Can I hire my Teaching Assistant/Administrative Assistant/AU Colleague as a consultant on my sponsored project/program?
Faculty or staff members who serve as consultants on the sponsored projects of other faculty members receive no compensation above full-time base salary. When consultation is across teaching unit lines and the faculty or staff consultant performs the work in addition to the regular work load, compensation above base salary must be specifically provided for in the agreement with the sponsor. Individual arrangements must be approved in writing by the teaching unit head, the college dean, the Dean of Academic Affairs (for faculty), or the Director of Human Resources (for staff), and the sponsor.
Since federal regulations governing supplementary compensation are very restrictive, the Principal Investigator/Project Director (PI/PD) should consult the assigned Office of Sponsored Programs (OSP) staff member before entering into any commitments on inter-unit consulting. A faculty member with a full-time appointment as a PI/PD cannot function as an inter-unit consultant.
Changes in sponsored award budgets are generally guided by the terms and conditions of the sponsored award. Some sponsors allow insignificant re-budget changes to be done without their approval. In this case, the PI/PD is free to re-budget accordingly. When the PI/PD has the ability to re-budget without prior approval, a revised Project Brief is not required.
Significant budget changes from one budget category/line item to another generally require the sponsoring agency's approval. As a rule of thumb, significant re-budgeting is defined as a transfer of 25% or more from one budget category/line item to another, however, "significant re-budget changes" are often defined in the terms and conditions of the sponsored award. OSP will contact and obtain the sponsor's approval prior to authorizing significant re-budget changes.
In those instances where re-budgeting requests can be submitted through a sponsor's post-award management system (e.g. NSF Fastlane), no additional paperwork is necessary. In all other instances, a letter will need to be drafted by the PI/PD that explains the re-budget request and the effect it will have on the project. A revised budget will need to accompany the letter. This letter should be signed by the PI/PD and counter-signed by OSP or the Vice Provost of Research/Dean of Graduate Studies. OSP will forward the request to the sponsor for action when significant re-budgeting changes are approved by the sponsor. OSP will create and distribute a revised Project Brief.
If you are unsure whether or not re-budgeting is allowed under a sponsored project/program, please contact your assigned OSP staff member for guidance.
Consultants provide expertise from outside the University. Consultants can either be an individual or an organization that provides goods and services within normal business operations. Consultants provide goods and services that are ancillary to the operation of the sponsored program. Consultants may not be subject to all compliance requirements. Consultant rates may be subject to approval by the sponsor. Rates should be consistent with rates of other consultants providing similar services.
Once the proposal is awarded, the consultant will enter into a consultant agreement with American University.
Unlike consultants, subcontractors are responsible for performing a substantive portion of the proposed project/program. If 50% or more of the requested funding will go to a subcontractor, a justification should be prepared by the PI/PD and included on the routing form. The proposed subcontractor should provide a scope of work and a detailed budget for its portion of the proposed sponsored project/program.
Click here to view the differences between a consultant and a subcontractor.
Travel can be arranged and paid directly by the traveler, with subsequent reimbursement.
The University prefers that transportation tickets (plane, train, bus) be purchased through the official travel agencies of American University (Travel-Plus, Marathon Travel, McNair Travel or WorldTek). Provide the travel agent with your name, department, and budget account number. You can request the travel reservation to be charged directly to your account, or use the University credit card. You can view the official travel policy here.
Some costs cannot be charged to a sponsored project/program. For example, the following costs cannot be charged to a project funded by a federal agency: contingency funds or reserves, bad debts, fines and penalties, entertainment (which includes alcohol) costs, interest, fundraising, and investment management costs, losses on other research agreements, including cost overruns, costs for public information services, and alumni or public relations costs. Costs or expenses for projects sponsored by a non-federal agency/source are determined by the terms and conditions of the award. OSP can provide guidance for questions related to allowability on certain costs.
Financial reports are prepared by Grants and Contracts Accounting (GCA) when required. GCA uses the guidelines supplied by the sponsor to complete such reports. Completion of financial reports is done according to the schedule requirements as required by the sponsor.
The Principal Investigator/Project Director prepares the technical reports. Most sponsored projects/programs require submission of both interim reports and a final report. To assist in ensuring reports are submitted timely, the Project Brief will indicate due dates for reports, and a reminder notice will be sent to the PI/PD referencing the project end date.
Failure to submit reports by the deadline date as specified by the sponsored award may not only adversely affect the PI/PDs (and the University's) ability to receive further support from the sponsor, but may result in a loss of payment for costs already incurred. All PIs/PDs with active grants are required to send copies of all technical reports to the office of their Dean or executive unit head as well as to the Office of Sponsored Programs.
Some agencies require technical reports to be countersigned by an Institutional Official and submitted electronically. The OSP Director or Vice Provost of Research/Dean of Graduate Studies will countersign reports when a signature by an Institutional Official is required and when sponsors require an Institutional Official to submit the technical report.
Sponsor policies vary regarding the handling of unspent funds at the end of a budget period. The terms and conditions of the sponsored award generally specify the treatment of unspent funds. When the terms require prior approval to carry over funds from one budget period to the next, the PI/PD is required to submit a written request/justification to OSP. OSP will then submit the carry over request to the sponsor. Most sponsors require the request to include an explanation of why such unspent funds exist and how they will be used during the next budget period. A revised project brief will be created by OSP upon the sponsor’s approval, and GCA will carry over funds from one budget period to the next. A revised project brief will not be created by OSP when the award terms and conditions authorize funds to be carried over without the sponsor’s approval.
Approximately 90 days before the expiration of a project, GCA will send e-mail notices to the PI/PD and other members of the project team to remind them of the expected end date of a sponsored award. OSP will then follow up with the PI/PD regarding the project status. Depending on the sponsor and the terms of the award, the PI/PD will confirm the status as one of the following three:
Close as scheduled (PI/PD will develop all technical and/or final reports if required, and GCA will prepare and submit all of the required financial reports)
Request a no-cost extension
Submit a proposal to request additional funding
OSP handles all necessary negotiations regarding property disposal or transfer, while GCA prepares the final financial report including all charges to date. The PI/PD is responsible for notifying GCA of pending financial charges so that appropriate arrangements can be made for billing the sponsor. Charges received after the financial report has been submitted to the sponsor will be charged to the PI/PD’s teaching unit.
OSP will initiate a project brief advising of the award close-out.
The purpose of a no-cost extension is to request an extension of time beyond the current ending date of an award. Occasionally, the completion of a sponsored project/program may require more time to complete. If no additional funds are necessary to complete a sponsored project/program during the proposed extension period, a no-cost extension may be requested from the sponsor. PIs/PDs seeking a no-cost extension should notify OSP at least 45-60 days (or another advanced period as required by the sponsor) prior the project/program expiration date.
When seeking a no-cost extension, the PI/PD is required to provide written justification for the request by completing the No-Cost Extension Request Form. The justification should contain all of the components (i.e. the reason for needing a no-cost extension/an account of award funds spent and unobligated to date, etc.) that are required by the sponsor. OSP will advise the PI of all the components that must be within the written request as well as submit the request on behalf of the PI/PD and American University.
As a general guideline, the following are minimum requirements for requesting a no-cost extension:
The project is not completed and additional time is needed to complete the project;
There are legitimate reasons for delays or reasons why the project has not been completed as expected and a reasonable plan for completing the project.
The University is subject to audit by sponsors for specific programs and is also audited annually for its administration of sponsored programs in accordance with the OMB Circular A-133. Auditors representing sponsors will periodically examine the University's records for the purposes of:
- determining whether contract or grant funds were used in accordance with applicable laws, regulations, and procedures
- making objective appraisals of the financial accounting system and administrative controls to ensure that programs are being charged with appropriate amounts
- determining the accuracy of the financial reports and records
Documentation of expenditures that includes original receipts (when required) is a requirement for the audit process. Grants and Contracts Accounting, with assistance from OSP, coordinates all activities with sponsors' auditors. Principal Investigators/Project Directors are required to be available during the audit process.