Research Policies

Research policies focus on topics related to the financial, administrative and compliance requirements involved in the lifecycle of research. 

The intended audience for these policies includes students, faculty and staff directly involved in research.

Compliance

Classified Research (PDF)

It is the general policy of the university not to accept or perform research that is considered classified.

Export Control (PDF)

It is the policy of the university to comply with U.S. export control laws. Export control laws restrict certain types of information, technologies, and commodities that can be transmitted overseas to individuals, including U.S. citizens, or made available to foreign nationals on U.S. soil. It is the responsibility of faculty and administrators to be aware of and comply with these laws and the university’s written instructions and procedures.

Public Access to NIH-Funded Publications (PDF)

All peer-reviewed articles arising from research funded by the National Institutes of Health (NIH) must be submitted to NIH’s PubMed Central to be made publicly available no later than 12 months after the date of publication. Researchers citing articles they authored or co-authored, or that otherwise arose from their NIH-funded award, must include the PubMed Central reference number in the citation.

Policy and Procedures Regarding Allegations of Research Misconduct (PDF)

Research misconduct includes, without limitation, fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or in reporting research results. All employees or individuals associated with George Washington University should report observed, suspected, or apparent misconduct in research to the Research Integrity Officer (RIO).

Policy for Compliance Regarding Select Agents and Pathogens (PDF)

Any activity involving Select Agents or Pathogens requires prior review and approval by the Institutional Biosafety Committee (IBC). Activity involving Select Agents (other than exempt quantities of listed Toxins) also requires express written permission from the Associate Vice President for Research. All IBC-approved activities involving Select Agents or Pathogens must be conducted in accordance with this policy. Failure to comply with this policy may result in disciplinary action up to and including termination.

Policy Regarding Treatment of Human Research Subjects (PDF)

Prior to any activity that involves human subjects, the proposal must be submitted to the university’s Office of Human Research (OHR), and reviewed and approved by the university’s Institutional Review Board (IRB). This policy applies to all human subject activity regardless of funding status or source. Engaging in Research activity involving human subjects, or analysis of data gathered from human subjects without prior approval may result in disciplinary action up to and including termination of Research privileges and/or academic appointment.

Subrecipient Monitoring (PDF)

The George Washington University (“university”) evaluates and monitors the financial and programmatic performance of Subrecipients, and assesses their capacity to properly manage a Subaward. The university’s objective is to monitor that sponsor funds are properly spent, that performance goals are met, and that Subrecipients comply with all applicable law, regulations, and prime award terms. The university may impose specific controls, as needed, for certain Subrecipients based on relevant risk factors. The terms of the Subrecipient’s relationship with the university are documented in a written Subaward agreement between the university and the Subrecipient organization.

 

Finance

Cost Sharing on Sponsored Projects (PDF)

It is university policy to comply with all Mandatory Cost Sharing requirements imposed by sponsors and with all Voluntary Cost Sharing commitments made to sponsors by the university. The university does not encourage Cost Sharing unless required by the sponsor. All Committed Cost Sharing is subject to the internal approval requirements of this policy, whether Voluntary or Mandatory. When Voluntary Committed Cost Sharing has been approved for a proposal submission to a sponsor, the commitment must be fulfilled for any resulting award as if the Voluntary Committed Cost Sharing were Mandatory Cost Sharing. All costs proposed in fulfillment of Mandatory or Voluntary Committed Cost Sharing on a sponsored project must be verifiable from the university’s records, necessary and reasonable for the project or program objective, and allowable under the applicable cost principles and administrative regulations, and/or the terms and conditions of the specific award.

Cost Transfers on Sponsored Agreements (PDF)

Under university policy, a cost may be allocated to a sponsored agreement solely on the basis of benefit or relationship to the sponsored agreement, and may not be allocated or shifted to a sponsored agreement to avoid or reduce an overrun on another sponsored agreement, or to avoid a restriction on the charging of the cost to another sponsored agreement, or for other reasons of convenience not related to the benefit received by the sponsored agreement charged. Errors in the allocation of costs to sponsored agreements must be identified, corrected, and documented in a timely and consistent manner. This policy applies to all agreements with both federal and non-federal sponsors. If an individual sponsor or sponsored agreement has more stringent requirements than university policy, the requirements of that sponsor or sponsored agreement shall govern.

Direct Charging of Administrative Costs to Sponsored Projects (PDF)

It is university policy to follow the Office of Management and Budget’s Cost Principles for Educational Institutions, 2 C.F.R. Part 220 (OMB Circular A-21), and other applicable federal requirements with respect to charging Administrative Costs directly to federally-sponsored projects.

Effort Reporting (PDF)

Effort reporting is the process by which the university determines and documents the effort expended on sponsored agreements during each reporting period. The university maintains an effort reporting system and obtains effort certification from employees in compliance with applicable federal regulation. Employees who are compensated in whole or in part by sponsored agreements or whose compensation is cost shared on a sponsored agreement must certify their effort twice a year.

Managing Program Income Generated on Sponsored Projects (PDF)

Program income that is generated from projects funded in whole or in part by federal or non-federal sponsors must be properly identified, used, accounted for and reported on in compliance with sponsor requirements.

Research Administration

Award Management and Closeout (PDF)

The university has a responsibility to manage the sponsored projects life cycle, to comply with policies, and to close out the completed sponsored project(s) in a timely and accurate manner. Award closeout is the final process of documenting and assuring the fulfillment of the terms and conditions of the award, compliance with applicable regulations, and making final disposition of all award by-products such as final vouchers, reports, patent disclosures and property inventory. These procedures include the collection of outstanding accounts receivable and the distribution and disposition of funds remaining on fixed priced awards (i.e., residual funds).

Categorization of External Funding (PDF)

This policy identifies and categorizes funding received from sources outside the university (External Funding) and identifies specific criteria for each category, including authorized signatories.  Any External Funding that is not identified as a Gift or Vendor Contract falls under Sponsored Project Agreements and will be processed through the Office of Sponsored Projects within the Office of the Vice President of Research.

Identification and Treatment of Unallowable Costs (PDF)

It is university policy to charge costs to federal and non-federal sponsored projects in accordance with applicable laws, regulations, sponsor policies and other requirements. For federal sponsors, the Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions (OMB Circular A-21), establishes principles for determining costs applicable to grants, contracts and other agreements with educational institutions, including federal flow-through projects. OMB Circular A-21 also identifies costs that are generally unallowable as charges to federally-sponsored projects (including federal flow-through projects). These costs are termed “unallowable” costs and may not be charged to federally-sponsored projects as either direct costs or as facilities and administrative (F&A) costs. Faculty and staff who are responsible for administering federally funded agreements should be familiar with the categories of costs that are generally unallowable