David Smelser, Assistant Director of Sponsored Programs, and Carol Malkemus, director of Sponsored Projects Accounting, spoke to an audience at the Office of Research and Engagement last week, giving a presentation they had collaborated on with Lynn Hardy, associate dean for research in the College of Nursing. The topic was “PI, Graduate Student, and Staff Responsibilities” and discussed various research participants’ roles and obligations pertaining to research grants and contracts. The speakers also addressed policies specific to the University of Tennessee, Knoxville and relevant procedures for grant proposal submissions, particularly federal funders, and the execution and management of awarded projects.
One of the topic areas dealt with principal investigator (PI) responsibilities in the process of obtaining funding. Submitted projects must concern topics of relevance to the funding body in question, demonstrate significant innovation, and fit within the broader mission of the university. It is the PI’s responsibility to understand what a given sponsor is looking for at the time of submission, as even recurring solicitations for funding change over time, and determine whether or not that solicitation is an appropriate fit for their project. The arduous process of compiling a competitive proposal demands that this first step of identifying the right targeted funding opportunities prior to submission is essential for proper time management on the part of an investigator.
In preparing a proposal, it is important to note that most research proposals contain more administrative than technical content. The documentation involved must be compliant with the relevant regulations concerning that solicitation, and sponsors have specific requirements and formats for all aspects of the proposals they review.
“The more time you give us, the more we can help,” said Smelser during the talk, citing the statement as a mantra around the Office of Sponsored Programs. OSP formally requires materials no less than one week prior to desired submission dates or required submission deadlines, but many colleges on campus have their own deadlines prior to that. Internal approvals are also required prior to submission, and the administrative portions of proposals are served well by providing the staff in OSP additional time to help perfect the submission. The Cayuse system is used to route proposals for approvals at the departmental and college levels, which must be done before the proposal is sent to OSP or no less than five days prior to submission.
Smelser provided attendees with an “Ultimate Checklist for Obtaining Funding and Managing a Project:”
- Determine it is the right mechanism/funding opportunity
- Understand the funding opportunity requirements
- Ensure the budget includes allowable allocable and reasonable charges
- Make subcontracts are understandable and easily monitored
- Submit requested reports on time
- Openly communicate with the funding agency
After discussing the intricacies of the submission process, the session moved on to discuss the management of awards. Once an award is received, PIs at the University of Tennessee, Knoxville must confirm that they have read and understand the content of the award, including all of the terms and conditions. The PI is responsible for executing all of the technical components of the project, as well as financial and administrative oversight of the project once it has been awarded. The PI assures that the approved budget is followed, specifically that all charges are reasonable, allowable, and allocable. He or she is also responsible for correctly classifying charges as direct cost versus F&A (facilities & administrative costs) and posted to the project in a timely manner, as well as for assuring that all sponsor and university rules and regulations are followed, award modifications are requested in a timely manner, effort certification is completed monthly, ledgers are monitored and updated as needed, and reports are submitted on time. Investigators are encouraged to seek advice from the Program Officer overseeing their award or from OSP if they are uncertain of a task or where a given responsibility lies.
Research compliance concerns are important responsibilities that apply to PIs, staff, and graduate students involved with a grant. For instance, researchers are mandated not to begin work if a protocol is not in place. For IRB relevant projects, IRB approval is required prior to any work being conducted on the project. Any modifications to the project, such as a PIs absence or adding additional investigators or changing the nature of project activities, require the approval of both the funding sponsor and the IRB prior to execution of any part of those modifications. Training relevant to the project is also a compliance concern, and while responsibility ultimately rests with the PI of a project to ensure that all mandatory personnel receive training, it behooves staff as well as graduate students to be accountable and active in the pursuit of their required training. Training requirements that are compliance relevant could include mandatory Responsible Conduct of Research (RCR) training, Conflict of Interest (COI) training, Human Subjects training, Export Control training, etc.
The speakers also discussed common financial compliance issues that impact staff and PIs on research projects. Effort certification, for instance, is required by the university and by most federal sponsors. The PI and all key personnel including researchers, post docs, and graduate students are required to electronically report the time/effort spent on a sponsored projects. Late cost transfers are red flags on a project. In order to avoid issues, ensure that if a cost is allocable to several projects that the money is allocated appropriately and responsibly in that funds are allocated proportionately to the time that items in question were used on the project. Cost transfers must be completed within 90 days of the original posting date. Anything alter than that requires a formal request and paperwork. Award close out must be completed in a timely fashion (UT Knoxville’s fiscal policy dictates that PIs have 60 days after an award ends to post al final costs). PIs and staff must also allow time to certify expenditures in time to meet the sponsors’ financial deadlines.
Malkemus outlined a series of reminders based on recent audit inquiries at various institutions:
- Obtain prior approval for foreign travel.
- Entertainment costs or social costs for staff and students are not allowable on the award itself.
- Computer expenditures are a “handle with care” category. It must be demonstrated that the computer is for that individual project and was a planned purchase for that project (approval documentation or its presence in the budget justification are important).
- Equipment purchases must all be budgeted and equipment must be purchased as it is used for the specific project.
An important take away regarding responsibility in research is that, ultimately, the buck stops with the Principal Investigator. The vast majority of final responsibility rests with that PI, and for good reason. However, understanding their role in compliance, financial and otherwise, is essential for good research staff and participating graduate students on a project. For graduate students in particular, whom this semester’s RCR Lunch & Learn particularly served, the identification of these roles and responsibilities is important as they progress in their careers and potentially become principal investigators themselves.
Samantha Ehrlich attended the session and served as rapporteur for the topic.
- Uniform Guidance (2 CFR 200), the code of federal regulations that provides final guidance on administrative requirements and cost principles
- Roles and Responsibility Matrix, provided by OSP, this matrix depicts the flow of responsibility on a project