Key Areas of Oversight
In order to ensure that sponsored projects comply with University and external agency regulations, the University has established a chain of command for oversight of all such projects. This section outlines the distribution of responsibility in general terms.
Responsibilities for ensuring a comprehensive grant and contract program of externally supported research and sponsored activities are allocated among University offices as follows:
- Senior University Administrators
- Pre Award Management
- Post Award Management
- Department Chairs
- Principal Investigators (PI)
- Project Staff
Senior University Administrators (the President, Provost, Vice Provost, and Vice President, Chief Financial Officer and Treasurer) share ultimate responsibility for all sponsored grants and contracts by providing continuous support and oversight of these activities.
The Pre Award Management team is responsible for: assisting investigators in identifying funding sources, approving proposals and administering sponsored projects, and insuring compliance with awarding agencies requirements.
In particular, the Vice President for Research or designee is responsible for signing proposals on behalf of the University after all other necessary signatures have been obtained by the principal investigator and before proposals are submitted to the funding agency. In order for a proposal to be approved, a record is created in the electronic research administration system and routed to the Pre Award Management team with all necessary approvals, no later than five working days before the due date of the proposal application. After a proposal has been approved, the Pre Award Management team may submit the proposal to the external funding source. Due to the high volume of applications submitted by the University, failure to comply with time requirements may result in delays of submission to funding agencies.
The Post Award Management team is responsible for interpreting and implementing sponsoring agency regulations on the allowability and allocability of costs to sponsored agreements. It is also responsible for issuing financial reports and invoices, collecting funds from awarding agencies, and approving expenditures on sponsored agreements.
Each dean is responsible for the research and other sponsored activities that are conducted in his or her specific school or college. The Dean or designee is responsible for approving the ERA proposal before it is submitted to the Pre Award Management team.
The approval/signature of the Dean:
- Attests to the appropriateness of the activity within the School or College
- Acknowledges that the research or sponsored activity conforms with the research and/or the educational mission of the School or College
- Attests that the Dean is aware of and approves the needs of the faculty in terms of space requirements, materials, staffing, matching funds, or hazards associated with the conduct of the activities
- Attests that the Dean is committed to providing specific requirements including matching funds if the proposal is funded, or is assured that funds are available from other sources
The Dean may decide to discuss any unique requirements with other university officials before approving the ERA proposal.
Department Chairs are responsible for knowing about all research or sponsored activities that are being conducted in their departments. Each activity must be approved by the Department Chair prior to submission of a proposal to both the Dean and the Pre Award Management team. The Department Chair's approval/signature on the ERA proposal indicates that he or she:
- Acknowledges that the research or sponsored activity conforms to either the long-or short-range plans of the Department
- Understands the needs of the faculty in terms of space requirements, materials, staffing, or hazards associated with the conduct of the activity
- Commits to providing specific requirements if the proposal is funded
The Department Chair may decide to discuss any special requirements with the Dean before approving/ signing the ERA proposal.
If an award is made, the PI is responsible for the intellectual content of the research or scholarly activity proposal and for carrying out the research or creative activity. Of note, because most agencies want one individual to serve as contact point for day-to-day administration of an award, when co-investigators are involved, one party should be named PI.
The PI has the added responsibility of ensuring that all necessary approvals are received prior to submission of the proposal to an outside funding source. Early in the development of the proposal, faculty should consult with their department chair or dean to inform them of plans for preparing a proposal and to discuss any special requirements that may be necessary. The ERA proposal containing all necessary approvals is electronically submitted to the Pre Award Management within five working days before the proposal is due at the funding agency.
In accordance with University guidelines, responsibility for scientific and budgetary decision-making in project agreements rests with the individual designated as the sponsored project's PI. The PI is responsible for understanding costing principles (e.g. direct vs. indirect costs) and appropriately communicating to University administrators the applicability of expenditures to a particular sponsored project. Administrators may assist in judging accuracy after the fact, but only the PI or the PI's technical staff can truly judge the appropriateness of a charge to the project. The PI should review FOAP data to ensure that only appropriate costs are charged to the project.
These decisions must be recorded in a manner that assures their subsequent accurate implementation and that permits ready review by internal or external auditors. In the event of a dispute concerning the allow ability of an item of cost, the Post Award Management team will be the final authority.
Project staff can be other faculty, post-doctoral research associates, graduate students, or technical support staff. They report to the PI for planning, conducting, and documenting of activities related to the sponsored activity.