Research

Research srodriguez31 Fri, 05/11/2012 - 14:56

Sponsored Programs Policies

Sponsored Programs Policies abruneau3 Fri, 10/18/2013 - 11:33

For additional information on Georgia Tech's Sponsored Programs Policies:

1.0 Overview

1.0 Overview s1polics Wed, 04/20/2016 - 10:29

The Georgia Tech Research Corporation (GTRC), a non-profit educational and research corporation affiliated with Georgia Institute of Technology, serves as the contracting entity for Resident Instruction colleges of Georgia Tech. Georgia Tech Applied Research Corporation (GTARC), also a non-profit research and education affiliate of Georgia Tech, acts as the contracting entity for the Georgia Tech Research Institute. Both corporations serve Georgia Tech in the financial administration of externally funded research programs and related research activities. All proposals for external funding must be routed through the Office of Sponsored Programs (OSP) or the Office of Industry Engagement (IE) for official submission to the sponsoring agency in the name of GTRC or GTARC as appropriate.

OSP verifies the proposed budget and handles all contractual or grant administrative matters relating to the submission and subsequent funding of proposals. OSP or Industry Engagement is responsible for negotiating the terms of research and related contracts. GTRC or GTARC is the recipient of the award and the contracting party while research is performed, per formal agreement, by Georgia Institute of Technology faculty, staff, and students under the direction of the Principal Investigator who shall be a member of the General Faculty and under the oversight and control of the school chair and dean, laboratory director, or other designated senior administrative official of the units in which the research is conducted.

Additional Resources:

Faculty Handbook Part 31: Office of Sponsored Programs

 

1.1 Offices Involved with Sponsored Projects

1.1 Offices Involved with Sponsored Projects s1polics Wed, 04/20/2016 - 10:33

 

Throughout the life-cycle of research projects, a number of Institute offices and affiliated organizations that serve as contracting entities for the institute have the responsibility for stewardship of funds, resources, results, and intellectual property.

 

1.1.1 Office of Sponsored Programs

1.1.1 Office of Sponsored Programs s1polics Wed, 04/20/2016 - 10:43

 

The Office of Sponsored Programs (OSP) provides progressive and responsive assistance in several areas of research administration including specialized educational, informational, and technological support to research administrators and faculty.

Additional Resources: 

Office of Sponsored Programs

1.1.2 Grants and Contracts Accounting

1.1.2 Grants and Contracts Accounting s1polics Wed, 04/20/2016 - 11:01

The Office of Grants & Contracts Accounting is part of Financial Services within the Division of Institute Planning and Resource Management.

 

Additional Resources:
http://grants.gatech.edu/

1.1.3 Georgia Tech Research Corporation

1.1.3 Georgia Tech Research Corporation s1polics Wed, 04/20/2016 - 11:03

The Georgia Tech Research Corporation (GTRC) advances research and technological development at Georgia Tech as it continually seeks to advance society and the global competitiveness of Georgia and the nation.

Additional Resources:
http://www.gtrc.gatech.edu/

1.1.4 Georgia Tech Applied Research Corporation

1.1.4 Georgia Tech Applied Research Corporation s1polics Wed, 04/20/2016 - 11:04

The mission of the Georgia Tech Applied Research Corporation (GTARC) is to provide efficient and effective contracting, grant, and research administration services for the Georgia Tech Research Institute (GTRI), a non-profit research arm of the Georgia Institute of Technology.

Additional Resources:
http://www.gtarc.gatech.edu/

1.1.5 Office of Research Integrity Assurance

1.1.5 Office of Research Integrity Assurance s1polics Wed, 04/20/2016 - 11:05

The Office of Research Integrity Assurance works with faculty oversight committees and boards to promote the ethical and responsible conduct of research and to ensure compliance with regulatory requirements relating to research involving human and vertebrate animal subjects, and rDNA.

Additional Resources:
http://researchintegrity.gatech.edu/

1.1.6 Industry Engagement

1.1.6 Industry Engagement s1polics Wed, 04/20/2016 - 11:07

At Industry Engagement, we work together with campus innovators and industry partners to move new technologies and discoveries out of Georgia Tech and into the mainstream of the U.S. economy. As a public university, Georgia Tech has a responsibility to ensure its research results benefit the general public.

Additional Resources:
http://industry.gatech.edu/

1.1.7 Office of Legal Affairs

1.1.7 Office of Legal Affairs s1polics Wed, 04/20/2016 - 11:08

The Office of Legal Affairs (OLA) supports the academic and research mission of the Georgia Institute of Technology through development of solutions designed to minimize Georgia Tech's legal exposure, while advancing the goals and programs of Georgia Tech within the bounds of the law.

Additional Resources:
http://legal.gatech.edu/

1.1.8 GT Global and International Affiliated Organizations

1.1.8 GT Global and International Affiliated Organizations s1polics Wed, 04/20/2016 - 11:09

Georgia Tech's vision is to define the technological research university of the 21st century and educate the leaders of a technologically driven world. In a global context.

Additional Resources:
http://global.gatech.edu/

1.1.9 Office of Conflict of Interest Management

1.1.9 Office of Conflict of Interest Management s1polics Wed, 04/20/2016 - 11:10

The Conflict of Interest Management Office, in conjunction with the faculty-led COI Review Committee, is charged with promoting objectivity throughout the Institute’s research enterprise by effectively managing conflicts of interest, which are the natural outgrowth of successful research, collaboration, and commercialization efforts.

The Office offers compliance training and its members are always available to answer your questions. Please contact us if you would like to schedule a training session or if you have any COI-related questions: http://coi.research.gatech.edu/

1.2 Signature Authority

1.2 Signature Authority s1polics Wed, 04/20/2016 - 10:44

The Board of Regents for the State of Georgia delegates signature authority to the President of the Institute who then delegates in writing that authority to other individuals and offices.

Signature authorities for GTRC and GTARC are delegated by their respective boards of trustees.

Only individuals with specific delegations of authority may sign any documents for Georgia Tech, GTRC, or GTARC in any matter related to research. Consult the Office of Sponsored Programs (OSP), Industry Engagement (IE), the Office of Research Integrity Assurance (ORIA), or the Office of Legal Affairs for information or to obtain signatures on proposals, agreements, or other documents.

See also Policy 2.4

Additional Resources

Office of Sponsored Programs
Industry Engagement
Office of Research Integrity Assurance
Office of Legal Affairs

 

2.0 Pre-award Project Management and Proposal Development

2.0 Pre-award Project Management and Proposal Development s1polics Wed, 04/20/2016 - 11:11

2.1 Principal Investigator Policy

2.1 Principal Investigator Policy
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 11:26
Policy No
RESEARCH 2.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is the policy of the Institute that the Project Director or Principal Investigator must hold a title of Academic Faculty or Research Faculty. Members of the Academic Faculty or Research Faculty 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. Externally funded sponsored projects at Georgia Tech are under the scholarly and administrative control of a member of the faculty, the Project Director or Principal Investigator (PD/PI or Co-PDs/PIs), who is responsible for the overall design, conduct and reporting of the research or other activity. When a sponsor recognizes Co-principal Investigators, one of them must be designated as the “Corresponding Principal Investigator” who shall be the individual who assumes institutional responsibility for the overall project and with whom the Office of Sponsored Programs will communicate for administrative matters.

Scope

This policy applies to all Georgia Tech faculty and staff members.


Definitions:

PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.

Policy History
Revision Date Author Description
12-30-2013 OSP Rev 1.0

2.1.1 PI/PD Eligibility

2.1.1 PI/PD Eligibility
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 11:36
Policy No
RESEARCH 2.1.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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/

Scope

This policy applies to all Georgia Tech faculty and staff members.

 

Policy Terms
PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.
Responsibilities

The PD/PI is responsible for the design, conduct, and report – both scientific or technical and fiscal – of the research. In addition they are responsible for any additional regulatory and review requirements.

Policy History
Revision Date Author Description
09-20-2021 OSP Editorial updates
12-30-2013 OSP Rev 1.0

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2.1.2 PI/PD Responsibilities

2.1.2 PI/PD Responsibilities
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 11:51
Policy No
RESEARCH 2.1.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Definitions:

PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.
Enforcement

Optional: To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-30-2013 OSP Rev 1.0

2.1.3 Transitional PI/PD

2.1.3 Transitional PI/PD
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 11:56
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty, staff, and visitors.

Definitions:

PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.
 

 

Policy History
Revision Date Author Description
12-30-2013 OSP Rev 1.0

2.1.5 Change of PI/PD

2.1.5 Change of PI/PD
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 12:20
Policy No
RESEARCH 2.1.5
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty, staff.

Definitions:

PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.
Procedures
Change of PD/PI
Initiating a Change To initiate a change, the PD/PI or, if unavailable, the School or Lab should inform OSP of the request for a change in the PD/PI on a project. The PD/PI’s School or Lab must concur in the recommendation of a new PD/PI. OSP will submit the request to the sponsor, if required, and will update the contract file after approval has been obtained. The curriculum vitae of the replacement PD/PI should accompany the request. In the event a sponsor objects to the nominated replacement, OSP will contact the requesting campus department.
Federal Sponsoring Agencies Federal sponsoring agencies require, at a minimum, advance notification if the PD/PI is absent or relinquishes active direction of a project for a period of three continuous months or longer, plans a significant change in effort, or plans to transfer to another institution. Repeated absences of less than 90 continuous days during a year represent a significant change in effort. The awarding agency must approve a replacement PD/PI who is requested by the awardee institution; departing PD/PIs often suggest or recommend such replacements. Agencies reserve the right to terminate a grant if approval for a leave of absence has not been sought or if the replacement PD/PI is not acceptable.

 

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.1.6 Minimum Effort

2.1.6 Minimum Effort
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 12:29
Policy No
RESEARCH 2.1.6
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Definitions:

PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.
Ongoing Basis Ongoing basis means per budget year over the life of the project.
Procedures
Reporting Minimum Effort
Committed Effort Budgeting 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. See information on thePlan Confirmation System.
Minimum Effort Training Video PD/PIs should watch the Minimum Effort Training Video, for more information on minimum effort requirements
 
Enforcement

Optional: To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.1.7 Maximum Effort

2.1.7 Maximum Effort
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 12:33
Policy No
RESEARCH 2.1.7
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Definitions:

PD/PI Project Director/Principal Investigator, individual responsible for the overall design, conduct and reporting of the research or other externally funded sponsored activity.
Enforcement

Optional: To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0
11-20-2014 OSP Rev 2.0

2.2 Funding Mechanisms

2.2 Funding Mechanisms
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 12:37
Policy No
RESEARCH 2.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is the policy of Georgia Tech that funding for research and other sponsored activities be awarded to the legal entity designated by the Institute as follows:

GTRC/GTARC

  • Grants, contracts, and cooperative agreements with U.S. government agencies, state and local governments, and municipalities
  • Grants and contracts with foreign governments
  • Industry contracts
  • Grants with restrictions, intellectual property provisions or deliverables

Georgia Tech Foundation (GTF)

  • Philanthropic gifts, donations, bequests, endowments
  • Unrestricted grants from industry or Foundations

Georgia Tech (GT)

  • IPAs
  • Fellowships and scholarships
Scope

This policy applies to all Georgia Tech faculty and staff members.

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.2.1 Policy on Distinguishing Gift vs. Sponsored Agreements in External Funding

2.2.1 Policy on Distinguishing Gift vs. Sponsored Agreements in External Funding
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 12:52
Policy No
RESEARCH 2.2.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures

The terms gifts and sponsored agreements (grants, contracts or cooperative agreements) are often used interchangeably, however it is important that categorization of external funding received be undertaken with care and concern with the considerations listed below.

5.1 Sponsored Agreements
Sponsored projects are established when funds are awarded to the Institute by external sources in support of research, instruction, training, or services under an agreement that includes any one of the following:
  • a set of terms and conditions that binds the Institute and requires endorsement.
  • an obligation by the investigator to a line of scholarly or scientific inquiry that typically follows a plan, provides for orderly testing or evaluation, or seeks to meet stated performance goals.
  • an understanding of how funds will be used (typically includes a detailed budget that identifies expenses by activity, function, or project period).
  • a requirement for fiscal accountability as evidenced by the submission of financial reports to the sponsor, an audit provision, or the return of unexpended funds at the conclusion of the project (if the contract type is cost reimbursement).
  • an obligation to report project results
  • disposition of tangible or intangible property resulting from the project. Examples of tangible property include equipment, records, technical reports, theses or dissertations. Intangible property includes rights in data, copyrights or inventions.
  • an imposition of legal or financial considerations such as indemnification or warranties

 

5.2 Gifts (via Development Office – Foundation Relations)
A gift is an unconditional, voluntary, non-reciprocal transfer of assets (including unconditional promises) from a private entity to a not-for-profit organization. The donor may have certain expectations but there cannot be any actual control over expenditure of funds or any quid pro quo. The donor may not benefit from the execution of the gift. Gift accounts are established when funds are received from outside sources that are for unrestricted use and are free of the constraints or obligations of sponsored projects as described above. Acceptance of a gift usually precludes any accounting and reporting by the Institute.

Terms:

  • In no instance should federal flow-through be considered a “gift.”
  • A gift does not change any research compliance obligations (protocol submissions) the PD/PI has in terms of their research. [See Section 3. for details]

If you have any questions regarding the above terms, please contact the Office of Sponsored Programs at 404.894.6937 or the Office of Foundation Relations at 404.894.2481.

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.2.2 Policy on Limited Submissions (Restricted Program)

2.2.2 Policy on Limited Submissions (Restricted Program)
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 13:34
Policy No
RESEARCH 2.2.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is the policy of Georgia Tech that it is the principal investigator's responsibility to review the solicitation they are applying for and notify the EVPR & OSP if s/he intends to make an application to a limited submission opportunity. A Limited Submission is a program in which a sponsor restricts the number of proposals the Institute may submit in response to an announcement. An internal screening process has been set up to select the candidate(s) who may submit a proposal to the sponsor which is administered by the Office of the Executive Vice President for Research. Principal Investigators/Directors must coordinate with the appropriate Contracting Officer in Sponsored Programs.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Definitions:

EVPR Executive Vice President for Research
OSP Office of Sponsored Programs
Limited Submission A program in which a sponsor restricts the number of proposals the Institute may submit in response to an announcement.
 
Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.2.3 Teaming Agreements

2.2.3 Teaming Agreements
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 13:37
Policy No
RESEARCH 2.2.3
Effective Date
Last Revised
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures

To establish a Teaming Agreement, the PD/PI must complete and sign a Teaming Agreement Routing and Analysis Form and submit the form to OSP to negotiate the terms of the Agreement.

Policy History
Revision Date Author Description
1-2-2014 OSP Rev 1.0

2.2.4 Interagency Personnel Act (IPA) Agreements

2.2.4 Interagency Personnel Act (IPA) Agreements
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 13:40
Policy No
RESEARCH 2.2.4
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures

After a Georgia Tech Department Head determines that it is appropriate to place an employee on an IPA, the Department Head will provide the Office of Human Resources (OHR) and the Office of Sponsored Programs (OSP) with all information regarding the terms of the assignment, such information includes a routing sheet, proposal, copy of the IPA Agreement and budget information.

The IPA Agreement will be negotiated and processed by OSP. Any terms in the Agreement relating to personnel administration should be reviewed and approved by OHR in advance of action being taken. The Agreement should describe responsibilities and obligations of all parties.

The Agreement shall be signed on behalf of Georgia Tech, The Federal Agency and the IPA Participant.

Federal Appropriations are available to pay or reimburse, a federal, state or local government employee in accordance with the provisions of the IPA Act. An IPA Proposal or Agreement containing any cost recovery not specifically authorized by the IPA Act or IPA Regulations will not be processed without the prior written approval of Legal Counsel for the Federal Agency receiving the IPA assignee. The Georgia Tech Office of Legal Affairs will obtain the necessary written approval from the Federal Agency’s legal counsel.

Any exceptions to this Policy or Procedure must be approved by the Provost in advance writing.

Applicable Rules and Regulations:

Policy History
Revision Date Author Description
1-2-2014 OSP Rev 1.0

2.3 Budget Development

2.3 Budget Development s1polics Wed, 04/20/2016 - 13:45

It is the policy of Georgia Tech that the project budget provides a sponsor and the Institute with a complete financial picture of the proposed project and follow Cost Accounting Standards (CAS). Budgets are reviewed by the sponsor to verify if the costs are allowable, reasonable and necessary to carry out the proposed project, and if it conforms to the sponsor’s instructions and/or format. The cost elements of a budget must be those necessary to accomplish the proposed activity. Cost estimates of individual line items should be carefully calculated so that the requested funds are adequate, but not excessive. Click here for more information.

2.3.1 Tools

2.3.1 Tools s1polics Wed, 04/20/2016 - 13:54

Budget Example & Wizard

We have developed a wizard to assist you with preparing your budget. This wizard will also route your proposal, additionally your CO can assist you with the budget if you provide them access to the budget. Agency (Form) Budget(the budget example is a .pdf file and includes information on how to calculate F&A

Agency Specific Guidelines

Guidelines for Department of Defense Cost Proposals

Service Center Rates

View Service Center Rates (pdf)

2.3.2 Tuition Policy

2.3.2 Tuition Policy
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 13:59
Policy No
RESEARCH 2.3.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all schools and Graduate Research and Teaching Assistants.

Definitions:

GRA/GTA Graduate Research/Teaching Assistants
 
Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.3.3 Allowable Direct Costs

2.3.3 Allowable Direct Costs
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:07
Policy No
RESEARCH 2.3.3
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

All costs charged to any sponsored projects must meet the standards established in the Uniform Administrative Requirements (2 CFR 200) and must meet the following criteria to be allowed:

  • Reasonableness - at the time the costs was incurred, a prudent person would have made a similar decision (in relationship to the goods or services purchased and the amount paid).
  • Allocable to sponsored agreements - the goods or services are chargeable to sponsored research projects (either directly or indirectly) in relationship to the benefits received (an equitable allocation process).
  • Consistent treatment - the cost is consistently treated as either a direct cost or an F&A cost by all university departments.
Policy Statement

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.
Scope

This policy applies to all Georgia Tech Faculty and Staff.

Definition:

Direct Costs Costs 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.
 
Policy History
 
Revision Date Author Description
12-31-2013 OSP Rev 1.0
11-20-2014 OSP Rev 2.0

2.3.4 Unallowable Costs

2.3.4 Unallowable Costs
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:12
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
 
Revision Date Author Description
12-31-2013 OSP Rev 1.0
11-20-2014 OSP Rev 2.0

2.3.5 Subaward Considerations

2.3.5 Subaward Considerations
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:22
Policy No
RESEARCH 2.3.5
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Procedures
5.1 Specific Considerations
What is a Subagreement?

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.

Subrecipients vs. Vendors

It is not always clear when the pass-through entity should award federal funds to a subrecipient via a subcontract or subgrant, or a procurement contract to a vendor. A subrecipient is a state or local government, college, university or nonprofit organization that expends federal awards received from a pass-through entity to carry out a federal program. Under a subaward, a subrecipient generally has a specific scope of work to conduct in conjunction with the proposed research. The PI with the subaward is accountable for programmatic progress as well as for following federal guidelines.

In contrast, a vendor is a dealer, distributor, merchant or other seller providing goods or services that are necessary for conducting a federal program. These goods or services may be for an organization’s own use or for the use of beneficiaries of the federal program. They provide the service as part of their normal business operations. They provide similar services to many different purchasers

Under a procurement contract, a vendor provides goods or services that are auxiliary to the proposed research.

What constitutes a Consultant?

A Consultant Agreement is issued to either a company or to an individual who is clearly a bona fide consultant (expert advisor) who pursues this line of business for him/herself. The consultant is paid for his/her time at the fixed daily (or hourly) rate of compensation specified in an agreement. Consulting effort is usually limited to the term and the pay line is usually determined by a rate per day, which includes travel, expenses, and any other overhead. Consultants set their own hours, use their own equipment and materials, choose their work methods, and are responsible for paying taxes on their earnings as consultants. They will receive Tax Form 1099 from Georgia Tech. Furthermore a consultant’s effort is considered “work for hire” and therefore all intellectual property and copyrightable information produced is assigned to GTRC.

The primary difference is that a subcontract is almost invariably with another institution or with a company, and a consulting agreement is almost invariably with an individual who is not a Georgia Tech employee and has not been employed by Georgia Tech for at least 1 year.

Subagreements under Federal Contracts (Not Grants)

In order to establish a subrecipient relationship under federal contracts, the Federal Acquisition Regulation (FAR 35.009) states that “it is important that the contractor not subcontract technical or scientific work without the contracting officer’s advance knowledge.” The FAR goes on to state that “during the negotiation of a cost-reimbursement R & D contract, the contracting officer shall obtain complete information concerning the contractor’s plans for subcontracting any portion of the experimental, research, or development effort.” Typically approval is granted when a subrecipient is included in the proposal to the Government and an award is made based on that proposal. If a subrecipient relationship is not approved as part of a proposal submitted to the agency, written sponsor approval would be required before any unbudgeted subrecipient subcontract could be established.

 
Policy History
 
Revision Date Author Description
12-31-2013 OSP Rev 1.0

2.3.6 Facilities & Administrative Costs (F&A, Indirect Costs, or Overhead)

2.3.6 Facilities & Administrative Costs (F&A, Indirect Costs, or Overhead)
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:28
Policy No
RESEARCH 2.3.6
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

 

Types of Facilities & Administrative Rates
(a.k.a.: Overhead or Indirect Costs)
For current rates: www.osp.gatech.edu/rates/
Research Capped (Federal Grants and Non-DoD Contracts) Applies to all DoD contracts awarded before November 30, 1993, all Non-DoD Instruments, and all DoD Grants.
Research Uncapped (DoD Contracts & Industry Subcontracts under DoD) Applies only to DoD contracts awarded on or after November 30, 1993 in accordance with and under the authority of DFARS 231.303(1)
Industrial (Non-Federal, International, and Non-Georgia State and Local Government Entities) Applies to projects funded by for-profit entities and others that are not U.S. entities described in the General Exception.
Other Sponsored Applies to projects that benefit the public with activities other than research & development and instruction. Used for projects funded by the State and Local Government Entities in Georgia.
Instruction Applies to projects that primarily involve the delivery of educational programs; teaching.

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.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0
11-20-2014 OSP Rev 2.0
06-03-2015 OSP Rev 3.0

2.3.6.1 Other Sponsored Activities and State and Local Government Overhead Rates

2.3.6.1 Other Sponsored Activities and State and Local Government Overhead Rates
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:30
Policy No
RESEARCH 2.3.6.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Georgia Tech applies the Other Sponsored Activities (OSA) F&A rate to projects that benefit the public through activities other than research, development, or instruction. Other Sponsored Activities make available to the public various resources and special capabilities that exist within the institution. OMB Circular A-21, Cost Principles for Educational Institutions, describes Other Sponsored Activities to include ". . . . programs and projects financed by Federal and non-Federal agencies and organizations which involve the performance of work other than instruction and organized research. Examples of such programs and projects are health service projects, and community service programs…." These activities are intended to be available to, and to benefit, "individuals and groups," the "public" and "various sectors of the community." As a result, the application of the OSA Facilities & Administrative rate hinges upon a determination of who will benefit from the activities associated with a particular project, regardless of the source of funding for that project.

In addition to those activities that qualify for the OSA rate based on the above guidelines, the following specific activities will be allowed to use the OSA rate (by direction of Georgia Tech's administration):

  • Advanced Technology Development Center (ATDC) - (ATDC company’s campus service accounts only)
  • Georgia Internships for Teachers (GIFT) Program regardless of funding source
  • K-12 Education Community

For activities meeting the above criteria and for the specific activities noted, Contracting Officers in the Office of Sponsored Programs are authorized to approve use of the OSA rate. Otherwise, use of the rate requires approval by the Vice President for Research.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
 
Revision Date Author Description
01-02-2014 OSP Rev 1.0

2.3.6.2 Rate Used for Projects Funded by the State of Georgia and Georgia Local Governments

2.3.6.2 Rate Used for Projects Funded by the State of Georgia and Georgia Local Governments
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:32
Policy No
RESEARCH 2.3.6.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Georgia Tech uses the Other Sponsored Programs rate that is negotiated with the Office of Naval Research as its "Georgia State and Local Government" rate regardless of the nature of the activity. It will automatically change for future periods to remain equal to the prevailing OSA Facilities & Administrative rate. This rate is also applicable to Georgia's county and city agencies, and to all Georgia colleges and universities when using their own funds.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
 
Revision Date Author Description
01-02-2014 OSP Rev 1.0

2.3.6.3 Policy on Reduced F&A and General Exception

2.3.6.3 Policy on Reduced F&A and General Exception
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:34
Policy No
RESEARCH 2.3.6.3
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Georgia Tech's policy is to recover F&A on sponsored projects. As a General Exception, Georgia Tech will accept a limitation on F&A recovery in the following situations:

  1. When a statutory limitation is imposed by the U.S. Congress for certain U.S. Government-funded programs, or
  2. When a regulatory restriction is imposed by a U.S. Government agency and is published in the solicitation for proposals, program guidelines, or RFP, or
  3. A U.S. domestic, non-profit (501.c.3) charitable organization imposes a limit that is published in its program solicitation and uniformly applied to all grantees.

Note that the industrial rate generally applies to projects funded by foreign governments, foreign governmental entities, and industry.

In agreeing to a reduced F&A rate, Georgia Institute of Technology is agreeing to cost share real costs associated with sponsored activities

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
 
Revision Date Author Description
01-02-2014 OSP Rev 1.0

2.3.6.4 Waiver of F&A Reimbursement

2.3.6.4 Waiver of F&A Reimbursement
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:42
Policy No
RESEARCH 2.3.6.4
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

An F&A waiver must be obtained from the Executive Vice President of Research prior to proposal submission if less than the full applicable F&A rate is to be used in a proposal submitted to a sponsor or obtained prior to acceptance of an award if the awarded rate is less than the full applicable rate. General exceptions to the policy can be found at 2.3.6.3

Cost share request forms can be found at OSP Forms Library

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
 
Revision Date Author Description
01-02-2014 OSP Rev 1.0

2.4 Policy on Routing

2.4 Policy on Routing
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 14:52
Policy No
RESEARCH 2.4
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is the policy of Georgia Tech that all proposals for sponsored funding must be transmitted to the Office of Sponsored Programs using the Georgia Institute of Technology Sponsored Program / Research Proposal Authorization Routing Form. All information blocks on the front of the form must be completed and all required approvals on the back of the form must be obtained by the proposed Project Director/Principal Investigator. The routing form is also required for electronically routed proposals, such as those submitted to the National Science Foundation (NSF) via FastLane.* In these cases, the PD/PI is to provide the properly signed routing form to the Contracting Officer prior to the NSF deadline.

Policies on submission:

  • The Electronic Submission Policy: proposals that are to be submitted by an electronic means need to be ready to be released to the sponsor 24 hours prior to submission deadline and additionally, it needs to be ready for OSP review 2 days prior to that. This includes electronic submissions via a dedicated online system or via email.
  • Paper copies must be in OSP by 2pm the day it needs to be submitted otherwise it will be processed the next business day.

Signature Authority & Proposal Submission 

The Office of Sponsored Programs is the unit legally authorized to approve proposals and negotiates awards on behalf of Georgia Tech Research Corporation (GTRC) and Georgia Tech Applied Research Corporation (GTARC). OSP is also the Authorized Organizational Representative to Sponsors that require such a role. The PI or Project Director is not considered an authorizing official and cannot legally sign award documents. For more information, go to:http://www.osp.gatech.edu/proposal-process/

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures
3.1 Routing Procedures

Pre-proposals, Letters of Intent (LOI) & White Papers only need to be reviewed and approved by OSP if:

1. The pre-proposal, LOI & White Paper must be submitted by an authorizing official (AOR) through an electronic submission process;

2. A detailed budget is required; or

3. The sponsor requires that the pre-proposal be signed by an authorizing official.

In addition to a new proposal submission, an OSP Routing form is required for the following types of proposals:

  • Non-Competing Continuations
  • Supplements
  • Competitive Renewals
  • SubAwards
  • Budget Reductions/Additions of 10% or greater requires a new routing form
  • Progress Reports that include a budget for a subsequent period of time

Requests for carryover of funds from one budget period to another, no-cost extensions, and requests to rebudget after the grant has been funded do not require a routing form. Non-financial requests that require the signature of the institutional official also do not require a routing form.

 

 

3.2 Post Application Submissions
NIH – Just in Time (JIT)

http://era.nih.gov/services_for_applicants/application_tracking_and_award/just_in_time-at-nih.cfm

Other agency requests may include:

1. Budget questions/revisions

  • NSF Budget Impact Statement. If asked to reduce the overall budget there is an obvious need to indicate that there is an impact to the budget.

2. Questions regarding the scope of work 3. Research Compliance Approvals (IRB, IACUC, etc.)

3.    Research Compliance Approvals (IRB, IACUC, etc.)

 
Policy History
 
Revision Date Author Description
1-2-2014 OSP Rev 1.0

2.4.1 Post Application Submissions

2.4.1 Post Application Submissions s1polics Wed, 04/20/2016 - 14:57

NIH – Just in Time (JIT) - http://era.nih.gov/services_for_applicants/application_tracking_and_award/just_in_time-at-nih.cfm

Other agency requests may include:

  1. Budget questions/revisions
    • NSF Budget Impact Statement. If asked to reduce the overall budget there is an obvious need to indicate that there is an impact to the budget.
  2. Questions regarding the scope of work
  3. Research Compliance Approvals (IRB, IACUC, etc.)

2.5 Cost Sharing

2.5 Cost Sharing
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:01
Policy No
RESEARCH 2.5
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Georgia Tech may provide cost-sharing or matching funds for projects funded by the federal government or non-profit organizations where mandatory and approved prior to proposal submission by the Executive Vice President for Research. The commitment of funds for cost-sharing is subject to the availability of funds for that purpose. It is the policy of Georgia Tech that all researchers who engage in sponsored or externally funded research will comply with Institute policies and sponsoring agency regulations regarding cost sharing or matching requirements on all proposals, and awards with regard to project costs and reporting of cost sharing funds on those projects. Cost sharing or matching is defined as that part of a project or program costs not borne by the funding agency but supported by contributions from the recipient and third parties.

Mandatory Cost Sharing:

Required by the sponsor as a condition of receiving an award. Principal investigators must include the total amount of the cost share commitment in the proposal budget.

Cost sharing, matching and in-kind costs cannot include contributions designated for other sponsored projects, unless they are specifically authorized by that sponsor. For example, a gift designated as a match on one project cannot also be used as a match on another project. Costs used to satisfy cost sharing or matching/in-kind commitments will be subject to the same policies as other costs under the approved budget, unless they are specifically authorized by that sponsor. Thus, to qualify for cost sharing, matching, or in-kind, all charges must be:

  • allowable under Institute and sponsor policies
  • allocatable as a cost to the project
  • reasonable and necessary for performance of the project
  • allowed as a direct cost on the project (for example administrative salaries cannot normally be used as cost sharing on federal projects)

Cost share commitments are auditable and must meet the same criteria as a direct charge to a grant.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures

Whenever cost sharing is proposed as part of a sponsored project, the source of funds must be identified and approval obtained from the person with authority to commit those funds. If the source is identified as “To Be Determined”, the funds from the unit originating the proposal are obligated until an actual source is committed prior to the time of award. Funds to be provided by entities outside of Georgia Tech, typically referred to as “third-party” cost sharing, must be supported at the proposal stage by written documentation from the outside entity indicating their commitment to provide cost sharing.

Cost sharing funds are actually made available to the Project Director/Principal Investigator (PD/PI) when/if the proposal results in a sponsored award. Cost sharing approvals are obtained by way of the Proposal Routing Form and a Cost Sharing Approval Form. The Office of Sponsored Programs (OSP) furnishes a management report of all outstanding cost sharing commitments associated with pending sponsored proposals to the Office of the President on a monthly basis.

Policy History
Revision Date Author Description
01-2-2014 OSP Rev 1.0
11-20-2014 OSP Rev 2.0
02-13-2015 OSP Rev 3.0

2.6 Agency Specific Proposal Requirements

2.6 Agency Specific Proposal Requirements s1polics Wed, 04/20/2016 - 15:02

2.6.1 Salary Rate Caps

2.6.1 Salary Rate Caps
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:05
Policy No
RESEARCH 2.6.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

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.

Policy Statement

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.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
 
Revision Date Author Description
08-09-2021 OSP Editorial updates
01-02-2014 OSP Rev 1.0

2.6.2 Salary Cost Limitation

2.6.2 Salary Cost Limitation
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:08
Policy No
RESEARCH 2.6.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

2.6.3 GT Implementation of NSF Responsible Conduct of Research Policy

2.6.3 GT Implementation of NSF Responsible Conduct of Research Policy
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:14
Policy No
RESEARCH 2.6.3
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

Georgia Tech students and trainees engaged in research at the undergraduate, graduate and post‐doctoral levels shall receive formal instruction in ethical considerations and decision‐making in Responsible Conduct of Research. See www.rcr.gatech.edu for the current policy, guidelines, and procedures. This policy is intended to comply with the requirements of the National Science Foundation’s (NSF) implementation of the requirements of Section 7009 of theAmerica Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science Act(42U.S.C. 1862o–1) found in the NSF Award and Administration Guide, Chapter IV, and National Institutes of Health (NIH) requirements found in NOT‐OD‐10‐019.

Policy Statement

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.

Scope

This policy applies to all Georgia Tech Faculty, Staff, and Students

Definitions:

Responsible Conduct of Research Responsible Conduct of Research(RCR) is defined as the practice of scientific investigation with integrity. It involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research.
 
Responsibilities

5.1 Principal Investigators

Principal Investigators of NSF and NIH-funded projects are responsible for ensuring that all students engage in research are informed or the requirement and that the requirement has been met.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

2.7 Advance Project Number

2.7 Advance Project Number
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:20
Policy No
RESEARCH 2.7
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

The Georgia Tech Advance Project Number Policy permits the establishment of an account to which expenses may be charged on behalf of an anticipated program prior to receipt of a grant or execution of an agreement, but only when there is strong evidence a proposed sponsor intends to fund the project and will recognize that funds will be expended in advance of the final agreement start date. In general, only charges incurred within 90 days of the start date of the project will be recognized by federal sponsors.

All Advance Project expenditures are guaranteed by the department>.

Once issued, the Advance Project Number will become the Project Number and stay with the project throughout its life and will not change.

All expenses charged to an Advanced Project must be for costs that will be allowable when the agreement is finalized.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures
3.1 Advance Project Number Requests
Advance Project Number Form Requests for an Advance Project Number are submitted to the Office of Sponsored Programs on a Request for Advance Project Number Form.
Submission of Advance Project Number Form to OSP Upon receipt of the completed request for an Advance Project Number, the OSP Contracting Officer will obtain confirmation that the sponsor intends to authorize the work, negotiate contract terms and conditions in good faith, and that the agreement effective date has been established such that any advance project charges will be allowable and recoverable from the sponsor.
Approved Request for Advance Project Number Form OSP will distribute copies of the approved Request for Advance Project Number Form, which includes the following information:
  • the project number assigned
  • the amount of advance funding authorized
  • the approved advance project time period
  •  
Policy History
Revision Date Author Description
1-2-2014 OSP Rev 1.0

3.0 Regulatory Management and Research Risks

3.0 Regulatory Management and Research Risks s1polics Wed, 04/20/2016 - 15:24

3.1 Office of Research Integrity Assurance

3.1 Office of Research Integrity Assurance s1polics Wed, 04/20/2016 - 15:31

Universities, as partners in the national research enterprise, are required by federal regulations to establish specific research committees to ensure the ethical and safe conduct of research and certain other scholarly activities.  The Institutional Animal Care and Use Committee, the three Institutional Review Boards, and the Institutional Biosafety Committee have been established to oversee activities involving, respectively, vertebrate animal subjects, human research subjects, and recombinant DNA (rDNA).  These federally mandated faculty committees are administered and supported by the Office of Research Integrity Assurance, which reports to the Vice President for Research.  Procedures for obtaining committee approval can be found at www.researchintegrity.gatech.edu.​

3.1.1 Institutional Review Board (IRB)

3.1.1 Institutional Review Board (IRB)
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:35
Policy No
RESEARCH 3.1.1
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kelly Winn
Contact Title
Director, HRPP and Regulatory Affairs
Contact Email
kelly.winn@oria.gatech.edu
Reason for Policy

Georgia Tech subscribes to the basic ethical principles that underlie the conduct of biomedical and behavioral research involving human subjects as set forth in the Belmont Report, the timeless statement of ethical principles and guidelines for the protection of human subjects published in 1979 by the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research.

Policy Statement

The three Georgia Tech Institutional Review Boards are charged with protecting the rights and welfare of human subjects participating in research projects conducted by Georgia Tech faculty, staff, or students. These include the Central IRB, the Joint Georgia State University-Georgia Tech IRB for the Advanced Brain Imaging Center, and the Classified IRB. The IRBs have the responsibility and authority to review, approve, disapprove, or require changes in research activities involving human subjects. All proposed research activities involving human subjects, regardless of source of funding or study location, must be reviewed and approved by the appropriate Georgia Tech Institutional Review Board (IRB) prior to initiation of research. The IRBs hold regularly scheduled meetings to review research protocols involving human subjects. Georgia Tech’s Federalwide Assurance is approved by the Department of Health and Human Services, and the Institutional Review Boards are registered with the Department of Health and Human Services, Office for Human Research Protections. Committee members are appointed by the Vice President for Research, who also serves as the Institutional Official for matters related to human subjects. Membership is structured in accordance with federal requirements set forth in Title 45 Code of Federal Regulations Part 46, “Federal Policy for the Protection of Human Subjects” including Subparts A, B, C, and D, and in Title 21 Code of Federal Regulations, Parts 50, 56, 312, and 812.

Scope

This policy applies to all Georgia Tech Faculty, Staff, and Students.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-30-2013 GTRC-ORIA Rev 1.0

3.1.2 Institutional Animal Care & Use Committee (IACUC)

3.1.2 Institutional Animal Care & Use Committee (IACUC)
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:41
Policy No
RESEARCH 3.1.2
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Mary Beran
Contact Title
Associate Director
Contact Email
mary.beran@gtrc.gatech.edu
Reason for Policy

The Georgia Institute of Technology is committed to ensuring that vertebrate animals used in research and teaching activities receive humane care and treatment.

Policy Statement

The Institutional Animal Care and Use Committee (IACUC) is charged with reviewing all proposed use of vertebrate animals, regardless of where the work is performed and source of funding, if any. The IACUC has the responsibility and authority to review, approve, disapprove, or require changes in research activities involving vertebrate animals.  This committee regularly inspects and monitors the animal care and use facilities and program at the Institute to ensure that all components are in compliance with regulations outlined in the federal Animal Welfare Act, the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals, and with the Eighth Edition of the Guide for the Care and Use of Laboratory Animals.  

The animal facilities are registered with the U.S. Department of Agriculture and undergo frequent, unannounced inspections by that agency.  Georgia Tech’s Animal Welfare Assurance is approved by the Department of Health and Human Services. Committee membership is structured in accordance with federal requirements; members are appointed by the Vice President for Research, who also serves as the Institutional Official for matters related to vertebrate animal subjects.   

The IACUC has set forth procedures for reporting, without fear of reprisal, concerns about the humane use and treatment of vertebrate animals used in research and teaching activities at Georgia Tech.   The IACUC meets monthly to review research protocols which propose the use of vertebrate animal subjects; committee approval must be obtained prior to initiation of proposed activities.

Scope

This policy applies to all Georgia Tech Faculty, Staff, and Students.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
 
Revision Date Author Description
12-30-2013 GTRC-ORIA Rev 1.0

3.1.3 Institutional Biosafety Committee (IBC)

3.1.3 Institutional Biosafety Committee (IBC)
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:49
Policy No
RESEARCH 3.1.3
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Mary Beran
Contact Title
Associate Director
Contact Email
mary.beran@gtrc.gatech.edu
Policy Statement

The Institutional Biosafety Committee (IBC) is responsible for reviewing all registrations for research, teaching, and training that involve the use of recombinant DNA by Georgia Tech faculty, staff or students and ensuring that the proposed activities comply with the federal “NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules” and all other applicable regulations.  All scholarly activities involving recombinant DNA, regardless of source of funding, must be reviewed by the IBC.  The Committee has the responsibility and authority to review, approve, disapprove, or require changes in research, teaching, and training activities involving recombinant DNA materials.

Georgia Tech’s Institutional Biosafety Committee is registered with the National Institutes of Health’s Office of Biotechnology Activities (OBA).  IBC works closely with Georgia Tech’s Biosafety Officer in the Office of Environmental Health and Safety.  Committee membership is structured in accordance with federal requirements.  Members are appointed by the Executive Vice President for Research, who is also the Institutional Official for matters related to the Biosafety Committee.  The IBC holds meetings as needed to review registrations.

Scope

This policy applies to all Georgia Tech Faculty, Staff, and Students.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-30-2013 GTRC-ORIA Rev 1.0

3.2 Office of the General Counsel

3.2 Office of the General Counsel kcross8 Fri, 07/16/2021 - 10:35

3.2.1 Export Control

3.2.1 Export Control
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 15:54
Policy No
RESEARCH 3.1.4
Effective Date
Last Revised
Review Date
Policy Owner
The Office of the General Counsel
Contact Name
Office of the General Counsel
Contact Email
export@gatech.edu
Reason for Policy

Research is a global endeavor, and international experiences and opportunities are vital in preparing Georgia Tech’s students to become leaders who meet the challenges of the future. It is sometimes challenging to conduct these programs in compliance with complex laws and regulations that change frequently. The Office of the General Counsel, in coordination with the Research Security Department (RSD), assists faculty members with the review of research proposals and awards and when appropriate prepares Technology Control Plans (TCP) to protect export controlled technology.

Policy Statement

It is the policy of the Georgia Institute of Technology (GIT) to fully comply with all applicable federal statutes, executive orders, regulations, and contractual requirements for the safeguarding of export controlled technical information in its possession. This includes full and total compliance with export controls and transfer of controlled technology. Under no circumstances shall employees or other persons acting on behalf of GIT engage in activities in contravention of U.S. export control laws. In general, export controlled Information means activities, items, and information related to the design, development, engineering, manufacture, production, assembly, testing, repair, maintenance, operation, modification, demilitarization, destruction, processing, or use of items with a capacity for military application utility.  Export controlled information does not include basic marketing information on function or purpose; general system descriptions; or information concerning general scientific, mathematical, or engineering principles commonly taught in schools, colleges and universities or information in the public domain.

The export of equipment and information including technical data, software and hardware is controlled by federal regulations such as the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). Information such as brochures, proposals, site visits and technical discussions are deemed "technical data." Exporting information or talking to a foreign sponsor (either in the U.S. or abroad) about certain types of technical data which may have a possible military application requires a State Department export license, which may take up to three months to obtain. Exporting information or a commodity which does not have significant military application usually requires obtaining one or more of the following: an assurance which precludes reexport; supporting documentation; or a Commerce Department export license. Export of some items to certain countries and some types of subcontracts with those countries are prohibited altogether. For more information: http://www.export.gatech.edu/

Scope

This policy applies to all Georgia Tech Faculty, Staff, and Students.

 

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
07/15/2021 OGC/GTRC Updated owner
12-30-2013 GTRC-ORIA Rev 1.0

3.2.2 Conflict of Interest

3.2.2 Conflict of Interest s1polics Wed, 04/20/2016 - 15:55

It is the policy of the Georgia Institute of Technology that all Financial Conflicts of Interests (FCOI) will be managed, reduced, or eliminated in accordance with Federal Regulations, State law, and Institute Policy.  In order to ensure timely management and reporting of FCOIs, every Employee of the Institute, including all who participate in outside professional activities and/or sponsored research must complete an annual disclosure using the online Conflict of Interest system (eCOI), which is available athttps://ecoi.research.gatech.edu. In answering the eCOI questions, if an Employee has indicated an actual or potential conflict, the system will notify the COI Office for review.  Employees must update their disclosures on an ongoing basis when circumstances change.  This includes receiving prior approval before engaging in any outside professional activity.

 

3.6 Organizational Conflict of Interest Policy

3.6 Organizational Conflict of Interest Policy kcross8 Thu, 09/23/2021 - 15:35
Effective Date
Review Date
Contact Name
Office of the Executive Vice President for Research
Contact Names
Gail Spatt
Contact Title
Director of Research Operations
Contact Email
spatt@gatech.edu
Reason for Policy

Organizational conflict of interest (OCI) assessment is a requirement of many government and some industry sponsors that fund Georgia Institute of Technology (Georgia Tech) research. The purpose of OCI assessment is to ensure objectivity in federal contracting. As a contractor, it is Georgia Tech’s intent to detect, avoid, and mitigate any OCI issues in its dealings with sponsors. The Organizational Conflict of Interest Policy provides consistency across such assessments and assurance to those sponsors who require that such a policy be in place before contracting with Georgia Tech.

Policy Statement

An organizational conflict of interest may occur when a federal contractor has an Unfair Competitive Advantage over other potential contractors or is unable to avoid Impaired Objectivity, or the appearance of Impaired Objectivity, in the course of the contracted work. (See section 4 below for detailed definitions of Unfair Competitive Advantage and Impaired Objectivity.) In order to comply with the Federal Acquisition Regulation (FAR) Subpart 9.5 – Organizational and Consultant Conflicts of Interest, researchers or their designates submit all research proposals via the eRouting system, where they answer questions about the programmatic requirement of an OCI assessment. Proposals that may contain an OCI requirement, as well as proposals for which the researcher would like a review, move to a member of the OCI Review Committee for a more detailed analysis. Georgia Tech is committed to recognizing, avoiding and mitigating potential organizational conflicts of interest, both real and perceived, wherever possible.

OCI review results are retained by the OCI committee and communicated via the eRouting system for institutional documentation.

Scope

This policy applies to all employees conducting sponsored research at Georgia Tech.

Policy Terms
Unfair Competitive Advantage Competing for work after having had access to source selection relevant information (from the sponsor or competitor’s private data) not available to all competitors or having defined the ground rules of the competition.
Impaired Objectivity Evaluating one’s own products, or similar products from competitors, on behalf of the government, in which judgment could be impaired or guidance provided to the government could be biased.
Procedures
OCI Evaluation
Submission The initial step for submission of any proposal at Georgia Tech is an entry into the eRouting system. This system contains a series of initial screening questions for OCI. Learn more here.
Review The screening questions in eRouting trigger an evaluation by the OCI Review Committee of all proposals that indicate a potential OCI or the potential appearance of an OCI. The committee’s review process typically includes, at a minimum: assessment of all relevant proposal paperwork and a search of other projects currently or recently underway for the sponsor by Georgia Tech researchers. Reviews generally take place as quickly as possible in the order in which the proposals were received, though the committee will place a greater priority on those proposals with a pending sponsor deadline. The review will be initiated within five business days of the committee’s receipt of the request, but the time frame for completion of the review will depend on its complexity.
Responsibilities

Faculty and Staff
Faculty and staff submitting proposals, conducting research, and supporting research operations are expected to consider the potential of organizational conflict of interest (OCI). They are to bring any concerns about possible OCI or the appearance of OCI to the attention of the Office of the Executive Vice President (EVPR), or the Georgia Tech Research Institute (GTRI), as well as to the contracting officer for the sponsor engagement. Faculty and staff should review information regarding submission timelines here. During execution of the project, researchers are to be vigilant about any developments which may introduce OCI. They must bring these to the attention of the above contracting officer so that these new developments can be disclosed, and potential mitigations considered.

Contracting Officers
When a proposal requires OCI review, the assigned contracting officer in the Georgia Tech Research Corporation or the Georgia Tech Applied Research Corporation ensures that the OCI Review Committee has evaluated the proposal and provided a recommendation. Based on that recommendation, the contracting officer is responsible for completing the necessary paperwork and certifying Georgia Tech’s compliance as required. The contracting officer is responsible for disclosing to the sponsor any OCI that emerges in the course of the work and for addressing any required mitigation actions with their counterparts in the sponsoring organization.

Office of the Executive Vice President for Research (EVPR)
The EVPR’s office is responsible for ensuring the accurate and thorough assessment of potential OCI on any given project, to the best of Georgia Tech’s ability. The Executive Vice President for Research directly appoints 1-2 members of the OCI Review Committee and delegates appointment of GTRI representatives to the director of GTRI. Other groups or offices may be asked to participate in this process at the direction of the EVPR.

Director of the Georgia Tech Research Institute (GTRI)
GTRI is designated as a University Affiliated Research Center (UARC) by the Department of Defense. A UARC is required to operate in the public interest and conduct its business in a manner befitting its special relationship with the government. To maintain the government’s trust in the integrity of the work, the GTRI Director has established a specially trained team that closely evaluates all proposals going out of GTRI. This team maintains OCI support throughout the life cycle of each GTRI project and supports the EVPR on other projects as required.

Georgia Tech Organizational Conflict of Interest (OCI) Review Committee
The OCI Review Committee works with researchers to evaluate the potential for OCI in sponsored projects, and then to plan and document avoidance or mitigation strategies if necessary and appropriate. The OCI committee also provides contracting officers in the Georgia Tech Research Corporation and the Georgia Tech Applied Research Corporation with advice on how to complete required OCI review certification or disclosure documents in sponsored proposals. Finally, the OCI review committee is available as a consulting body if researchers have questions around OCI or suspect that circumstances within their project may have altered their original analysis of real or perceived OCI.

Enforcement

The Georgia Tech OCI committee works diligently to ensure that noncompliance does not become an issue in the course of the award. Anyone involved in research who becomes aware of such an occurrence should immediately contact the EVPR office for correction according to the sponsor’s guidelines. Failure to disclose potential OCI issues to sponsors can cause awards to be rescinded or terminated or result in restrictions on future contracting. Actual OCI or the appearance of OCI can also be a cause for protests from competitors, creating program delays, loss of funding, and strained relations with government and industry partners. Deliberate violation of this policy constitutes research misconduct.

Policy History
Revision Date Author Description
09/2021 Office of the Executive Vice President for Research New Policy

3.7 Environmental Health and Safety

3.7 Environmental Health and Safety s1polics Wed, 04/20/2016 - 16:05

The Environmental Health and Safety (EHS) Office at Georgia Tech develops programs and provides oversight, consultation, training and other specialized services to assist the Institute community in meeting its public health, safety, environmental protection, and compliance responsibilities.

http://www.ehs.gatech.edu/

3.7.1 Office of Radiological Safety

3.7.1 Office of Radiological Safety s1polics Wed, 04/20/2016 - 16:06

The Office of Radiological Safety (ORS) manages all aspects of the use of radioactive material (RAM) and radiation generating devices at Georgia Tech.

http://www.ors.gatech.edu/

4.0 Post-award Management - Financial Administration

4.0 Post-award Management - Financial Administration s1polics Wed, 04/20/2016 - 16:09

4.2 Payment Terms

4.2 Payment Terms
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:13
Policy No
RESEARCH 4.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is the policy of Georgia Tech’s Office of Sponsored Programs that, in issuing and administering sponsored projects/awards, the office is in compliance with:

  • Georgia Institute of Technology Policies and Procedures
  • Applicable sponsor regulations
  • Terms and conditions of the prime award
Scope

This policy applies to all Georgia Tech Faculty and Staff.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=750

Policy History
 
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.2.1 Advance Payment

4.2.1 Advance Payment
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:14
Policy No
RESEARCH 4.2.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is the policy of Georgia Tech that an advance payment is required on all industrial projects with industry sponsors. This advance payment is required because it usually takes several months from the start of a project until receipt of the first payment. The amount of the advance payment is usually 25% of the total project cost. However, if the sponsor has a bad credit rating, a higher amount (up to the full project cost) may be required. The sponsor is notified of this advance payment requirement in the proposal transmittal letter. The amount of the advance payment is cited in the payment clause of the contract. An invoice for the advance payment is transmitted by the Program Initiation Division Contracting Officer with the proposal. The advance payment is applied against the final invoice for the project, and any funds remaining are returned to the sponsor. This policy does not apply when the industrial sponsor has a prime government contract under which Georgia Tech will be a subcontractor.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
 
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.2.2 Fixed Price

4.2.2 Fixed Price
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:17
Policy No
RESEARCH 4.2.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

This contract is most appropriate when there is a clear SOW and little risk to the Institute. On occasion, a sponsor will insist on a fixed price contract. If the PD/PI’s Lab/School determines that the financial/legal risks are minimal and acceptable, the researcher’s Lab/School will state that internal funds will be available in the event of a cost overrun, and that the deliverables do not include hardware or software items, some special programs may be accepted on a fixed price basis with the approval of the Vice President for Research. This is preferred contract type when a PI has subcontractors or will be issuing sub-awards on the project.

Per the Uniform Administrative Requirements (2 CFR 200), Subpart - C, this type of agreement cannot be used when there is mandatory cost sharing required.  Changes in PD/PI, project leader, project partner or scope of effort must receive the prior written approval of the Federal award agency or pass-through entity.  Additionally, the non-Federal entity must certify in writing to the Federal awarding agency or pass-through entity at the end of the Federal award that the project or activity was completed or the level of effort was expended. If the required level of activity or effort was not carried out, the amount of the Federal award must be adjusted.

Click here for the Georgia Tech Fixed Price Memo, which should be submitted along with the OSP Routing Form.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0
11-20-2014 OSP Rev 2.0
03-16-2015 OSP Rev 3.0

4.2.3 Cost-reimbursement

4.2.3 Cost-reimbursement
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:19
Policy No
RESEARCH 4.2.3
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

There are several flavors of Cost Reimbursable (CR) contracts, the two most common at Georgia Tech are the pure Cost Reimbursement and Cost Plus Fixed Fee (CPFF). Including cost sharing in a contract or proposal is also a form of a cost reimbursable contract. The CR and CPFF contract is the preferred contract for the Institute to receive (without cost sharing), as it limits risk on research endeavors that may not have a clearly defined SOW. Under the CPFF, in addition to reimbursing the Institute for costs related to the work, the sponsor will also provide the Institute with a fee.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.2.4 Time and Materials

4.2.4 Time and Materials
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:21
Policy No
RESEARCH 4.2.4
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Under this type of agreement the sponsor agrees to pay a negotiated hourly rate for specified types of labor and to reimburse the Institute for materials used on the project. Base hourly rates invoiced to the sponsor include base hourly rate plus all indirect costs. Prepare your budget as such. This type of contract requires careful oversight and management. This type contract also requires the approval of the Vice President for Research.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.2.5 Foreign Sponsor Payments

4.2.5 Foreign Sponsor Payments
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:23
Policy No
RESEARCH 4.2.5
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Exchange Rate Consideration

The exchange rate is the price of one currency expressed in terms of another currency. For example, as of the November 2009, the exchange rate of one U.S. dollar for one Euro was approximately 0.67, which means that one dollar can be exchanged for 0.67 euros. Fluctuation in exchange rates have significant affects on the payments for sponsored research projects. All GA Tech units should be aware of the risks, including potential loss of dollars, involved in agreements containing payment terms in foreign currency.

Payment Terms for Foreign Sponsors

OSP generally requires at least 50% advance payment from all foreign sponsors. To eliminate the risk associated with exchange rates, OSP establishes the agreement amount and payment terms in U.S. dollars. If the sponsor will not agree to establish the agreement’s price and payment terms in U.S. dollars, OSP will try to reduce the risk associated with exchange rates by requiring payment in full upon execution of the agreement or as much advance payment as can be mutually agreed upon. If the sponsor will not agree to advance payments, OSP will require a memo signed by the School Chair stating that they understand the ramifications associated with payments made in a foreign currency, and the School will be responsible for any cost over-runs associated with foreign currency fluctuations.

Budget

The PI should prepare a budget in U.S. dollars and the currency of the foreign sponsor. OSP will process the budget for the Agreement in U.S. dollars at the time an award is processed based on the current exchange rate. Grants & Contracts will notify the PI and OSP of the payment amount received to adjust the budget as necessary. The PI’s School will be responsible for any shortfalls in the awarded amount due to fluctuations in the currency’s exchange rate. Therefore, the PI should stay abreast of the affect the exchange rate will have on the budget throughout the life of the research project.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.2.6 Risk Mitigation Policy

4.2.6 Risk Mitigation Policy
Type of Policy
Administrative
s1polics Wed, 04/20/2016 - 16:25
Policy No
RESEARCH 4.2.6
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Research projects that are funded by private industry sponsors and certain others carry an added risk of financial losses due to non-payment by the sponsor. The causes of non-payment range from financial exigencies faced by the company particularly during periods of general economic slowdown to disappointment on the part of the sponsor with the outcomes of the research project. With such sponsors, it is particularly important to establish clear contractual agreement as to the nature of the research relationship between Georgia Tech and the sponsor. It is equally important to develop payment terms that mitigate Georgia Tech’s financial exposure, set clear expectations regarding payment, and exercise consistent and prudent oversight of project receivables.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.3 Cost Sharing

4.3 Cost Sharing
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:21
Policy No
RESEARCH 4.3
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Cost share (Matching) funds are those funds contractually obligated by the Institute to meet the financial requirements specified in a sponsored award. These expenses represent the Institute’s contribution to an externally funded sponsored project. When a cost share obligation is identified in the sponsored agreement, it must be accounted for in the records of the Institute and reported to the sponsor. Cost share expenses should generally be incurred at the same rate as the sponsor’s portion of award expenses.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Procedures
3.1 General Procedures
From OMB Circular A-110, Section 23 (2 CFR 235), "Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations":

"All contributions, including cash and third party in-kind, shall be accepted as part of the recipient's cost sharing or matching when such contributions meet all of the following criteria.”

  1. Are verifiable from the recipient's records.
  2. Are not included as contributions for any other federally-assisted project or program.
  3. Are necessary and reasonable for proper and efficient accomplishment of project or program objectives.
  4. Are allowable under the applicable cost principles.
  5. Are not paid by the Federal Government under another award, except where authorized by Federal statute to be used for cost sharing or matching.
  6. Are provided for in the approved budget when required by the Federal awarding agency.
  7. Conform to other provisions of this Circular, as applicable.

** If any expense cannot meet the above criteria, it is not eligible to be recorded and reported as cost share. **

Policy History
Revision Date Author Description
01-02-2014 OSP Rev 1.0

4.4 Prior Approvals of Budget, PI, or other program changes

4.4 Prior Approvals of Budget, PI, or other program changes s1polics Thu, 04/21/2016 - 09:22

4.5 No-Cost Extensions

4.5 No-Cost Extensions s1polics Thu, 04/21/2016 - 09:23

5.0 Subcontracts, Subawards, and Subrecipient Administration

5.0 Subcontracts, Subawards, and Subrecipient Administration s1polics Thu, 04/21/2016 - 09:26

It is the policy of Georgia Tech’s Office of Sponsored Programs that, in issuing and administering subawards, the office is in compliance with:

  • Georgia Institute of Technology Policies and Procedures
  • Applicable sponsor regulations
  • Terms and conditions of the prime award

The ultimate goal of the following procedures is to guarantee that the subaward activities satisfy Institute and governmental reviews as well as government audit requirements while protecting the Institute’s best interest.

5.1 Pre-Award Stage

5.1 Pre-Award Stage
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:29
Policy No
RESEARCH 5.1
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

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.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Procedures
3.1 Specific Considerations
What is a Subagreement?

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.

Subrecipients vs. Vendors

It is not always clear when the pass-through entity should award federal funds to a subrecipient via a subcontract or subgrant, or a procurement contract to a vendor. A subrecipient is a state or local government, college, university or nonprofit organization that expends federal awards received from a pass-through entity to carry out a federal program. Under a subaward, a subrecipient generally has a specific scope of work to conduct in conjunction with the proposed research. The PI with the subaward is accountable for programmatic progress as well as for following federal guidelines.

In contrast, a vendor is a dealer, distributor, merchant or other seller providing goods or services that are necessary for conducting a federal program. These goods or services may be for an organization’s own use or for the use of beneficiaries of the federal program. They provide the service as part of their normal business operations. They provide similar services to many different purchasers

Under a procurement contract, a vendor provides goods or services that are auxiliary to the proposed research.

What constitutes a Consultant?

A Consultant Agreement is issued to either a company or to an individual who is clearly a bona fide consultant (expert advisor) who pursues this line of business for him/herself. The consultant is paid for his/her time at the fixed daily (or hourly) rate of compensation specified in an agreement. Consulting effort is usually limited to the term and the pay line is usually determined by a rate per day, which includes travel, expenses, and any other overhead. Consultants set their own hours, use their own equipment and materials, choose their work methods, and are responsible for paying taxes on their earnings as consultants. They will receive Tax Form 1099 from Georgia Tech. Furthermore a consultant’s effort is considered “work for hire” and therefore all intellectual property and copyrightable information produced is assigned to GTRC.

The primary difference is that a subcontract is almost invariably with another institution or with a company, and a consulting agreement is almost invariably with an individual who is not a Georgia Tech employee and has not been employed by Georgia Tech for at least 1 year.

Subagreements under Federal Contracts (Not Grants)

In order to establish a subrecipient relationship under federal contracts, the Federal Acquisition Regulation (FAR 35.009) states that “it is important that the contractor not subcontract technical or scientific work without the contracting officer’s advance knowledge.” The FAR goes on to state that “during the negotiation of a cost-reimbursement R & D contract, the contracting officer shall obtain complete information concerning the contractor’s plans for subcontracting any portion of the experimental, research, or development effort.” Typically approval is granted when a subrecipient is included in the proposal to the Government and an award is made based on that proposal. If a subrecipient relationship is not approved as part of a proposal submitted to the agency, written sponsor approval would be required before any unbudgeted subrecipient subcontract could be established.

Policy History
Revision Date Author Description
12-31-2013 OSP Rev 1.0

5.2 Requesting a Subaward

5.2 Requesting a Subaward
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:31
Policy No
RESEARCH 5.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

A SubAgreement may be required if part of the research effort under a grant or contract is to be performed by an outside organization or institution.

Policy Statement

Subcontracts should be set up as soon as possible after the receipt of an award. To initiate one, you or an authorized representative will need to make a request for subcontract agreement using Georgia Tech’s web-based OSP Contract System - https://webwise.gtri.gatech.edu/osp/sub/sitemap

Upon final submission through the on-line system you will need to forward a signed copy of the request form to OSP. A notification of acceptance, as well as other progress notifications will be sent via the ICOL system. Upon receipt of the returned subcontracts, an agreement will be issued to the subcontractor against which project-related costs may be billed. The Principal Investigator will be responsible for monitoring the technical performance of the subcontractor, verifying that required cost-sharing is properly documented and approving the invoices for payment. Please notify a contracting officer in OSP’s Subagreement Division promptly with any questions or concerns. A request for modification will be needed in order to add additional funds or time to the existing subcontract.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Procedures
4.1 Requesting a Subaward
As part of the on-line “Request for a Sub-Agreement” process you will want to have the following information ready:
On-line “Request for a Sub-Agreement”
  1. Visit OSP Contract System -https://webwise.gtri.gatech.edu/osp/sub/sitemap
  2. Use your GT Kerberos Password or GTRI credentials to access the system.
  3. From the Subagreement site map click on “make a request for new subagreement”
  4. Query on the fund # you wish to issue the subcontract/consulting agreement under.
  5. After completing the required fields, “Submit to OSP”
  6. Print request form for signature
  7. FAX or e-mail signed copy of the request form to OSP. FAX (404)385-0864
Responsibilities

5.1 Principal Investigators

The Principal Investigator will be responsible for providing oversight of the subcontract including:

  • monitoring the technical performance of the subcontractor,
  • verifying that required cost-sharing is properly documented,
  • and approving the invoices for payment.
Policy History
Revision Date Author Description
01-02-2014 GTRC-IE Rev 1.0

5.2.1 Statement of Work

5.2.1 Statement of Work s1polics Thu, 04/21/2016 - 09:36

Preparing the Statement of Work - The Statement of Work (SOW) is a document that lists and describes all essential and technical requirements for the effort to be performed, including standards to be used to determine whether the requirements have been met. This document may include the following items where appropriate:

  • Objective or Purpose
  • Period of Performance
  • A list of detailed work requirements
  • Workload requirements
  • Personnel requirements
  • Resources (if any) to be furnished to the subcontractor.
  • Reporting requirement/Other deliverables

5.2.2 Sole Source Justification

5.2.2 Sole Source Justification s1polics Thu, 04/21/2016 - 09:37
It is necessary to include documentation that you have obtained quotes from alternative vendors or completed a Sole Source Justification form. The PI is required to provide information of the technical competence of the sole source selection.

5.2.3 Cost Price Analysis

5.2.3 Cost Price Analysis s1polics Thu, 04/21/2016 - 09:33

The PI is also required to provide a technical assessment of the subaward budget. The assessment would include verification that the costs are reasonable and necessary to carry out the proposed project. The cost elements within the subaward budget must be necessary to accomplish the proposed activity.

The Government is responsible for insuring that Georgia Tech maintains adequate policies and procedures governing subcontracting activities on federally sponsored grants and contracts. These activities are monitored through the periodic Contractor Purchasing Systems Review (CPSR) conducted on campus by the Office of Naval Research every three years. The cost price analysis form is a key component in the Government’s review of our purchasing system.

One of the Government’s principal procurement objectives is to obtain fair and reasonable contract prices. Sub-award pricing is a critical element in the pricing of prime contracts and a major consideration in receiving Government consent to sub-awards and approval for contractor purchasing systems. Sub-awards can sometimes represent a major portion of the total dollars spent under a prime contract. Contracting officers cannot ensure the fairness and reasonableness of prime contract prices without evaluating the prices of critical sub-awards.

In accordance with the Federal Acquisition Regulation (FAR), the contracting officer is responsible for the determination of price reasonableness for the prime contract. To make this determination, the contracting officer must conduct an analysis of the relevant facts and data including subcontractor cost or pricing data. In all cases, a main consideration is to assure that the price to be paid for these goods and services is fair and reasonable. This is essential to insure that both University and Government funds are utilized in a cost effective manner and to conserve funding where resources are limited. To accomplish this, some form of cost or price analysis must be made and documented in connection with every procurement action.

A price analysis is an examination of the price proposed by the anticipated subcontractor and an assessment or evaluation as to whether or not it is fair and reasonable. A cost analysis however, actually examines the individual cost elements that comprise the total proposed estimated cost. These elements generally include such things as labor rates, material costs, overhead or indirect rates, a cost of money factor, general and administrative expenses (G&A), and a profit or fee.

It is not possible for personnel in the Office of Sponsored Programs (OSP) to determine if the price is fair and reasonable without input from others. OSP can evaluate costs, but assistance will be required from the responsible Project Director/Principal Investigator to evaluate the appropriateness of the total price.

If a sub-award exceeding $700,000 is to be issued under a Government contract prime award, OSP must be in compliance with Public Law 87-653, Truth in Negotiations. [The Public Law has been implemented in the United States Code of Federal Regulations 10 U.S.C. 2306a (Armed Forces) and 41 U.S.C. 254b (Public Contracts) and in the Federal Acquisition Regulation Part 15 and Clause No. 52.215-12.]. Public Law 87-653, Truth in Negotiations (TINA) is a requirement for cost or pricing data and certification for any sub-award expected to exceed $700,000. The sub-awardee is required to submit cost or pricing data prior to placement of the sub-award unless one of the following exceptions applies:

  • When the sub-award administrator determines that prices agreed upon are based on adequate price competition.
  • When the sub-award administrator determines that prices agreed upon are based on prices set by law or regulation.
  • When a commercial item is being acquired.
  • When a waiver for cost or pricing data has been granted by the Government contracting officer under the prime award.
  • When modifying a contract or sub-award for commercial items.

Cost or pricing data shall be obtained if the sub-award administrator concludes that none of the exceptions above applies. When cost or pricing data are required, the sub-award administrator shall require the sub-awardee to submit the following in support of any proposal:

  • Cost or pricing data (See FAR 15.408, Table 15-2 for guidance).
  • A certificate of current cost or pricing data, certifying that to the best of its knowledge and belief, the cost and pricing data were accurate, complete, and current as of the date of agreement on price or, if applicable, an earlier date agreed upon between the parties that is as close as practicable to the date of agreement on price. (See FAR 15.406-2 for format.)
  • For sub-awards under the TINA threshold the guidelines of FAR 15.403-3, Requiring Information Other than Cost or Pricing Data, should be utilized in certain cases. This would also include thorough documentation of cost or price reasonableness in accordance with FAR 15.406-3, documenting the negotiation.

5.3 Subrecipient Monitoring

5.3 Subrecipient Monitoring
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:39
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu

Georgia Tech is responsible for ensuring that all subrecipients of its sponsored research awards are in compliance with applicable requirements in accordance with 2 CFR 200 Subpart D Subrecipient Monitoring and Management and Subpart F – Audit Requirements, when it is expected that the subrecipient’s Federal awards expended during the respective fiscal year equals or exceed $750,000 (2 CFR 200.501). These guidelines and procedures are provided to assist faculty and staff in ensuring that subrecipients conduct their portions of research projects in compliance with laws, regulations and terms and conditions of awards and subawards and that project costs incurred by subrecipients are reasonable and allowable.

Roles and Responsibilities

Principal Investigators (PI)

PIs have primary responsibility for monitoring subrecipient's technical and financial performance to ensure compliance with federal regulations and both prime and subrecipient award terms and conditions. The Federal Government places the primary responsibility for management of federally funded projects with the PI. This includes:

  • Monitoring of subrecipient’s programmatic and financial activities related to the sub-award.
  • Review of technical/performance reports as required.
  • The PI is responsible for verifying the subrecipient work is conducted in a timely manner and that the results delivered are in line with the proposed statement of work.
  • The PI is responsible for reviewing and approving subrecipient invoices. This includes reviewing expenditures to ensure the charges are allowable, allocable, reasonable, and that the charges are within the period of performance.
  • The PI is responsible for maintaining regular contact with the subrecipient.

Unit Financial Officers (Departmental Administrators)

  • Reviewing invoices from subrecipients to ensure invoices are within the parameters of the sub-award budget, and questioning expenditures if necessary.
  • Ensure that invoices are approved by the PI or his/her designee and submitted to Accounts Payable in a timely basis.
  • If there are any unusual or excessive charges invoiced by the subrecipient, the department should request clarification from the subrecipient.
  • Maintain copies of all invoices that provide evidence of the regular review of invoices by the PI. “Evidence” can be in the form of authorized signature by the PI or his/her designee, PI’s initials, e-mail communications, or notes of meeting between the PI with the department administrator.
  • Maintaining documentation of monitoring efforts (copies of e-mail, phone log, etc.).
  • Unit Financial Officers (UFO’s) should assist PI’s in carrying out their subrecipient monitoring responsibilities. This includes:

Office of Sponsored Programs (OSP)

OSP is responsible for the oversight of subrecipient monitoring and ensuring that the Institute’s subrecipient monitoring procedures are compliant with federal and other applicable regulations. These responsibilities include:

  • Identifying to the subrecipient the Federal award information as required in section 2 CFR 200.331 (e.g., CFDA title and number, award name, name of Federal agency) and applicable compliance requirements, including any appropriate flow-down provisions from the prime agreement.
  • Ensure the use of subrecipient is well documented and cost price analysis performed in accordance with applicable regulations.
  • Determining whether or not the subrecipient or its PI’s are debarred or suspended from receiving Federal funds.
  • On an annual basis, reviewing all active sub-awards for which monitoring is mandated. Accordingly, OSP requests audit certification letters from all subrecipients expending $750,000 or more in Federal funds during the subrecipient’s fiscal year.
  • The returned certification letters are reviewed by the OSP Audit Coordinator to verify that no audit findings related to Federal funds provided by Georgia Tech are reported. If no findings are indicated, the OSP Audit Coordinator will initial, date, and notate that no follow-up action is required. OSP will inquire further into those that are deemed to require closer scrutiny, and take appropriate action.
  • Add additional conditions to the subaward when appropriate in accordance with 2 CFR 200.207 to manage any risk posed by subrecipient.
  • In accordance with FAR 52.219-9(d)(9), for Subrecipients under Federal Contracts, when a subcontract is awarded to a subcontractor (other than a Small Business) and is in excess of $750,000, OSP will obtain a Subcontracting Plan from the subcontractor.
  • In accordance with FAR 52.215-12, will obtain from the subcontractor a Certificate Cost or Pricing Data on all subcontracts in excess of $2,000,000 on or after July 1, 2018 and issued under a Federal contract.

The above list is not exhaustive of all compliance requirements. In addition to the general elements of compliance noted above, there may be additional sponsor- or program-specific requirements that mandate collecting and documenting other assurances (e.g. on lab animals, human subjects, biohazards, export controls, financial conflicts of interest etc.) during the course of a project. OSP will work with PIs and department administrators to establish channels of communication with subrecipients that require further scrutiny.

6.0 Post-award Management – Programmatic Administration

6.0 Post-award Management – Programmatic Administration s1polics Thu, 04/21/2016 - 09:41

6.1 Intellectual Property and Licensing

6.1 Intellectual Property and Licensing
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:44
Policy No
RESEARCH 6.1
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director, Corporate & International Contracting/Exchange Agreements
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

Commercializing your innovation begins with an initial disclosure to the Office of Technology Licensing. Through this process, Office of Technology Licensing can record the innovation, determine what form of intellectual property is involved and any sponsor rights, establish accurate inventorship and ownership interests in the innovation, and determine through various means of evaluation whether the innovation has commercial potential. Innovations should be reported to the Office of Technology Licensing as early as possible in the discovery process to ensure protection of intellectual property and to gain a comprehensive understanding of the options available in commercializing your research.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

6.2 Deliverables [Progress/Annual/Interim/Monthly Technical Reports]

6.2 Deliverables [Progress/Annual/Interim/Monthly Technical Reports]
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:47
Policy No
RESEARCH 6.2
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

It is Georgia Tech’s policy to meet all contractual obligations of a sponsored project.  It is the responsibility of the PD/PI to submit to the sponsor, all technical reports, final reports and any other deliverables that may be required under the sponsored agreement.

Deliverables must be submitted to OSP on-line via WebWise.

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures
3.1 Deliverable Submission
Online Submission Deliverables must be submitted to OSP on-line via WebWise under the project deliverables tab. Submissions are updated immediately by the system and may be viewed on line.

 

3.2 Training Tutorials
Deliverable Submission:
Tips:
  • Distributions made by the lab/school/center or via a 3rd party system directly to the sponsor must still be submitted via WebWise. Please upload the document as well as any proof of submission.
  • In the comments section, please note mm/dd/yy of submission, how it was originally sent and OSP will back date the item for you providing you submit proof of submission.
  • Publication Restricted field may be used for export control and ITAR controlled items
  •  
Policy History
Revision Date Author Description
1-2-2014 OSP Rev 1.0

6.3 Property Management

6.3 Property Management s1polics Thu, 04/21/2016 - 09:48

6.4 Travel including International Travel

6.4 Travel including International Travel
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:50
Policy No
RESEARCH 6.4
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

All travel by faculty, staff, students and guests utilizing sponsored programs funds administered through the Office of Sponsored Programs must meet the Cost Accounting Standard criteria.  It is allowable, allocable, and reasonable.  Travel is allowable as a direct charge if such travel will provide a direct benefit to the project.

If prior approval for foreign travel wasn’t obtained in the proposal stage and it is a federal sponsor, please refer to the FDP Approval Matrix for next steps.

The Fly American Act applies for travel funded by federal awards

Scope

This policy applies to all Georgia Tech faculty and staff members.

Policy History
Revision Date Author Description
1-2-2014 OSP Rev 1.0

6.5 Closeout

6.5 Closeout
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 09:54
Policy No
RESEARCH 6.5
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Policy Statement

Project Close Out is an administrative process that is handled by a Contracting Specialist assigned to the Contracting Support Division within the Office of Sponsored Programs. The requirements for project closeout are established by contractual provisions and/or agency regulations. The Contracting Specialist will ensure that all required closeout documents are submitted to the sponsor (i.e. final invoice, disclosures on patents and inventions, property, and security).

Scope

This policy applies to all Georgia Tech faculty and staff members.

Procedures
3.1 Closeout Procedures
Process

30 days prior to end of performance date – Auto-generated e-mail sent to PI and department notifying PI that project expires in 30 days

1. PI notifies CO if extension will be requested
2. No action required by PI if project will expire at end of performance date

30 days after end of performance date – Auto-generated e-mail sent to PI stating project has passed its end of performance

Project is closed by Contracting Specialist

Reporting Requirements

1. PI responds to close out notice stating if there are inventions or discoveries associated with project

2. PI completes all deliverables for the project

3. Final Invoice/Financial Papers are completed by G&C Accounting or GTRI Accounting

4. Property Report is prepared by Property Dept

5. Classified Material Certificate is prepared by Security Department

Subagreements Closeout Documents flow down from the main project
Termination of Project Project is terminated when all obligations to the sponsor have been fulfilled
Questions? Contact the Contracting Specialist or Closeout Manager overseeing the project close out.
Responsibilities

4.1. Principal Investigator

The PI is responsible for informing the Contracting Specialist and OSP, if an extension will be requested, if there are any inventions or discoveries associated with the project, and for completing all deliverables for the project

4.2. OSP Contracting Specialist

The Contracting Specialist is responsible for ensuring that all required closeout documents are submitted to the sponsor (i.e. final invoice, disclosures on patents and inventions, property, and security).
Policy History
Revision Date Author Description
1-2-2014 OSP Rev 1.0

7.0 Research Contracting with Industrial Entities/Sponsors

7.0 Research Contracting with Industrial Entities/Sponsors s1polics Thu, 04/21/2016 - 09:58

The Office of Industry Engagement is your home for all industry-sponsored research activities, both in the U.S. and abroad. We review all sponsored research proposals, negotiate terms and conditions, and execute the contracts. In addition, Industry Engagement can assist with preparation of proposal materials, including the statement of work, budget, forms, and agreements. We work with Georgia Tech researchers and industry partners to ensure that agreements are in accord with university policies and procedures as well as federal regulations and requirements.

7.1 Intellectual Property Terms in Industry Contracts

7.1 Intellectual Property Terms in Industry Contracts
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:00
Policy No
RESEARCH 7.1
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

Georgia Tech Research Corporation asserts a right of ownership to any intellectual property that was developed by an employee of Georgia Tech or resulted from significant use of Georgia Tech resources, even in research projects sponsored by industry. However, GTRC has worked hard to create and establish mechanisms that enable companies to easily obtain access to the project IP on fair and reasonable terms with minimal negotiations.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

7.2 International Collaboration

7.2 International Collaboration s1polics Thu, 04/21/2016 - 10:01

7.4 IP and Licensing

7.4 IP and Licensing s1polics Thu, 04/21/2016 - 10:03

7.5 Advance Payments

7.5 Advance Payments
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:05
Policy No
RESEARCH 7.5
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

It is the policy of Georgia Tech that an advance payment is required on all industrial projects with industry sponsors. This advance payment is required because it usually takes several months from the start of a project until receipt of the first payment. The amount of the advance payment is usually 25% of the total project cost. However, if the sponsor has a bad credit rating, a higher amount (up to the full project cost) may be required. The sponsor is notified of this advance payment requirement in the proposal transmittal letter. The amount of the advance payment is cited in the payment clause of the contract. An invoice for the advance payment is transmitted by the Program Initiation Division Contracting Officer with the proposal. The advance payment is applied against the final invoice for the project, and any funds remaining are returned to the sponsor. This policy does not apply when the industrial sponsor has a prime government contract under which Georgia Tech will be a subcontractor.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

8.0 Research Contracting with International Entities/Sponsors

8.0 Research Contracting with International Entities/Sponsors s1polics Thu, 04/21/2016 - 10:15

Georgia Tech encourages international collaborations. The Office of Industry Engagement serves as the point of contact for all international sponsored projects. This team facilitates international collaborations and helps assure compliance with Georgia Institute of Technology policies, as well as state and federal rules, regulations, and laws.

See Index of Section 8 Policies below.

For more information, visit the Office of Industry Engagement's website at http://industry.gatech.edu/.

Also, we encourage you to visit Georgia Tech's Guide for Responsible International Activities website at https://research.gatech.edu/gt-community/international-activities.

 

8.1 Foreign Sponsors

8.1 Foreign Sponsors
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:21
Policy No
RESEARCH 8.1
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Reason for Policy

Georgia Tech encourages international collaborations. The International Contracts and Technology Transfer group within Industry Engagement serves as the point of contact for all international sponsored projects. ICTT facilitates international collaborations and helps assure compliance with Georgia Institute of Technology policies, as well as state and federal rules, regulations, and laws.

Policy Statement

Projects are considered international when sponsored by a foreign government or by a private entity based in a foreign nation, regardless of where the work is to be performed. Examples of foreign sponsors are foreign governments and governmental agencies, foreign universities, non-U.S. domiciled companies (defined as a company legally organized and originally incorporated under the laws of a foreign country), and non-U.S. non-governmental organizations and foreign public charities.

Agreements with foreign sponsors will generally provide that English is the operative language, that advance payments are made, and that all payments are made in U.S. dollars.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

8.2 Compliance Requirements for International Agreements and Sub agreements

8.2 Compliance Requirements for International Agreements and Sub agreements s1polics Thu, 04/21/2016 - 10:22

See below for index of sub-sections of 8.2: Compliance Requirements for International Agreements and Sub agreements.

8.2.1 Export Controls Policy

8.2.1 Export Controls Policy
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:24
Policy No
RESEARCH 8.2.1
Effective Date
Last Revised
Policy Owner
The Office of the General Counsel
Contact Name
Office of the General Counsel
Contact Email
export@gatech.edu
Reason for Policy

The export of equipment and information including technical data, software and hardware is controlled by federal regulations such as the Export Administration Regulations (EAR) and the International Traffic in Arms Regulations (ITAR). Information such as brochures, proposals, site visits and technical discussions are deemed "technical data." Exporting information or talking to a foreign sponsor (either in the U.S. or abroad) about certain types of technical data which may have a possible military application requires a State Department export license, which may take up to three months to obtain. Exporting information or a commodity which does not have significant military application usually requires obtaining one or more of the following: an assurance which precludes reexport; supporting documentation; or a Commerce Department export license. Export of some items to certain countries and some types of subcontracts with those countries are prohibited altogether.

Policy Statement

Proposals to foreign sponsors submitted to the Office of Corporate and International Contracting are provided to the Office of the General Counsel for review and will not be sent to the sponsor before approval is received. It is strongly advised that proposals be submitted to the Office of Corporate and International Contracting at least 5 business days before the sponsor deadline to allow for this review. Proposals will not be submitted without export review.

For more information: export.gatech.edu

Scope

This policy applies to all Georgia Tech Faculty, Staff, and Students.

Policy History
Revision Date Author Description
7-15-2021 OGC/GTRC Updated owner
12-31-2013 GTRC-ORIA Rev 1.0

8.2.2 Foreign Corrupt Practices Act (FCPA) Policy

8.2.2 Foreign Corrupt Practices Act (FCPA) Policy
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:27
Policy No
RESEARCH 8.2.2
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

It is the policy of Georgia Tech that each of our employees, faculty, staff, agents, representatives, vendors and other third parties that work with GIT, GTRC and GTARC comply with the anti-bribery laws of the United States and of the foreign countries where Georgia Tech does business. Bribery of any kind in the United States and abroad, regardless of foreign custom or practice, is strictly prohibited. No Georgia Tech employee, faculty, staff, agent, representative, vendor or any other third party with which Georgia Tech works shall make any payment or provide anything of value, to any person, in order to improperly influence that person to secure any advantage for Georgia Tech, including obtaining or retaining business, or directing business to any person or entity. It is also the policy of Georgia Tech that each of its employees, faculty, staff, agents, representatives, vendors and all third parties that work with Georgia Tech make and keep books, records, and accounts, which, in reasonable detail, accurately reflect any transactions and dispositions of the university and any of its subsidiaries or partners. Any contracts involving, directly or indirectly, foreign officials must be in writing and reviewed by the Georgia Tech Office of Legal Affairs prior to execution. The Foreign Corrupt Practices Act (FCPA) is a federal law (15 U.S.C. § 78-dd-21 et seq.) that exists to prevent corrupt practices in international transactions. The Act prohibits bribery of foreign officials and employees who work for foreign governments. The FCPA prohibits the corrupt payment (or offer, promise or authorization of payment) of anything of value to any foreign official or employee, directly or indirectly, for the purpose of obtaining or retaining business, directing business to any person or entity, or securing any improper advantage. The FCPA’s prohibitions are applicable to United States organizations, public or private, and any person, including a foreign person or firm, if they commit a prohibited act in the United States. Further, a United States entity may be held liable under the FCPA for the improper activities of its foreign subsidiaries if the United States entity authorized or participated in the conduct. This policy ensures the Georgia Tech community is aware of, monitors, and complies with this statute.

Scope

This policy applies to all Georgia Tech operations worldwide. It applies to the Institute’s (including subsidiaries) own employees, faculty, and staff. The Institute expects that third parties with whom the university works, i.e., all vendors, representatives, joint venture partners, and other third parties on international operations will comply this policy.

Definitions:

Foreign Officials Foreign Officials as defined by the FCPA includes officials and employees of foreign governments, state-owned enterprises, public international organizations, and political parties, as well as agents and close relatives of these individuals.
Payment The FCPA prohibits paying, offering, promising to pay (or authorizing to pay or offer) money or “anything of value.”
"Anything of Value" Anything of Value as interpreted by the FCPA includes not only cash or cash equivalents, but also trips, donations, and services. The determination is not retail value but whether the recipient subjectively attaches value to the disbursement.
 

 

Enforcement

In addition to the federal civil and criminal fines and penalties imposed by the FCPA itself, violators of this Georgia Tech policy may be subject to disciplinary measures imposed by the Institute. Penalties for violations will vary with the circumstances, but may include termination. If any Georgia Tech employee is unsure about whether they are being asked to make an improper payment, they should not make the payment. They should consult with their supervisor, the Georgia Tech Office of Legal Affairs, or call Georgia Tech’s Ethics Hotline at 1-866-294-5565, or report the instance using our online reporting tool if there is any doubt about the propriety of the payment. Institute policies prohibit retaliation for good faith reporting.

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
 
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

8.2.3 Anti-boycott Compliance Policy; Restrictive Trade Practices

8.2.3 Anti-boycott Compliance Policy; Restrictive Trade Practices
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:29
Policy No
RESEARCH 8.2.3
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

It is the policy of Georgia Tech that that each of our employees, faculty, staff, agents, representatives, vendors and other third parties that work with GIT, GTRC and GTARC comply with all requirements set forth in Title 15 C.F.R. Part 760 (Restrictive Trade Practices or Boycotts) and all related regulations pertaining to boycotts of specific countries.

United States law prohibits any United States person from refusing, agreeing to refuse, or requiring or requesting any other person to refuse to do business with any business concern organized under the laws of a boycotted country, with any national or resident of a boycotted country, or any other person, when such refusal is the result of an agreement, requirement, or request of a boycotting country which runs counter to United States policy.

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

8.2.4 Trafficking in Persons Compliance Policy

8.2.4 Trafficking in Persons Compliance Policy
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:30
Policy No
RESEARCH 8.2.4
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

It is the policy of Georgia Tech that that each of our employees, faculty, staff, agents, representatives, vendors and other third parties that work with GIT, GTRC and GTARC comply with all requirements set forth in 18 U.S.C. 77 §§1581 et. seq. (Peonage, Slavery, and Trafficking in Persons) and all related regulations.

Scope

This policy applies to all Georgia Tech Faculty and Staff..

Enforcement

To report suspected instances of noncompliance with this policy, please visit Georgia Tech’s EthicsPoint, a secure and confidential reporting system, at: https://secure.ethicspoint.com/domain/en/report_custom.asp?clientid=7508

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

8.3 F&A on International Agreements

8.3 F&A on International Agreements
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:33
Policy No
RESEARCH 8.3
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Reason for Policy

Georgia Tech encourages international collaborations. The Office of Industry Engagement serves as the point of contact for all international sponsored projects. This office facilitates international collaborations and helps assure compliance with Georgia Institute of Technology policies, as well as state and federal rules, regulations, and laws.

Policy Statement

In general, the industrial F&A rate applies to all international projects including those funded by foreign governments and foreign government entities.  Any exceptions to the F&A rate for international projects need to be approved in writing by the Office of the Executive Vice President for Research (EVPR). http://policies.gatech.edu/facilities-administrative-fa-cost-rates

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
12-31-2013 GTRC-IE Rev 1.0

9.0 Other Agreements

9.0 Other Agreements
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 10:42
Policy No
RESEARCH 9.0
Effective Date
Last Revised
Review Date
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

Georgia Tech researchers may find it necessary to enter into agreements with entities or individuals outside Georgia Tech to facilitate a research project. Such agreements may describe understandings about roles and responsibilities in a potential research collaboration, permit the exchange of non-public proprietary information or date, or the exchange of materials for use in research. It is the policy of Georgia Tech such agreements shall:

  • Be negotiated by the office responsible for the agreement,
  • Be signed by an individual authorized by Georgia Tech to do so,
  • Include a start date and a termination date consistent with the project, and
  • Become part of the project file for research awards, for human subjects protocols, and IACUC protocols for which the agreement is relevant.

These agreements may be executed by Georgia Institute of Technology, by Georgia Tech Research Corporation, or by Georgia Tech Applied Research Corporation. These agreements themselves are not confidential although material or data exchanged pursuant to them may be considered proprietary.

Non-disclosure Agreements

It is the policy of the Georgia Institute of Technology that when proprietary information must be exchanged and Georgia Tech and an outside partner have determined to enter into a contract, a non-disclosure agreement (NDA) is used to outline the terms under which the proprietary information shall be exchanged. For more information, or to initiate an NDA, visit http://nda.gatech.edu/.

Material Transfer Agreements


A Material Transfer Agreement (MTA) clarifies how the materials may be used and defines rights and responsibilities for both the provider and the recipient. The Office of Industry Engagement handles all incoming and outgoing MTAs. Visit http://mta.gatech.edu/ to determine if an agreement is needed or to initiate an agreement.

Memoranda of Understanding (MoU)

It is the policy of Georgia Tech that when two or more parties wish to engage in a collaborative effort in research, education or other activities that furthers the mission of Georgia Tech that a Memoranda of Understanding [MOU] is utilized. MOUs are legal agreements defining the roles and responsibilities. MoUs do not include terms and conditions for funding, exchange of materials, non-disclosure of proprietary information, licensing or future licensing of intellectual property, or specific research activities. MoUs may, however, describe how agreements for such activities will be negotiated and establish a timeline for doing so. For more information see http://www.legal.gatech.edu/

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 GTRC-IE Rev 1.0

9.1 Non-disclosure Agreements (NDA)

9.1 Non-disclosure Agreements (NDA)
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 13:42
Policy No
RESEARCH 9.1
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

It is the policy of the Georgia Institute of Technology that when proprietary information must be exchanged and Georgia Tech and an outside partner have determined to enter into a contract, a non-disclosure agreement (NDA) is used to outline the terms under which the proprietary information shall be exchanged. To initiate an NDA, please complete the NDA Routing Form, which is processed by the Office of Legal Affairs http://www.legal.gatech.edu/

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 GTRC-IE Rev 1.0

9.2 Material Transfer Agreements (MTA)

9.2 Material Transfer Agreements (MTA)
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 13:46
Policy No
RESEARCH 9.2
Effective Date
Last Revised
Review Date
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

A Material Transfer Agreement (MTA) clarifies how incoming or outgoing materials may be used and defines rights and responsibilities for both the provider and the recipient. The Office of Industry Engagement handles all incoming and outgoing MTAs. Visit the MTA website to determine if an agreement is needed or to initiate an agreement.  http://mta.gatech.edu/

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Definition:

Material Transfer Agreement A material transfer agreement is a contract between Georgia Tech Research Corporation and another party that governs the transfer of tangible research materials including but not limited to chemicals and biological materials such as cell lines, vectors, and plasmids. The MTA defines the rights of the provider and the recipient with respect to the use of the exchanged material and any derivatives.
Policy History
Revision Date Author Description
01-02-2014 GTRC-IE Rev 1.0

9.3 Memoranda of Understanding (MOU)

9.3 Memoranda of Understanding (MOU)
Type of Policy
Administrative
s1polics Thu, 04/21/2016 - 13:48
Policy No
RESEARCH 9.3
Effective Date
Last Revised
Policy Owner
Georgia Tech Research Corp. (GTRC)
Contact Name
Kevin Wozniak
Contact Title
Executive Director
Contact Email
kevin.wozniak@gtrc.gatech.edu
Policy Statement

It is the policy of Georgia Tech that when two or more parties wish to engage in a collaborative effort in research, education or other activities that furthers the mission of Georgia Tech that a Memoranda of Understanding [MOU] is utilized.  MOUs are legal agreements defining the roles and responsibilities.   MOUs do not include terms and conditions for funding, exchange of materials, non-disclosure of proprietary information, licensing or future licensing of intellectual property, or specific research activities. MOUs may, however, describe how agreements for such activities will be negotiated and establish a timeline for doing so. For more information see http://www.legal.gatech.edu

Scope

This policy applies to all Georgia Tech Faculty and Staff.

Policy History
Revision Date Author Description
01-02-2014 GTRC Rev 1.0

9.4 Software In-Licenses

9.4 Software In-Licenses s1polics Thu, 04/21/2016 - 13:49

10.0 Contracting Services for other Georgia Tech Affiliated Non-profit Entities

10.0 Contracting Services for other Georgia Tech Affiliated Non-profit Entities s1polics Thu, 04/21/2016 - 13:51

10.1 GCMI Agreements

10.1 GCMI Agreements s1polics Thu, 04/21/2016 - 13:52

10.2 BOR Agreements

10.2 BOR Agreements s1polics Thu, 04/21/2016 - 13:53

10.3 GATV Agreements

10.3 GATV Agreements s1polics Thu, 04/21/2016 - 13:53

Research Integrity Assurance Policies

Research Integrity Assurance Policies jbarber32 Fri, 06/22/2012 - 14:22
Review Date

Universities, as partners in the national research enterprise, are required by federal regulations to establish specific research committees to ensure the ethical and safe conduct of research and certain other scholarly activities. The Institutional Animal Care and Use Committee, the three Institutional Review Boards, and the Institutional Biosafety Committee have been established to oversee activities involving, respectively, vertebrate animal subjects, human research subjects, and recombinant DNA (rDNA). These federally mandated faculty committees are administered and supported by the Office of Research Integrity Assurance, which reports to the Vice President for Research. Procedures for obtaining committee approval can be found at www.researchintegrity.gatech.edu.

Institutional Animal Care and Use Committee

Institutional Animal Care and Use Committee jbarber32 Fri, 06/22/2012 - 14:29
Review Date

The Georgia Institute of Technology is committed to ensuring that vertebrate animals used in research and teaching activities receive humane care and treatment. The Institutional Animal Care and Use Committee (IACUC) is charged with reviewing all proposed use of vertebrate animals, regardless of where the work is performed and source of funding, if any. The IACUC has the responsibility and authority to review, approve, disapprove, or require changes in research activities involving vertebrate animals. This committee regularly inspects and monitors the animal care and use facilities and program at the Institute to ensure that all components are in compliance with regulations outlined in the federal Animal Welfare Act, the Public Health Service (PHS) Policy on Humane Care and Use of Laboratory Animals, and with the Eighth Edition of the Guide for the Care and Use of Laboratory Animals.

The animal facilities are registered with the U.S. Department of Agriculture and undergo frequent, unannounced inspections by that agency. Georgia Tech's Animal Welfare Assurance is approved by the Department of Health and Human Services. Committee membership is structured in accordance with federal requirements; members are appointed by the Vice President for Research, who also serves as the Institutional Official for matters related to vertebrate animal subjects.

The IACUC has set forth procedures for reporting, without fear of reprisal, concerns about the humane use and treatment of vertebrate animals used in research and teaching activities at Georgia Tech. The IACUC meets monthly to review research protocols which propose the use of vertebrate animal subjects; committee approval must be obtained prior to initiation of proposed activities.

For more information about the Institutional Animal Care and Use Committee, please see the Institutional Animal Care and Use Committee website.

Institutional Biosafety Committee

Institutional Biosafety Committee jbarber32 Fri, 06/22/2012 - 14:41
Review Date

The Institutional Biosafety Committee (IBC) is responsible for reviewing all registrations for research, teaching, and training that involve the use of recombinant DNA by Georgia Tech faculty, staff or students and ensuring that the proposed activities comply with the federal NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules and all other applicable regulations. All scholarly activities involving recombinant DNA, regardless of source of funding, must be reviewed by the IBC. The Committee has the responsibility and authority to review, approve, disapprove, or require changes in research, teaching, and training activities involving recombinant DNA materials.

Georgia Tech's Institutional Biosafety Committee is registered with the National Institutes of Health's Office of Biotechnology Activities (OBA). IBC works closely with Georgia Tech's Biosafety Officer in the Office of Environmental Health and Safety. Committee membership is structured in accordance with federal requirements. Members are appointed by the Executive Vice President for Research, who is also the Institutional Official for matters related to the Biosafety Committee. The IBC holds meetings as needed to review registrations.

For more information about Institutional Biosafety Committee, please see the Institutional Biosafety Committee website.

Institutional Review Boards

Institutional Review Boards jbarber32 Fri, 06/22/2012 - 14:26

Georgia Tech subscribes to the basic ethical principles that underlie the conduct of biomedical and behavioral research involving human subjects as set forth in the Belmont Report, the timeless statement of ethical principles and guidelines for the protection of human subjects published in 1979 by the National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research.

The three Georgia Tech Institutional Review Boards are charged with protecting the rights and welfare of human subjects participating in research projects conducted by Georgia Tech faculty, staff, or students. These include the Central IRB, the Joint Georgia State University-Georgia Tech IRB for the Advanced Brain Imaging Center, and the Classified IRB. The IRBs have the responsibility and authority to review, approve, disapprove, or require changes in research activities involving human subjects. All proposed research activities involving human subjects, regardless of source of funding or study location, must be reviewed and approved by the appropriate Georgia Tech Institutional Review Board (IRB) prior to initiation of research. The IRBs hold regularly scheduled meetings to review research protocols involving human subjects.

Georgia Tech's Federalwide Assurance is approved by the Department of Health and Human Services, and the Institutional Review Boards are registered with the Department of Health and Human Services, Office for Human Research Protections.

Committee members are appointed by the Vice President for Research, who also serves as the Institutional Official for matters related to human subjects. Membership is structured in accordance with federal requirements set forth in Title 45 Code of Federal Regulations Part 46, Federal Policy for the Protection of Human Subjects including Subparts A, B, C, and D, and in Title 21 Code of Federal Regulations, Parts 50, 56, 312, and 812.

For more information about the Institutional Review Board, please see the Institutional Review Boards website.

Protecting Sensitive Data

Protecting Sensitive Data jbarber32 Fri, 06/22/2012 - 14:57

Protecting Sensitive Data in Electronic Format and Best Practices for Backing Up Sensitive Data

  • The Office of Information Technology (OIT) provided this guidance for the Office of Research Integrity Assurance to share with faculty and other researchers who possess sensitive data, particularly those data that involve human subjects and for which confidentiality is essential. Detailed safeguard recommendations for protecting sensitive data are posted on OIT’s site.
  • These safeguards are highlighted here:
    • Store data only on a laptop/desktop with whole disk encryption. This will protect the data in the event the machine is stolen.
    • Back up the data regularly to a professionally-managed file server that is protected and backed up on a routine schedule. Talk with OIT or a CSR for more information on options.
    • Back up data to a tape or drive that is managed by OIT or the researcher’s unit. Back ups should be encrypted and stored in a physically secure location.
    • Machines on which data reside should be fully patched with the latest security patches.
    • Limit access to the data strictly to those with legitimate need. For example, do not store data on a public-facing web server or Prism account.

For more information about Protecting Sensitive Data, please see: "Protecting Sensitive Data in Electronic Format and Best Practices for Backing Up Sensitive Data"

Responsible Conduct of Research

Responsible Conduct of Research
Type of Policy
Administrative
jbarber32 Fri, 06/22/2012 - 14:45
Last Revised
Review Date
Policy Statement

Georgia Tech students and trainees engaged in research at the undergraduate, graduate and post-doctoral levels shall receive formal instruction in ethical considerations and decision making in Responsible Conduct of Research that is appropriate for their disciplines and for the stages of their research careers. This policy is intended to comply with the requirements of the National Science Foundation’s (NSF) implementation of the requirements of Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science Act (42 U.S.C. 1862o–1) found in the NSF Award and Administration Guide, Chapter IV, and National Institutes of Health (NIH) requirements found in NOT-OD-10-019*.
Responsible Conduct of Research (RCR) is defined by NIH “…as the practice of scientific investigation with integrity. It involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research.”

For more information about Responsible Conduct of Research, please see: "Responsible Conduct of Research"

Policy History
Revision Date Author Description
08-2013 Policy Library Fixed Responsible Conduct of Research external link

Environmental Health and Safety

Environmental Health and Safety jgastley3 Sat, 07/07/2012 - 21:06

Environmental Health and Safety (EHS) is a unit within Facilities Management and consists of the following offices and services.

  • Biosafety
  • Environmental Programs
  • Fire Safety
  • General Safety
  • Hazardous Waste
  • Lab & Chemical Safety
  • Occupational Health Program
  • Radiation Safety
  • Shipping

EHS develops programs and provides oversight, consultation, training, and other specialized services to assist the Institute community in meeting its public health, safety, environmental protection, and compliance responsibilities.

Georgia Tech's Environmental Health and Safety Policies are found in the Campus Use & Facilities Policy Book in this library, linked here.The Environmental Health and Safety department website can be found at:  http://ehs.gatech.edu/ 

Intellectual Property

Intellectual Property abruneau3 Mon, 03/25/2013 - 14:39

Intellectual Property
Georgia Tech's Intellectual Property policies apply, as a condition of employment, to all full or part-time faculty and staff of the Institute. The Institute's policy also applies to students although the conditions in which students are required to execute an assignment of intellectual property agreement are different and described in the policy.

Intellectual Property Policies
Georgia Tech's Intellectual Property Policies can be found in the Faculty Affairs section of the Faculty Handbook in this Policy Library, and linked below. http://policylibrary.gatech.edu/faculty-handbook/5.4-intellectual-property-policy 

Intellectual Property Assignment Agreement
Georgia Tech's Intellectual Property Assignment Agreement is signed during employee onboarding and can be found here: http://ipagreement.gtrc.gatech.edu/index.html 

Technology Licensing and Invention Disclosures
The Office of Technology Licensing, as a function of the Georgia Tech Research Corporation, manages licensing and intellectual property affairs.  For more information on the Office of Technology Licensing, including the online Invention Disclosure system, staff contacts, and more, visit: http://licensing.research.gatech.edu/ 

Responsible Conduct of Research Compliance Policy

Responsible Conduct of Research Compliance Policy
Type of Policy
Administrative
s1polics Tue, 12/15/2015 - 15:16
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

Georgia Tech’s Responsible Conduct of Research (RCR) Compliance Policy is intended to comply with the requirements of the National Science Foundation’s (NSF) implementation of the requirements of Section 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science Act (42 U.S.C. 1862o–1) found in the NSF Proposal and Award Policies and Procedures Guide, the National Institutes of Health (NIH) requirements found in NOT‐OD‐10‐019, and the U.S. Department of Agriculture (USDA) National Institute of Food and Agriculture (NIFA) program’s RCR training requirements. The applicability criteria contained within this Policy (see below) may expand to cover other groups of researchers and sponsors in the future. RCR is defined by the NIH “…as the practice of scientific investigation with integrity. It involves the awareness and application of established professional norms and ethical principles in the performance of all activities related to scientific research.”

Policy Statement

It is the policy of the Georgia Institute of Technology that undergraduate students, graduate students, and postdoctoral researchers on covered awards who are engaged in research shall receive formal instruction in ethical considerations and decision‐making in Responsible Conduct of Research (RCR) that is appropriate for their disciplines and career stage. Faculty, staff, and other members of the Georgia Tech community must complete RCR training as well if the sponsor of their research imposes the requirement.

It is the responsibility of the Principal Investigator/Project Director (PI/PD) of covered awards (see Applicability below) to ensure that all applicable research team members are informed of the requirement and that the requirement has been met. In the case of the NSF Graduate Research Fellowship Program (GRFP), these responsibilities will be shared between the graduate advisor and the Coordinating Official in the Fellowship Office. Moreover, it is the PI’s responsibility to provide appropriate mentoring through discussions of RCR topics and through oversight of the research project.

Scope

The RCR Compliance Policy requires that students, postdoctoral researchers, faculty, and staff receiving research funds or who participate in research activities funded by Georgia Tech’s President’s Undergraduate Research Award Program (PURA) and certain covered awards (see applicability below) shall engage in a program of study in RCR that includes some or all of the following elements:

  • Authorship and publication
  • Collaborative research, including collaborations with industry
  • Conflicts of interest including personal, professional, and financial
  • Data acquisition, management, sharing, ownership and reporting
  • Mentor/mentee responsibilities and relationships, including how to support a respectful, inclusive environment and prevent harassment
  • Peer review
  • Policies regarding human subjects in research
  • Policies regarding live vertebrate animal subjects in research
  • Policies regarding safe laboratory practices
  • Research misconduct and policies for handling research misconduct
  • The scientist and engineer as a responsible member of society, and the environmental and societal impacts of scientific research

Applicability
This Policy is intended to meet the RCR training requirements of federal funding agencies and other sponsors. The applicability criteria contained within this Policy may expand to cover other groups of researchers and sponsors in the future.

This Policy covers:

GT PURA ­­– This Policy applies to all students who participate in Georgia Tech’s President’s Undergraduate Research Award (PURA) Program.

NSF ­­– This Policy applies to all undergraduate students, graduate students, and postdoctoral researchers, whether as an employee, Graduate Research Assistant (GRA), or other trainee, funded by new proposals submitted, or due, on or after January 4, 2010, to conduct research; it excludes, for example, conference, symposium, workshop, and travel proposals. The Policy also applies to students funded by the NSF GRFP Fellowship.

NIH ­­– This Policy applies to the NIH programs listed here. All undergraduate students, graduate students, and postdoctoral researchers funded by an NIH training grant, a career development award (individual or institutional), a research education grant, a fellowship, or a dissertation research grant must receive RCR instruction, with the exception of those funded by the K99/R00 program. For the K99/R00 program, only the PI (fellow) of the project is required to complete the RCR training.

USDA NIFA ­­– This Policy applies to all researchers funded by the USDA National Institute of Food and Agriculture (NIFA) program, including the principal investigator, other faculty members, students, postdocs, and any staff participating in the research project.

Policy Terms
RCR

Responsible Conduct of Research

Procedures

5.1 Training Requirements by Funding Source and Career Stage

President's Undergraduate Research Awards (PURA) Program
All undergraduate students participating in Georgia Tech’s PURA Program must complete the online RCR training from the Georgia Tech approved vendor. (http://www.rcr.gatech.edu/pura).

The mentors of students funded by the PURA Program are strongly encouraged to provide discussion-based training opportunities for these students as well.

Undergraduate Students Funded by Covered NSF or NIH Awards
All undergraduate students paid in whole or in part from covered awards funded by NSF or NIH must complete both: (1) online RCR training from the Georgia Tech approved vendor and (2) in-person RCR training.

Applicable NSF-funded undergraduates must complete at least 1 hour of discussion-based RCR instruction; it is strongly encouraged that this instruction be focused on the topic of research misconduct.  NIH-funded undergraduates must complete at least 8 hours of discussion-based (“in-person”) RCR instruction.  At the discretion of the PI or School, applicable undergraduate students shall fulfill the discussion-based (“in-person”) RCR training requirement by either:

  • Participating in OSP approved RCR training events (www.rcr.gatech.edu/workshops); or
  • Participating in educational events that the PI or School has deemed appropriate for RCR training, which can include regularly scheduled meetings or discussions involving the research team that address RCR topics; or it can involve a class, seminar, or other interactive approach developed by the School or PI that addresses RCR topics.‡

UNDERGRADUATE
IN-PERSON RCR TRAINING
REQUIREMENT

Funding Source and Hours Required

Training Options

NSF - 1 HOUR

  • OSP approved RCR Training Events
  • Research Team Meetings‡
  • Other events approved by the PI or School‡

NIH - 8 HOURS

‡ Documentation of this form of in-person training must be maintained in the project file by the PI.  All other training will be documented in either the Research Administration Education & Compliance training system or in Banner.

NSF-Funded or NIH-Funded Master’s Students
All master’s students paid in whole or in part from covered awards funded by NSF or NIH must complete both: (1) online RCR training from the Georgia Tech approved vendor and (2) in-person RCR training.

Applicable NSF-funded master’s students must complete at least 2 hours of discussion-based RCR instruction.  NIH-funded master’s students must complete at least 8 hours of discussion-based RCR instruction. At the discretion of the PI or School, applicable master’s students shall fulfill the “in-person” requirement by either:

  • Participating in OSP approved RCR training events (www.rcr.gatech.edu/workshops);  or
  • Registering through Oscar and successfully completing an approved RCR course  (http://rcr.gatech.edu/rcr-courses); or
  • Participating in educational events that the PI or School has deemed appropriate for RCR training, which can include regularly scheduled meetings or discussions involving the research team that address RCR topics; or it can involve a class, seminar, or other interactive approach developed by the School or PI that addresses RCR topics.‡

MASTER’S STUDENT
IN-PERSON RCR TRAINING
REQUIREMENT

Funding Source and Hours Required

Training Options

NSF - 2 HOURS

  • OSP approved RCR Training Events
  • Approved RCR course                        
  • Research Team Meetings‡
  • Other events approved by the PI or School‡

NIH - 8 HOURS

‡ Documentation of this form of in-person training must be maintained in the project file by the PI.  All other training will be documented in either the Research Administration Education & Compliance training system or in Banner. 

NSF-Funded or NIH-Funded Doctoral Students
Doctoral students paid in whole or in part from covered awards funded by NSF or NIH must adhere to the training requirements delineated within the GT RCR Academic Policy for Doctoral Students (http://www.rcr.gatech.edu/doctoral-policy/).

NSF-Funded or NIH-Funded Postdoctoral Researchers
All postdoctoral researchers paid in whole or in part from covered awards funded by NSF or NIH must complete both: (1) online RCR training  from the Georgia Tech approved vendor and (2) in-person RCR training.

Applicable NSF-funded postdoctoral researchers must complete at least 4 hours of discussion-based RCR instruction and NIH-funded postdoctoral researchers must complete at least 8 hours of discussion-based RCR instruction in order to satisfy the in-person training requirement. At the discretion of the PI or School, applicable postdoctoral researchers shall fulfill the “in-person” requirement by either:

  • Participating in educational events that the PI or School has deemed appropriate for RCR training, which can include regularly scheduled meetings or discussions involving the research team that address RCR topics; or it can involve an interactive approach developed by the School that addresses RCR topics.‡

POSTDOCTORAL
IN-PERSON RCR TRAINING
REQUIREMENT

Funding Source and Hours Required

Training Options

NSF - 4 HOURS

  • OSP approved RCR Training Events
  • Receive permission to attend PHIL 6000
  • Research Team Meetings‡
  • Other events approved by the PI or School‡

NIH - 8 HOURS

‡ Documentation of this form of in-person training must be maintained in the project file by the PI.  All other training will be documented in either the Research Administration Education & Compliance training system or in Banner.

USDA NIFA-Funded Students, Postdoctoral Researchers, Faculty, and Staff
All researchers funded through the National Institute of Food and Agriculture (NIFA) program, including the principal investigator, other faculty members, students, postdocs, and any staff participating in the research project (defined as those who are funded by the project), must complete an online RCR training from the Georgia Tech vendor.

The PIs of projects sponsored by NIFA are strongly encouraged to provide discussion-based training opportunities for their research team as well.

5.2 Re-training Requirements

Change of Career Stage
Any applicable student who received RCR training during one career stage at Georgia Tech (for example, as an undergraduate) and is required to complete RCR training after changing to a different career stage at the Institute (for example, by becoming a master’s student) must at a minimum complete any additional RCR training requirements associated with the latter career stage. A postdoctoral researcher in this circumstance who received RCR training as a doctoral student at Georgia Tech must complete at least 1 additional “in-person” training hour. Applicable students and postdocs must also adhere to any re-training requirements imposed by their funding source. 

NIH-Funded Students or Postdoctoral Researchers
According to the NIH, “Reflection on responsible conduct of research should recur throughout a scientist’s career: at the undergraduate, post-baccalaureate, predoctoral, postdoctoral, and faculty levels ... Instruction must be undertaken at least once during each career stage, and at a frequency of no less than once every four years.”

The PIs of covered NIH projects are required to develop an RCR training plan that addresses the re-training requirement and ensure that their trainees adhere to that plan.

5.3 Deadline for Training Completion

Online Training Deadline

The online training requirement described within this Policy, must be successfully completed within ninety [90] days of first being appointed to a covered award. Even if it imposes a shorter deadline, the online training requirement must be completed before an applicable person graduates or otherwise leaves the Institute.

In-Person Training Deadline
The “in-person” RCR training requirements described within this Policy must be completed within the first year of the appointment to the covered award. Even if it imposes a shorter deadline, the in-person training must be completed before the applicable person graduates or otherwise leaves the Institute.

A doctoral student funded by a covered award must follow the in-person completion deadline delineated in this Policy unless the “in-house” RCR course required by their home academic unit is not offered during the first year of the student’s doctoral program. However, if an applicable doctoral student is unable to complete the required in-person RCR training prior to graduating or leaving the Institute, the student must, at a minimum, have an RCR exit interview with the PI/advisor.

5.4 Pre-Award Procedures

RCR Instruction Plan
Compliance with the requirements for providing RCR instruction is a responsibility of the PI.  As such, the PI for covered proposals, with the exception of the PI for NSF GRFP Fellows, shall complete the RCR Project Plan Addendum to the Sponsored Programs/Research Proposal Authorization Routing Form at the time an applicable proposal is submitted.* This Plan should indicate which instruction method(s) will be used for those individuals who are appointed to the project and are required to complete RCR training.  It shall become part of the project file in the Office of Sponsored Programs (OSP). 

* The training requirement for covered proposals will be flagged "Yes" in the OSP Oracle Database under T&C Ethics/RCR Training and in the Research Portal under "Effort on My Funds". 

5.5 Post-Award Procedures

Online Training
The Office of Grants & Contracts Accounting will prepare reports of applicable students, postdoctoral researchers, faculty, and staff that are paid from applicable projects and will check these individuals against CITI records.  PIs, the School, or the Fellowship Office will be notified of any non‐compliance of those who are required to complete CITI training.

 

Documentation of online RCR training is accomplished through the CITI Program; records will be maintained in the Research Administration Education & Compliance training system.

In-Person Training
Documentation of in-person training that has been taken to satisfy the RCR Compliance Policy is the responsibility of the PI unless the training has been completed through an OSP approved RCR training event (http://www.rcr.gatech.edu/workshops) or through an approved RCR course (http://www.rcr.gatech.edu/rcr-courses).  OSP approved RCR training events will be documented in the Research Administration Education & Compliance training system; RCR courses will be documented in Banner.

Training Certification
It is the PI’s responsibility to certify on an annual basis that all students and postdoctoral researchers funded by the project are in compliance with RCR training requirements. The Annual RCR Certification must be made via the OSP Deliverable System.

Responsibilities

The Principal Investigator (PI)
The PI is responsible for:

  • Filling out the RCR Project Plan Addendum to the Sponsored Programs/Research Proposal Authorization (as described in 5.4);
  • Notifying the research team of any applicable RCR training or re-training requirements;
  • Ensuring that the research team completes the RCR training;
  • Retaining records in the project file (as described in 5.5);
  • Certifying to OSP on an annual basis that the RCR training has been completed (as described in 5.5); and
  • If a covered NIH project, preparing a plan to address the re-training requirements (as described in 5.3).

Office of Sponsored Programs (OSP)
The OSP is responsible for:

  • Notifying PIs about the RCR training requirements via terms and conditions in the project initiation package;
  • Retaining records of online RCR training completions;
  • Notifying trainees, staff, and/or PIs of  non-compliance of online RCR training requirements; and
  • Retaining records of attendance at OSP- approved RCR workshops and events.

Coordinating Official (Fellowship Office)
The Coordinating Official for the Fellowship Office is responsible for:

  • Advising NSF GRFP Fellows on RCR policies and training requirements;
  • Communicating with the RCR Program about new GRFP fellows;
  • Working with the GRFP Fellow’s graduate advisor to ensure that the training is completed;
  • Working with the GRFP Fellow’s graduate advisor to obtain the necessary verifications required by NSF which confirm that all responsibilities have been fulfilled;
  • Certifying Satisfactory Academic Progress;
  • Working in coordination with the PI and the RCR Program on the annual RCR certification that is submitted to OSP;
  • Retaining records of in-person training completed outside of OSP approved events or approved RCR courses.
Enforcement

Students and Postdoctoral Researchers
Non‐compliance with the training completion deadlines specified in this Policy on the part of any employed student or postdoctoral researcher may result in the termination of employment and shall result in the disallowance of salary and any associated expenses charged to the sponsored award.

Non-compliance on the part of any NSF Graduate Research Fellow shall result in the failure to certify the Fellow’s Satisfactory Academic Progress and may result in the termination of the Fellowship.

Faculty and Staff
Non-compliance with the training completion deadlines specified in this Policy by faculty or staff on a USDA NIFA award shall result in the disallowance of salary and any associated expenses charged to the sponsored project.

Non-compliance by the PI on a USDA NIFA award may also result in the removal of the PI from the project and the appointment of a replacement PI.

Policy History
Revision Date Author Description
01-01-2016 OSP Compliance Updates
     

 

Combating Trafficking In Persons Policy

Combating Trafficking In Persons Policy
Type of Policy
Administrative
s1polics Fri, 02/12/2016 - 12:39
Effective Date
Last Revised
Review Date
Policy Owner
Sponsored Programs, Office of
Contact Name
Cynthia Hope
Contact Title
Interim Vice President for Research Administration
Contact Email
cindy.hope@osp.gatech.edu
Reason for Policy

The United States Government has adopted a zero tolerance policy regarding trafficking in persons. These statutes and regulations require federal grant recipients and contractors to prohibit the use of research funds received from federal sources for promotion of prohibited activity.

Policy Statement

Georgia Institute of Technology opposes prostitution, forced labor and any related activities contributing to the phenomenon of trafficking in persons. Trafficking in persons is a violation of U.S. Law and recognized as a violation of human rights.

Related Regulations
18 USC Section 1581
45 CFR Section 52.222-50

Applicability

This policy applies to all researchers at Georgia Tech and all employees or students who assist these researchers or participate in performing tasks related to such research activities.

Definitions

Trafficking in Persons The United States government considers trafficking in persons to include all of the criminal conduct involved in forced labor and sex trafficking, essentially the conduct involved in reducing or holding someone in compelled service. [More]
Procedures

Report any violations via Ethics Point which can be found online at https://secure.ethicspoint.com/domain/media/en/gui/7508/index.html.

Responsibilities

Report any violations via Ethics Point which can be found online at https://secure.ethicspoint.com/domain/media/en/gui/7508/index.html.

Enforcement

Non-compliance with this policy would be a violation of U.S. law. Georgia Tech will take action for violation of this policy including, but not limited to, removal from the contract, taking disciplinary action up to and including termination of employment.

Policy History
Revision Date Author Description
04/08/2016 OSP New Policy

 

Grants and Contracts Accounting (Administration & Finance)

Grants and Contracts Accounting (Administration & Finance) kcross8 Mon, 08/31/2020 - 14:17

Grants and Contracts Accounting

Grants and Contracts Accounting is part of Financial Services within the Division of Institute Planning and Resource Management (IPRM)--reporting to Georgia Tech's Division of Administration and Finance.

Institute Planning and Resource Management Offices support the Georgia Institute of Technology in fulfilling its mission of research, education, and public service.

Grants and Contracts Accounting Policies can be found in the Business and Finance Policy Book in the Policy Library, here.

For more information, including regulatory information, manuals and more, visit:
http://grants.gatech.edu/policies-and-procedures 

Insider Threat Program and Reporting Policy

Insider Threat Program and Reporting Policy kcross8 Fri, 09/24/2021 - 10:30
Effective Date
Review Date
Policy Owner
Georgia Tech Research Institute (GTRI)
Contact Name
Research Security/Insider Threat Program
Contact Names
Dannie Lyvers
Contact Title
Insider Threat Program Senior Official
Contact Email
dannie.lyvers@gtri.gatech.edu
Reason for Policy

The Department of Defense has designated the Georgia Institute of Technology (“Georgia Tech”) a Cleared Defense Contractor (CDC), which gives Georgia Tech clearance to receive and store certain classified and sensitive information for the purpose of providing critical services and innovative solutions to various military defense and national security projects. Certain Georgia Tech personnel must protect the information and prevent nefarious actors, who may use deceptive tactics meant to appear as if permitted by Georgia Tech, from accessing the information. The requirements of safeguarding information mandates that Georgia Tech establish and maintain an Insider Threat Program that safeguards sensitive information from theft and follows specific government security protocols. The Insider Threat Program serves to gather, integrate, and report relevant information of potential or actual insider threats, in compliance with Federal Law and established security best practices; including Executive Order (E.O.) 13587 and 32 Code of Federal Regulation (CFR) Part 117, National Industrial Security Program Operator’s Manual (NISPOM).

Policy Statement

As a CDC, Georgia Tech will provide security measures to all personnel to understand how to identify potential or actual insider threat red flags at a variety of workplace locations such as but not limited to; locally on-campus, off-campus at various geographic locations, telework, etc., and how to become familiar with reporting the observation(s) of insider threat red flags. Once reported, the Research Security Insider Threat Program will deliver ample information to employ risk management principles, analytical methodologies, and investigative techniques tailored to meet the distinct needs of each reported observation. Appropriate protections will comply with privacy, civil rights, and civil liberties of both the reporter and reported.

Scope

The policy applies to all Georgia Tech employees and all other individuals granted authorized access to Georgia Tech personnel, facilities, data, information, networks, and servers. In addition, the policy covers all geographically separated and remote working locations where employees are conducting work assignments for Georgia Tech.

Policy Terms

Cleared

Personnel to whom the Department of Defense (DOD) grant eligibility determinations or who are being processed for access to classified information.

Uncleared

Personnel to whom the DOD did not grant or who are not being processed for access to classified information.

Insider Threat

The likelihood, risk, or potential that inside personnel will use their authorized access, wittingly or unwittingly, to do harm.

Responsibilities

In order for Georgia Tech to provide accurate, timely, and effective protections to assets and resources, Georgia Tech’s Insider Threat Program Working Group (ITPWG) communicates, reviews, and analyzes data identifying trends indicating potential insider threat risk. The ITPWG is comprised of senior leaders representing identified institution stakeholders including but not limited to: Research Security, the Office of the General Counsel (OGC), OGC and Georgia Tech Research Institute (GTRI) Office of Ethics and Compliance, the Office of Information Technology, Georgia Tech Cyber Security, Georgia Tech Human Resources, GTRI Talent Management Department, GTRI Information Systems Department, GTRI Chief Legal Counsel and the Georgia Tech Police Department. The ITPWG members support the Insider Threat Program through delivery of information obtained through the performance of their assigned responsibilities.

Specific Insider Threat Program responsibilities are:

5.1 Director Research Security
Direct oversight of Insider Threat Program operations, as well as compliance with federal regulations and institutional policies.

5.2 Insider Threat Program Senior Official (ITPSO)
5.2.1 Is responsible for the program’s daily operations, management, and compliance with federal regulations.

5.2.2 Constructs and manages Georgia Tech’s ITPWG.

5.2.3 Will employ risk management principles, analytical methodologies, and investigative techniques to all actual or potential insider threat reported situations.

5.2.4 Will submit in writing reports to the Federal Bureau of Investigations (FBI) and Defense Counterintelligence and Security Agency (DCSA) pertaining to all actual, probable, or possible espionage, sabotage, terrorism, or subversive activities at any of Georgia Tech’s locations as outlined in 32 CFR Part 117.

5.2.5 Will ensure all cleared personnel complete insider threat training consisting of but not limited to: counterintelligence security fundamentals; procedures for conducting insider threat response actions; applicable laws and regulations regarding the gathering, integration, retention, safeguarding, and use of records and data including consequences of misuse; applicable legal, civil liberties and privacy policies applicable to the insider threat program.

5.3 All Georgia Tech Personnel
5.3.1 To protect the Georgia Tech brand and reputation, all GT personnel will utilize available resources through Research Security to report and identify potential insider threats. By doing so, maximum protection of all Georgia Tech personnel, facilities, data, information, networks, and servers will be achieved.

5.3.2 Georgia Tech Cleared Personnel
All cleared personnel are required to report both personal disclosures and any observations of others in the following categories to Georgia Tech’s Facility Security Officer: any questioning of an individual’s allegiance to the United States, all indications of the presence of improper foreign influence, any indication of foreign preference, any personal misconduct, all unexplained financial affluences, any changes in alcohol consumption behavior, any illegal drug use, possession, or distribution, all criminal misconduct, all situations of mishandling protected information, any conflicting outside activities, and all indications of misuse of information technology. Additionally, cleared personnel are required to report all foreign travel; business and life changing events, such as but not limited to, divorce or positive or negative financial affluence.

Enforcement

To report suspected instances of insider threat indicators, please visit the anonymous Insider Threat Program Reporting tool at: https://gtri.gatech.edu/insider-threat-reporting-tool.

Policy History
Revision Date Author Description
09-2021 Research Security/Insider Threat Program New Policy

Office of the General Counsel

Office of the General Counsel kcross8 Fri, 07/16/2021 - 13:58

Export Control

Export Control jbarber32 Fri, 06/22/2012 - 14:44
Review Date

Research is a global endeavor and international experiences and opportunities are vital in preparing Georgia Tech’s students to become leaders who meet the challenges of the future. It is sometimes challenging to conduct these programs in compliance with complex laws and regulations that change frequently.
 

Because you, as an individual, and Georgia Tech can be held liable for improperly transferring controlled technology it is important that you review these federal requirements.
 

What is Export Control?
“Exports” include:

  • Verbal communication
  • Transfer of written documents, and
  • Transfer of U.S. computer software to a foreign national whether in the U.S. or abroad if the technology is controlled by export regulations.

The determination of whether a technology is controlled is critical in determining whether export control laws and regulations apply to the activity. To find out if technologies or data are controlled, check the Export Administration Regulations (EAR) and International Traffic in Arms Regulations (ITAR) control lists and contact the Office of Legal Affairs or by phone at 404.894.4812. Please refer to the both the EAR and ITAR web sites for a more general overview of the regulations regarding each of the above mentioned control lists.
 

As defined in these laws, technology includes information related to the design, development, or production of equipment or software. Transfers of listed technologies to non-U.S. persons or entities in the form of drawings, schematics, blueprints, research results, formulae, meetings, symposiums, classroom discussions, conversations, email, etc, are controlled.
 

If any controlled information, technology, software, or equipment will be transferred to another party overseas or to a foreign party in the United States, a license must be obtained prior to the transfer unless a valid licensing exception or exclusion applies.

For more information about Export Control, please see the Export Control website.