Responsibilities for Procurements on Sponsored Projects

This section assigns accountability for both federal and non-federal sponsored projects procurements to:

The Sponsored Project Administrator (SPA) from the Office of the Vice President for Research (OVPR). The SPA is responsible for the review and approval of proposed procurements that includes determining that the proposed procurement is reasonable, allowable, allocable, and appropriate for the purpose of the sponsored projects.
The Director, Sponsored Projects. The Director serves as a general resource to Procurement in interpreting federal regulations related to sponsored projects and to PIs in complying with GW procurement processes. The Director is responsible for educating PIs with respect to the regulations and requirements for procurements on sponsored projects.
Procurement. As indicated above, Procurement is responsible for final approval of procurements and the initiation of purchases. Procurement is not responsible for identification and/or final approval of sub-awards, but simply processes the transactions when provided the required documentation.
The Principal Investigator (PI). The PI is responsible for:

Identifying procurement transactions and forwarding requisitions through the department/school administrative staff to the SPA.
Coordinating with the department/school administrative staff, SPA and Procurement on sponsored projects ensure procurement requirementsare followed.
Ensuring that no sponsored research funds are expended or committed prior to appropriate reviews.
Providing clear and detailed justifications when requesting a sole source (non-competed) contract award.
Providing any additional documentation that may be required by the sponsor or internal policies and procedures.

Please see Appendix C for Definitions of terms related to sponsored research grants.

Sub-Awards

Fully executed sub-awards for all dollar levels should be forwarded to Procurement in the form of a Notice of Grant Award (NOGA) requisition to reserve the funding as a NOGA and not as a PO. In the case of uncertainty as to whether the resulting contractual document is a contract or sub–award, please consult Procurement for guidance. Sub-awards that conduct collaborative research and development under grants and cooperative agreements are not subject to the procurement documentation criteria and procedures.