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Principal Investigator/Program Director Responsabilities
INTRODUCTION
Whether a faculty member or staff member is submitting a grant proposal, it is assumed that the Principal Investigator (PI) will personally participate in and contribute to the project in a significant way. Most agencies frown upon the use of a prestigious name as the designated PI solely for the purpose of lending credibility to a project. This does not, however, preclude the use of one or more Co-Principal Investigators on a project that is multifaceted or requiring expertise in more than one discipline.
It is also understood that the PI will conduct and administer the project in a responsible manner, adhering to all policies and procedures mandated by the institution, agency and any other governing entities. These policies and procedures might include such important areas as the use of human or animal subjects, biohazards, lasers, or recombinant DNA.
The PI has overall responsibility for the conduct and administration of the research project. This includes everything from the preparation and appropriate on-campus review of the proposal, to post-award financial and technical reporting. Failure to comply with these requirements can affect the PI’s and/or the institution’s ability to secure continuing and future funding.
The following sections of this handbook address several specific areas of responsibility. Every individual with an interest in conducting research at Fort Lewis College should become familiar with these responsibilities and be prepared to fulfill these obligations.
Peformance Of Specific Aims And Objectives
It is the sole responsibility of the PI to assure that all specific aims and objectives of any project are performed and completed as described in the proposal document. Therefore, a project plan must be realistic and attainable, and include a budget that is sufficient without being excessive to complete the work. Regular laboratory or project personnel meetings help to insure that all individuals who are associated with the project are accomplishing these goals according to the time frame presented to the agency.
Some agencies allow some latitude in this area; however, most require prior approval to make changes to the scope of specific aims and objectives, as well as changes in the methods used to accomplish them. The PI should consult with the designated funding agency program director to determine whether the proposed changes will require prior approval, and what will be required to accomplish this approval.
TECHNICAL REPORTING REQUIREMENTS
The work conducted as part of a research grant is not considered to be complete until the PI has submitted, and the agency has accepted, all reports required by the agency. These reports are usually due within 90 days of the end of a budget period or project period. The most common reports include financial, progress, technical, cost sharing, and property reports. Financial reporting has been discussed in the section of this handbook entitled “Fiscal Responsibility and Reporting Requirements.” Because there is some variability between agencies, the PI should become familiar with the specific requirements of each sponsor.
The importance of submitting reports in a timely manner cannot be overstated. Some agencies will withhold continued funding to not only the PI of the delinquent project, but also to the entire Campus until the reports in question are received and approved.
A copy of any report generated and submitted by the PI, along with any supporting documents, must be provided to the Director of Grants Management for inclusion in the official grant file. Receipt of a copy will be deemed fulfillment by the PI of his/her reporting responsibility to the agency.
Progress Reports
These reports are usually required of the PI at the end of each budget period, or some other specifically designated period of the project, and they sometimes include fiscal reporting in addition to technical reporting.
Technical Reports
These reports are usually required of the PI at the end of a project period, or some other specifically designated period of the project. They may include a discussion of the final technical progress made on the project, problems and solutions that were encountered, and a list of publications that have resulted from the research, among others as required.
Patents, Inventions, and Other Deliverables
These reports are generally associated with contracts rather than grants. If any are required as a condition of a research project, the PI must work in cooperation with the Director of Grants Management to coordinate the timely submission of these reports.
FISCAL RESPONSIBILITY AND REPORTING REQUIREMENTS
Every expense charged to a research project must meet certain criteria. Is the expense allowable under the terms of the award and/or OMB Circular A-21; is it of direct benefit, and therefore allocable, to the specific project; and is the cost reasonable? Other considerations include whether justification for the expense is documented, and whether there are sufficient funds remaining to cover the expense.
Certification of Expenditures
Monthly general ledgers, available upon request from the Accounting Office, should be carefully reviewed by the PI to certify their accuracy. Any questionable charges must be investigated and may necessitate processing of a journal voucher. If a journal voucher is required, it should be processed as soon as possible to minimize audit exposure. All journal voucher activity between research projects is especially vulnerable to audit and, therefore, must be fully explained and certified by the PI as being directly beneficial and appropriate to the project receiving the expense.
Most agencies require periodic, written certification of expenditures, usually quarterly. These requirements are specifically addressed in the award notice and/or the individual agency’s policies and regulations.
Retention of Fiscal Records
All records pertaining to project expenses, including payroll and purchasing documents, should be retained for three years after the close of the project by the agency, unless otherwise stipulated by the agency. If documents are not available for the required period of time and a challenge arises, the expense in question will most likely be denied.
Pre-Award Spending
Occasionally it is appropriate to incur pre-award expenses against an approved award if the funding has been delayed. This action is not without risk, however, if for some reason the funding is withdrawn by the agency. Usually a “guarantee account” is required that will absorb any expense incurred if the funding should not be forthcoming. The PI should consult with the funding agency, their Department, and Grants Management in determining if this arrangement can be successfully completed. Under no circumstance is it acceptable for expenses to be incurred prior to the start date of the project with the intent of transferring those expenses to the new funding source at a later time, thus creating audit exposure.
Spending Patterns
Some funding agencies are monitoring the rate of expenditure for projects much more closely than in the past, and have been known to withdraw funding because of deviations from the original project proposal. The spending pattern should keep pace with the project, and continued funding can be affected by spending more quickly or more slowly than projected. It is expected that the awarded funds will be spent as proposed in the original approved budget, with a reasonable degree of flexibility as allowed by the specific agency. Each funding agency expects to be informed of any deviations in projected spending, not just those requiring prior approval for re-budgeting.
Allowable Late-in-Period Expenses
Under unusual circumstances, it is possible to make major and minor purchases of equipment and supplies late in the project period, defined as within 60 days of the project end date. If it is necessary to do so, make certain that the funding agency program officer is consulted and that written approval is obtained prior to these purchases, and that the allowability and allocability of such purchases is well documented. In general, expenses incurred after the end of the project period are not allowed unless they are specifically provided for in the award notice. If there is work to be completed on the project after the original end date, a no-cost extension of the project should be requested. During a no-cost extension, the work continues for a designated period of time at no additional cost to the granting agency. The PI will be required to document the need for an extended period, and it is not appropriate to make such a request for the sole purpose of “spending out” any remaining budget amounts. These types of expenses are highly scrutinized and will not be allowed if they cannot be proven to have directly benefited the continuation of work on the project, and if they are not approved by the agency in advance.
Fiscal Reports
The PI bares the ultimate responsibility for monitoring the preparation, review, and timely submission of all required reports, including those pertaining to project expenditures. The PI is also responsible for assuring that all documents in support of project expenditures are adequate and available for review if the need should arise. Many reports are generated and submitted automatically, but some require the direct input of the PI. Contact the Office of Grants Management for assistance.
RETENTION OF AND ACCESS TO RESEARCH DATA
Another responsibility of the PI is the maintenance and retention of research data. These must be retained in sufficient detail and for an adequate period of time to allow the PI to respond to any questions having to do with accuracy and authenticity. The PI will determine what is to be retained based upon requirements set forth in OMB Circular A-110 pertaining to stewardship of data.
Data and records are an essential part of a research project and should be maintained in an accurate and appropriate manner. Usually tangible property, including data and records, remain the property of the institution, not the PI. The PI is, however, responsible for maintenance and retention of both. This requirement applies to all individuals involved in the conduct or reporting of research irrespective of the funding source, and any notebooks and other records necessary for reconstructing how research conclusions were reached. This may seem to some to be unreasonable or unnecessary, however, these procedures are in place to help protect the PI from false or frivolous accusations relating to research conduct, including tampering with research data and records. The section entitled “A System for Keeping Research Data and Records” provides some suggestions as to how data and records may be handled in order to assure that records are complete and relatively tamper-proof.
The system used by the PI to collect, maintain, and retain data and records should be orderly and understandable, and utilized by all personnel assigned to the project. In addition, procedures should be developed to insure protection of these records in the event of fire or some other emergency.
The College’s responsibilities in this area have to do with complying with project agreements, securing intellectual property rights where applicable, protecting the rights of staff and students regarding access to data, and facilitating any investigations of charges of misconduct or conflict of interest.
Data and records should be retained for at least 3 years after the close of the project in their original form wherever possible. A longer retention period may be appropriate to protect intellectual property, in cases where charges of misconduct or conflict of interest have been made, and/or if students are involved, until a degree is awarded or the student has abandoned the work.
When possible, the data and records should be retained in the department where the work was produced on-campus. If this is not practical, they may be stored in an off-campus location under the auspices of the College. It is the right of the College to take custody of data and records if necessary to assure access for any number of reasons.
Typically, if a PI should leave the College community, originals of data and records remain in the possession of the College, and only copies may be taken by the PI. If the work will be continued at another institution of higher learning, the originals may be removed provided the new institution is willing to assume custodial responsibility, and agrees to grant access to Fort Lewis College if needed.
A System for Keeping Research Data and Records
One of the most useful tools available to any Principal Investigator, and one that is essential to sustaining a well-organized project, is the research notebook. The purpose of research notebooks should be to provide a permanent record of the project’s work in order to prove what work was accomplished, and when, by way of consecutively dated documents. The nature of the entries should be sufficient to prove certain facts pertaining to the procedures utilized and observations made in arriving at the reported results. These criteria become important in a number of situations including patentable processes and designs, and questions relating to accuracy and authenticity of the work represented. Following a few simple steps will help to insure that research data and records are maintained in a secure and understandable manner.
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Each item should have an identifying description or label to associate it with a specific project. |
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Record all entries in ink or some other permanent medium in notebooks with permanent pages, or bind all materials together permanently if data and records are typically recorded on full size sheets of paper. |
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Identify each item with the appropriate project and number each item consecutively, preferably with a numbering stamp. |
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Date each item with the date of creation. |
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Keep a permanent catalog of numbered items included in each notebook, including the item number, a brief description, and the date of creation. |
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Include all data and records generated including research and progress notes, formulas, diagrams, analytical printouts, and photographs. |
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Each entry should stand-alone and be understandable by another qualified individual through notations. |
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Permanently mount all loose pieces of paper to the notebook pages consecutively and, in the case of photographs, identify the photographer and date of creation. |
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All individuals participating in the project should utilize the same notebook. |
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If more than one individual is making entries into the same notebook, each should initial their entries for identification purposes. |
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Progressive notes relating to the results of experiments, interviews and observations, should be included. |
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Never erase! This could be misconstrued as fraudulent reporting of data. Instead, if a correction is necessary, line through the original entry, initial it, and enter the new information. |
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Never mutilate a notebook by cutting or tearing out pages. |
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Have a qualified individual who is not connected with the project review entries on a regular basis and witness them by signature and date. |
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Although this process may seem overwhelming, it should quickly become second nature, and is an adequate means of insuring that original data is kept in a complete and secure manner.
AUDIT REALITIES AND THE CURRENT CLIMATE
In addition to the actual conduct of the research project, the Principal Investigator is responsible for the overall financial management of research funding. Various requirements relating to the appropriate use of funds are imposed by both internal and external entities, and it is up to the PI and the institution to work together in complying with these requirements. The focus of both must be to accomplish the goals of the project while avoiding abuse of the financial support and fraud, or the appearance thereof.
There are certain principles and policies that have been established by the Office of Management and Budget of the Federal government that govern the spending of Federal funds by institutions of higher education. Colleges and universities that receive research funding from federal agencies are required to adhere to the principles set forth in the Office of Management and Budget’s Circulars A-21 and A-110, among others. These principles are so widely accepted that many non-Federal granting agencies use these principles as the basis for their own spending, administrative and reporting requirements. A-21 and A-110 are perhaps the most important and most applicable to the day-to-day conduct of research projects. All PIs should become familiar with these documents and principles as they relate to their own research efforts.
OMB Circular A-21 relates directly to allowable and allocable direct costs charged to specific projects. This means that any cost charged to a project must be allowable under the terms of the award, and allocable, or of direct benefit, to the project that paid the expense. This may not seem like a problem to the researcher who manages very distinct projects with no overlap of project content or resource requirements. However, it is an issue for others who are involved in a broad research effort that is being funded by more than one agency. In addition to assessing whether an expense is allowable and allocable, there is the question of whether the cost is reasonable. Is it consistent with what a “reasonable” person might expect to pay for the service or commodity? All expenses must meet these tests if they are to be charged to a research project.
One more area of concern to an auditor is that of consistency. This relates to how the institution handles various costs across campus. If an expense is treated as a direct cost in one department or school, it must be treated the same elsewhere. As long as policy is being applied consistently, this issue should not arise as an audit concern.
The best way to avoid audit problems is to know and understand the terms and conditions of your award, and to allocate expenses correctly when they are originated. Allocate all expenses correctly to avoid the need for journal vouchers, commonly referred to as cost transfers by some agencies. Although this situation may be justifiable and defendable in an audit, these types of transactions can be the primary cause and sole focus of campus-wide audits. In such an audit, the expense will be scrutinized to determine the reason for the journal voucher. These might include whether it was processed for the sole purpose of using unexpended funds close to the end of a funding period, or for the purpose of clearing an overdraft situation. In either case, it is likely that the expense will be disallowed.
Researchers are encouraged to manage the expenditures against their projects to avoid audit situations. If expenses are allocated based upon their benefit to a specific project, and whether they are allowable, audits of expense transactions will support the Principal Investigator’s decisions.
OMB CIRCULAR A-21
This circular sets forth the cost principles, or “rules” that govern spending of Federal funds by institutions of higher education. Its purpose is to define four over-riding principles: allowability, allocability, reasonableness and consistency.
Allowability
The issue of allowability addresses whether or not a given expense is allowed by the agency. Some expenses such as entertainment and alcohol are never allowable on federally funded projects. Other items might be allowed on one project, but not on another, depending upon the specific terms of the award. Examples might include foreign travel or administrative costs. This is an area of particular concern to auditors, and one they will scrutinize very closely.
Allocability
Allocability relates to the issue of whether or not an expense has directly benefited the project to which it is being charged, and is not the same as allowability. The fact that an expense is allowable, does not make it allocable. It is always a good idea to support with documentation any expenses that may be questionable as to their allocability to a specific project. An example would be the purchase of a piece of equipment that will be shared by more than one project. A portion directly proportionate to its use on a given project would be charged to that project.
Reasonableness
This principle simply states that the cost of any item or service must be within a limit that any reasonable person might expect to pay. Often State laws and statutes also limit the amount that may be paid for a given item, further supporting this principle. Again, an expense may be allowable and allocable, but not reasonable and therefore denied during an audit.
Consistency
Institutions are expected to consistently apply criteria for how they classify certain costs throughout the institution. In other words, if a cost is classified as a direct or indirect cost in one department or school, it must be classified the same in any other department or school within the same institution.
OMB CIRCULAR A-110
This document establishes acceptable standards for pre- and post-award administration of federally funded grants and agreements awarded to institutions of higher education.
Pre-award administration relates to issues that exist even before an award is funded. A few of those issues include, but are not limited to:
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Determining what the award instrument will be – a grant, contract, or cooperative agreement |
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If a PI has exhibited prior poor performance or non-compliance with award terms, special conditions can be placed upon the award to protect the Federal government’s interests |
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Annual certifications and representations are allowed as long as there exists an on-going relationship between the project and the Federal government |
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Post-award administration establishes the standards for financial management and other issues that arise during the project period and after closing. Some of the issues addressed in this section of the circular are:
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Rules for satisfying cost sharing and matching by the institution |
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Accounting requirements for income-generating projects |
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Revisions to existing budgets and their approval |
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Audit guidelines |
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Determination of allowability of costs |
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Withholding of payments for non-compliance by the PI of project objectives, terms of the award, and reporting requirements. |
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Standards for purchasing practices |
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Reporting, record keeping, and access to records |
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Termination of projects due to non-compliance. |
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Closeout procedures |
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