Responsibility for Proposals, Awards and Regulatory Compliance
Those responsible include the Principal Investigator, Department and Chair, Dean, Sponsored Projects Office (SPO), Post-Award Office (PAO), and the Research Compliance Office (RCO).
Notes
- The Principal Investigator (PI) is ultimately responsible for identifying funding opportunities but SPO assists in this process by periodically sending lists of opportunities to the PIs and providing custom searches by the SPO staff.
- A PI who needs assistance with the preparation of a proposal should normally seek advice from the department or financial administrator for the PI's department. However, the PI may also contact SPO with questions regarding the preparation of a proposal. If a department or financial administrator needs assistance with the preparation of a proposal, he or she should call SPO. In addition, the proposal budget approval is provided either by an SPO certified departmental administrator or directly from an SPO Grant/Contract Coordinator.
- The PI and the department administrator(s) work together to make any necessary fundamental changes to the proposal. SPO may make minor changes to the proposal with verbal approval from the PI.
- When negotiating the terms and conditions of an award, the SPO representative should be in frequent discussion with the PI to ensure that the PI is aware of the changes being made. The SPO representative will ensure that the PI is in agreement with necessary changes.
- SPO and PAO are responsible for coordinating issue resolution with the sponsors. To determine which unit has responsibility, identify the topic and look for who has responsibility for that topic in the roles and responsibilities matrix.
- PAO is responsible for monitoring the collections of overdue payments for sponsored projects. When PAO determines that the institution is unable to collect the payment, PAO coordinates with other units to resolve any issues related to the inability to collect the payment. These units may include, but are not limited to, the AG's office, SPO, and the departments.
- While many units track the end dates of awards to determine when awards need to be closed out, PAO has the ultimate responsibility for identifying close out situations and working through the tasks that need to be completed to close an award.
- The department must ensure that all expenditures/cost transfers have been posted and that the accounts are reconciled, but PAO will assist them in completing these tasks when department initiates need for assistance or upon PAO discovery of need for cost transfer and post audit review.
- SPO and PAO share responsibility for these tasks. Depending on the topic of the regulation, policy, procedure or training, one of the units will have primary responsibility. For example, SPO would be responsible for regulations on proposal submission, PAO would be responsible for regulations on financial status reports as well as being responsible for regulations on effort reporting. To determine which unit has responsibility, identify the topic and look for who has responsibility for that topic in the roles and responsibilities matrix. In some circumstances, responsibility for training or policy development may not follow the matrix. However, the matrix should be used as a starting point for which office to contact with questions.
- The PI has the primary responsibility for the monitoring of subrecipients. The Department assists the PI with this task, and PAO ensures that the University's subrecipient monitoring procedures are compliant.
- While SPO has the ultimate responsibility for mailing the proposal to the sponsor, the PI may request that they or the department mail the proposal. SPO can facilitate the request if the original proposal and final research plan is delivered to SPO with all necessary corrections and copies by 5 pm the day before delivery is to be made.
- PAO manages all the grantee approved changes, ie, pre-award costs, rebudgeting, no-cost extensions, cost-transfers, etc. SPO manages, with input from PAO as necessary, all the requests that require sponsor approval.
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This responsibility includes the following:
- That funds are used only for purposes directly related to the activity supported and that these funds are reasonable, allowable, and allocable as defined in OMB Circular A-21.
- That expenditures are consistent with all special terms, conditions, or limitations applicable under the particular grant or contract.
- That expenditures do not exceed the total funds authorized for a given period under the grant or contract. In many cases, the grant or contract may also specify expenditure limits by budget category or line item.
- Responsibility for the following compliance activities, including but not limited to, technology transfer, financial conflict of interest, biosafety, human subjects, animal care and use, environmental health and safety, radiation safety, personnel issues, equal opportunity, etc.