Policies & Compliance
- Research Handbook
- 1. Roles & Responsibilities
- 2. Standards for Conduct of Research
- 3. Overview of Sponsored Projects Administration
- 4. Funding Sources & Opportunities
- 5. Proposal Development
- 6. Budget Development
- 7. Procedures for the Submission of Proposals
- 8. Award Acceptance
- 9. Award Management
- 10. Research Related Regulations, Policies & Procedures
- 11. Other Conduct of Research Issues
- 12. Acronyms & Definitions
- 13. Glossary
- Procedure Library
- Regulations Library
- Export Controls
Award Management
9.1 Post-Award Administration
The process of managing sponsored projects is a shared responsibility between the PI, the department, OSP, and Grants & Contracts Accounting, and each has unique areas of primary responsibility.
9.1.1 Role of PI in Post-Award Administration
The PI has primary responsibility for accomplishing the technical goals of the project, while also complying with the financial and administrative policies and regulations associated with the award. Although PI’s may have administrative staff to assist them with the management of project funds, the ultimate responsibility for the management of the sponsored project work and funds rests with the PI.
In order to carry out their responsibilities effectively, PI’s should meet with their department administrative and/or accounting staff to review charges in a timely manner. The fundamental responsibilities of the PI during the post-award phase include:
- Executing the project as outlined in the funded proposal, using sound management techniques
- Authorizing only those expenditures that are reasonable and necessary to accomplish the project goals and are consistent with the sponsor’s terms and conditions
- Spending no more than the amount authorized by the sponsor for the budget period
- Carrying out the project’s financial plan as presented in the funded proposal, or make changes to the plan following a prescribed set of policies and procedures
- Reporting project progress to the sponsor as outlined in the terms of the award
- Reviewing expenditures in a timely fashion to assure their appropriateness and correctness
- Complying with all University policies and procedures related to project management and personnel practices
- Complying with all applicable sponsor rules, regulations and/or terms and conditions of the award
9.1.2 Role of PI in Subrecipient Monitoring
As a recipient of sponsored research funding, the University is required to ensure that funding is used for authorized purposes in compliance with applicable grant and contract terms, federal and state regulations and university policies and procedures. The University of Utah, as a pass-through entity (PTE), remains ultimately responsible and accountable to the prime sponsor for funds management and compliance by its subrecipients.
To satisfy the requirements of Uniform Guidance 2 CFR 200.331 Requirements for pass-through entities, it is the responsibility of prime recipients of sponsored funding to advise subrecipients of requirements imposed on them by laws, regulations, and the provisions of contracts or grant agreements as well as any additional requirements imposed. The terms of the subrecipient relationship shall be thoroughly documented in an agreement executed by OSP and by an authorized representative of the subrecipient organization. OSP will establish a risk classification for each new subrecipient. High-risk subawards may specify additional documentation requirements and monitoring to be performed.
Recipients who receive $750,000 or more in federal funding, directly or indirectly, are required to have a single or program-specific audit. It is likely that subrecipients who receive less than $750,000 from the University may be receiving federal funds from other sources or directly from the federal government and will have a single or comparable audit.
Subrecipient entities expending less than $750,000 in Federal funding during their fiscal year and entities which are exempt from federal audit requirements, including foreign entities (300,000 USAID), are required to make financial records available for review or audit by federal agencies or pass-thru entities as requested, under the terms and conditions of their subrecipient agreement and agency guidelines.
The Principal Investigator (PI) is ultimately responsible for ensuring compliance by reviewing all invoices and the technical progress of work completed by the subrecipient before payments are authorized. The PI is also responsible for monitoring requests for extensions and re-budgeting and reviewing the technical and financial reports of the subrecipient. The PI shall work with OSP to request additional subaward agreements or amendments if increases or decreases in time and/or support are necessary for the collaboration.
To establish effective stewardship of sponsored funding that is passed-through to other entities, administrative staff and faculty in all departments who are involved in sponsored projects where subrecipients conduct a portion of research activity should follow these procedures:
