Office of Sponsored Programs - 200.04 - Principal Investigator Responsibilities

Title

Office of Sponsored Programs - 200.04 - Principal Investigator Responsibilities

Purpose

This operating standard establishes the overall responsibility of Principal Investigators (PIs) in undertaking sponsored research projects and related components of those projects.

Policy Statement

PIs are responsible for the overall proposal preparation, administration, technical, and financial management of sponsored projects. These obligations include, but are not limited to, the management of the project within funding limitations, adherence to reporting requirements, and ensuring that the sponsor is notified regarding significant conditions that may affect the technical or scientific aspects of the sponsored project.

PIs do not have the authority to enter into legal agreements involving grants, contracts, and cooperative agreements on behalf of the University. These must be signed by a University representative with institutional signature authority.

While the PI may delegate day-to-day operations of project finances and administration to staff members, the PI accepts ultimate accountability for compliance with Federal, University, and sponsor policies and requirements. This also includes knowledge of sponsor regulations regarding any stipulations on rebudgeting and changes in key personnel, scope of work, and subrecipient requests.

PIs are required to review the University's policies on ethics in research and stewardship of sponsored funds as well as compliance regulations applicable to their sponsored projects.

I. Preparation of Proposals

PIs are responsible for creating proposals based on the sponsor’s guidelines as well as the University's requirements. This includes using the sponsor’s formatting, including all required components, and providing the completed proposal for central office review in a timely manner.

This also means submitting all proposals through RAMSeS and including all compliance requirements as well as any other University required certifications. The PI may delegate certain aspects of the proposal to department administrators, such as the budget creation, but they are ultimately responsible for all aspects of the proposal.

All proposed budgets must conform to Federal, University, and sponsor policies. In proposing budgets for sponsored projects, the PI assures the University and the potential sponsor that project finances are represented as accurately as possible. PIs are required to inform potential sponsors that no budget is considered final until authorized by the Office of Sponsored Programs (OSP) on behalf of the University.

II. Prohibitions on Award Acceptance

PIs are prohibited from accepting or indicating acceptance of a sponsored award verbally or in writing. Only official designees of the University have the authority to accept an offer of award.

III. Management of Project Expenditures

Upon finalization of award acceptance and creation of a Project ID for awarded funds, the PI is responsible for authorizing direct charges in accordance with 2 CFR §200.413 and applicable funding agency guidelines. All project expenditures should be reviewed on a monthly basis. The PI’s authorization assures that all expenses charged to the project are allowable, allocable to the project, and reasonable.

IV. Reporting Requirements, Additional Requests Related to Sponsor Notifications & Prior Approvals

The PI is responsible for providing all technical and scientific reports on the date indicated in the agreement, using the agreed upon format. Please note that certain sponsors require the technical or scientific report to be submitted with the financial report. In this case, please send the completed technical or scientific report to OSP for submission.

In all cases, required notifications or requests for prior approval should be made in writing to both the administrative and technical officials in the sponsoring agency. All notifications must be coordinated and sent by OSP.

V. Changes in PI Status

Sponsors often have requirements regarding notification or prior approval of changes in the availability of the PI. For Federal contracts and non-Federal projects, the terms and conditions of the particular agreement will govern.

For Federal grants, 2 CFR §200.308 requires prior written approval from the awarding agency for either of the following circumstances involving key personnel:

• A reduction in time devoted to the project of 25% or more from the proposed and awarded level
• Disengagement from the project for more than three months

The grant award and grant policies of the specific sponsoring agency should be reviewed for any additional requirements.

The PI, department chair, or department administrator should contact SponsoredPrograms@unc.edu to coordinate securing required approvals for all PI Status Change requests. In the original award, if the University had committed to fund some of the PI's effort as cost-sharing and the PI reduces the overall committed level on the project, OSP will also negotiate reductions in levels of the cost-shared component of effort, as appropriate.

When a PI’s appointment will terminate before the agreement end date or is scheduled for a leave of absence, it is mandatory that the sponsoring agency concurs in writing before the PI departs. Satisfactory arrangements are to be made for a substitute PI and the continuation of the specified research or training. Any leaves of absence are coordinated through the appropriate OSP Sponsored Projects Specialist (SPS).

VI. Project Closeout

PIs are responsible for overseeing the proper closeout of sponsored projects, including the timely submission of all required reports in conjunction with OSP. They are also required to promptly remove any charges deemed unallowable by OSP.

VII. Audit Information

Any auditing activity is required to be conducted in the presence of an OSP representative. Communications and correspondence with auditors are conducted by OSP and OSP must review any materials requested by auditors before submission.

PIs are responsible for ensuring that budgets and expenditure accounts are managed in accordance with the regulations provided in 2 CFR § 200 Subpart F - Audit Requirements. In addition to other auditing requests, this includes providing OSP information and records requested by the auditing agency regarding:

• Compliance and internal controls
• Review of financial transactions, payroll, and effort reporting
• Monitoring research funds and how costs have been allocated to sponsored projects

Exclusions

The definition of a leave of absence varies from sponsor to sponsor. Other sponsors may be more or less restrictive and may reserve the right to approve any change in key project personnel. Adherence to sponsor requirements for advance notification and clearance minimizes the chance of problems with, and possible cost disallowances, by a sponsor.

Related Requirements

• Research Administration Glossary at Carolina
• 2 CFR §200 Subpart E - Cost Principles
• 2 CFR §200.308 - Revision of budget and program plans
• 2 CFR §200 Subpart F - Audit Requirements
• 2 CFR §200.413 - Direct Costs

Unit Policies, Standards, & Procedures

• OSP Operating Standard 200.01 - OSP Responsibilities
• OSP Operating Standard 200.02 - Signature Authority
• OSP Operating Standard 200.05 - Departmental Administrator Responsibilities

Contact Information

For questions regarding this operating standard and its related procedure, please contact SponsoredPrograms@unc.edu.

For questions regarding Pre-Award management or Post-Award administration, please contact the assigned SPS.

For invoicing, reporting and other financial matters, please contact the assigned Sponsored Projects Accountant.
OSP Staff assignments may be found in RAMSeS or on the OSP website.

History

The operating standards in the Office of Sponsored Programs Operating Standards & Procedures Manual supersede any OSP operating standards, procedures and appendices previously included in the University Business Manual, a publication of UNC-Chapel Hill’s Division of Finance.