Principal Investigator (PI) Responsibilities
The PI carries out the project work according to the scope, directing project staff and reporting progress to the sponsor as required. The PI also has responsibility for financial and project management. It is up to the PI to establish a start-up plan for the project, and provide clear roles and responsibilities for project and support staff.
The PI is responsible for compliance and ethical conduct in research.
One of the most important aspects of a project is managing it successfully to ensure additional funding and compliance. This may mean adhering to your reporting milestones, steadily spending your budget, monitoring subcontractors, hiring students, or managing the absence of a project team member.
Compensation and Time and Effort Reporting
All personnel paid from sponsored projects, whether they receive a Stipend/Additional Compensation or Release Time (see explanation below) are required to submit a Time and Effort Worksheet to the Grants and Compliance Accountant. In the case of faculty Release Time it is submitted once per semester. For those being paid Additional Compensation the Time and Effort form must be submitted monthly.
Time & Effort Reimbursement
There are two possibilities for reimbursement for grant project work:
- Additional Compensation
- Course Release (Alternate/Additional Work Assignment approval required)
The decision on which reimbursement procedure to use must be made prior to grant submission and award, using the following criteria:
If the grant has funding for personnel that is under 12.5% of the faculty’s base salary for the academic year, then the faculty shall be allowed to receive the funds as a stipend. This is equivalent to or less than one course.
The PI must submit an Additional Compensation Form for stipends paid by the grant. This should be submitted after having submitted the Time and Effort Worksheets. (PI should forward the Additional Compensation Form to the GA for signature, after which the form is forwarded to the Provost’s office for signature, then on to HR for payment).
If the grant has funds for faculty time that is above 12.5% of the faculty’s base salary for the academic year, the faculty member should budget for release time of at least one course per academic year. If a faculty member receives funding from multiple grants, then they may calculate release time for one course per semester. If a faculty member cannot find a suitable replacement to teach the class, he or she may file a waiver of release time in favor of additional compensation.
1 academic year = 8 courses. 12.5% is equivalent to one course per academic year. If faculty seek release time for 25% of their academic yearly teaching responsibilities, that is equivalent to 2 courses.
See Forms and filled out example forms above in Important Forms & Help.
Post Award Reporting
All agencies and most private foundations have reporting requirements for grantees.
The PI is responsible and accountable for meeting the funding agency’s reporting requirements by the required due date. It is the PI’s responsibility to also send the reports to the OSPR, where they can be filed with the grant file.
Funding agencies may require some of the following reports to be submitted:
Ninety (90) days before a grant terminates, the OSPR will notify the PI that their grant will be terminating. The Grant and Compliance Accountant (GA) closely monitors all expenses during this period to avoid unallowable costs. All financial reports will be prepared by the GA.
More Details on Federal Grant Compliance
At the federal level, the Office of Management and Budget (OMB) issues circulars.
On December 26, 2013, the Office of Management and Budget (OMB) issued the “Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards," a/k/a the Uniform Guidance, the Omni-Circular or the Omni-Guidance.
The Uniform Guidance consolidates, streamlines and supersedes eight existing OMB Circulars, including Circulars A-21, A-110 and A-133. The new guidance, which affects all federal grants and contracts, took effect on December 26, 2014.
The Federal Register published the full, final guidance issued by the Office of Management and Budget (OMB) on 12/26/13 - Final Guidance - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards the Uniform Guidance is broken down into its following subparts:
- Preamble - Major Policy Reforms
- Subpart A (200.0 - 200.99) - Acronyms and Definitions
- Subpart B (200.100 - 200.113) - General Provisions
- Subpart C (200.200 - 200.211) - Pre Award Requirements
- Subpart D (200.300 - 200.345) - Post Award Requirements
- Subpart E (200.400 - 200.475) - Cost Principles
- Subpart F (200.500 - 200.521) - Audit Requirements (includes Appendices I-XI) - Subpart F applies to audits of fiscal years beginning on or after December 26, 2014 and includes A-133 Audit.
The new Uniform Guidance replaces/consolidates three previous circulars that were specifically related to grants, contracts and sponsored projects and Institutions of Higher Education, and that were effective until 12/26/2014.
- 2 CFR Parts 215 and 220 - Cost Principles for Educational Institutions (formerly OMB Circular A-21) - Explains Allowable and unallowable expense
- 2 CFR Part 215 – Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education…and other Non-Profit Organizations (formerly OMB Circular A-110) - Explains policies and procedures that must be in place at the federal and institutional level in order to enter into an agreement (contract, grant, other project) - Outlines regulations for cost sharing - Outlines budget and/or other changes that require agency approval
- OMB Circular A-133 – Audits of States, Local Governments, and Non-Profit Organizations- Mandates audit requirements for organizations that spend over $500,000 in federal dollars in any given fiscal year.