "that paid for similar work in other activities of the institution." If it is necessary to seek someone, for a project, with qualifications not available within the institution, a reasonable compensation rate would be comparable to that paid for similar work in the labor market in which the institution competes for similar employees.

Additionally, all personnel involved in a sponsored project effort must be paid in accordance with university and state guidelines. Budgeted amounts contained in a proposal do not in any way supersede University policies. The salary and wage categories and job or position classifications on sponsored projects must be congruent with those established for other employees of the University. Salary rates increments are, therefore, subject to the regulations applied to all other University employees of the same classification. Exceptions may result in audit disallowances.

***Per the University of Georgia (USG), grant funds should not be used as a source for additional pay but instead to "buyout" the effort of researchers, i.e. course release time.

However, there may be specific exceptions depending on the category of the employee.

Faculty -  Ordinarily, federal and non-federal awards may not be used to augment the total salary or salary rate of faculty members; however, an exception may exist if a faculty member cannot be released from their teaching duties, but still performs grant-related research. In this case the faculty member would be eligible for extra service pay, if permitted by institutional policy, allowed by the grant, included in the budget, and approved in advance by the granting agency.

Another exception would be extra compensation during the summer when the faculty member is not teaching. Typically, charges for work performed during periods not included in the "Base Salary Period" are allowable if included in the grant budget and at a rate not to exceed the IBS rate (see definitions). Payment calculation is subject to grantor guidelines. Compensation for summer grant/contract activities are considered in the MGA Summer faculty compensation limitation of 33 1/3% of IBS rate.

Administrative Faculty (12 month) - Administrative faculty may have the opportunity to participate in sponsored projects. The assignment to be performed must be at a time totally separate and apart from the employee's normal and usual working hours and will not interfere with the performance of regularly assigned duties. In rare circumstances an administrative faculty member may receive additional compensation if pre-approved in the grant. In this situation, supplemental pay for both exempt and nonexempt staff utilizing restricted grant funds must be an allowable cost based on the  guidelines of the grant agreement at a rate not to exceed the IBS and must be consistent with MGA's policies and procedures as outlined within this guidance.

Part-time Faculty - Research/grant work performed by faculty with part-time status will be at a rate not to exceed that regularly paid for part-time assignments (IBS rate).

Non-Faculty (Staff Employees) - Occasionally, grant-funded initiatives may require additional support from staff to perform certain tasks and/or activities. The assignment to be performed must be at a time totally separate and apart from the employee's normal and usual working hours and will not interfere with the performance of regularly assigned duties. In this situation, supplemental pay for both exempt and nonexempt staff utilizing restricted grant funds must be an allowable cost based on the guidelines of the grant agreement at a rate not to exceed the IBS and must be consistent with MGA's policies and procedures as outlined within this guidance.

Per the USG, under no circumstances should an employee receive extra compensation for a task while receiving normal compensation for the same time. Therefore, an employee must take leave time to receive extra compensation for grant/contract work during the same time period.

The Office of Research & Sponsored Projects (ORSP) provides support for research and sponsored activities, emphasizing the avoidance of conflicts, bias, and foreign influence. Principal Investigators/Program Directors (PI/PDs) and Senior/Key Personnel are required to maintain a high level of transparency regarding their personal financial matters, which includes those of their spouse and dependent children and disclose any potential conflicts of interest to ORSP. Furthermore, they must be forthcoming about any financial support, affiliations with international institutions, and available resources. These implementation procedures apply to research, educational, or service projects funded by federal agencies either directly to MGA or through another institution or organization by a subaward. It is crucial to keep this information up to date throughout the duration of an award. Those individuals who meet the definition of Investigator on a grant award, will be responsible for complying with the requirements set for in MGA's FCOI document. Training concerning conflicts of interest are required for investigators through ORSP and through .

No PI/PD, department head, faculty member, or staff of MGA should sign a sponsored project proposal, grant, or contract on behalf of the University. The sole authority for signing these documents rests with the university's authorized official, specifically the President and those individuals to whom this authority has been delegated. (MGA Policy 1.1.3 Institutional Signature Authority for Agreements). This policy does not prohibit PI/PD's, department heads, and other individuals from signing internal processing documents or the proposal or award, as may be required by the funding agency. However, the proposal or award document must also bear the signature of the authorized official. All sponsored project documents, including but not limited to proposals, grants, and contracts, that necessitate the signature of the authorized official must be processed through ORSP.

For an agreement to hold validity and enforceability, it is crucial that it be signed by an individual with specific statutory delegation to sign on behalf of the university. Consequently, if a sponsored program proposal or award lacks the signature of the authorized official, the agreement is rendered void and unenforceable.

This emphasis on appropriate signatory authority serves two primary objectives:
1. Safeguarding both the University and individual university employees against potential legal liabilities.
2. Ensuring compliance with university, system, state, federal, and private regulations and requirements while conducting research and providing services that are inherent in sponsored programs.

Transferring to another institution: If a PI/PD plans to move to a different institution and wants to continue their sponsored projects there, certain steps should be taken. The transfer of a grant or contract can only proceed with the agreement of an authorized representative at the new institution. There may be cases where the university decides to retain the projects and designate an alternative PI/PD, but this necessitates approval from the sponsoring agency. It is important to note that not all sponsors automatically grant such transfers. Any arrangements for transferring a grant should be coordinated through ORSP, which will then follow the procedures outlined by the agency to release the award.

Transferring from another institution: If a faculty member is joining MGA from another institution and wishes to transfer a sponsored project, the approval of the home institution and the sponsoring agency is required. Before submitting the transfer request to the sponsoring agency, the request should go through an internal approval process at MGA administered by ORSP.