Policies & Compliance

Award Management

9.1 Post-Award Administration

The management of sponsored projects is a shared responsibility among the Principal Investigator (PI), the department, the Office of Sponsored Projects (OSP), and Grants & Contracts Accounting. Each party has distinct roles that, together, ensure the project is conducted in compliance with sponsor requirements, University policy, and applicable laws and regulations.

9.1.1 Role of PI in Post-Award Administration

The Principal Investigator (PI) bears primary responsibility for the successful execution of the sponsored project, including achievement of the project's scientific or programmatic objectives and stewardship of project funds in accordance with award terms.

While departmental administrators may assist with financial tracking and administrative functions, ultimate accountability for both technical performance and financial management rests with the PI.

To fulfill these responsibilities effectively, PIs are encouraged to work closely with departmental administrative and accounting staff and to review project expenditures and reports on a regular basis.

The PI's core post-award responsibilities include:

Executing the project in accordance with the approved scope of work, using sound management practices;
Authorizing only expenditures that are reasonable, allocable, necessary, and consistent with sponsor terms and conditions;
Ensuring that expenditures do not exceed the approved budget for the authorized period of performance;
Managing project funds consistent with the approved financial plan, or requesting changes in accordance with established policies and procedures;
Submitting required technical or progress reports to sponsors in a timely manner;
Reviewing project expenditures regularly to ensure accuracy, allowability, and appropriateness;
Complying with all applicable University policies, including those related to personnel, effort reporting, and financial management; and
Adhering to all sponsor regulations, award conditions, and reporting requirements.

9.1.2 Role of PI in Subrecipient Monitoring

When the University issues a subaward to another organization, the University acts as a pass-through entity (PTE) and remains accountable to the prime sponsor for the proper use of funds by its subrecipients.

In accordance with Uniform Guidance (2 CFR 200.331), the University is required to:

Inform subrecipients of all applicable requirements imposed by laws, regulations, the prime award, and University policy;
Document the subrecipient relationship through a formal executed subaward agreement; and
Conduct risk-based monitoring of subrecipients.

OSP establishes an initial risk classification for each subrecipient. Subawards deemed higher risk may include additional reporting documentation or monitoring requirements.

Subrecipients that expend $750,000 or more in federal funds during their fiscal year are required to undergo a Single Audit or program-specific audit. Subrecipients below this threshold - and entities exempt from Single Audit requirements, including many foreign entities - must still make financial and programmatic records available for review or audit upon request, as required by subaward terms.

PI Responsibilities for Subrecipient Oversight

The Principal Investigator (PI) is responsible for the programmatic and financial oversight of subrecipient activities, including:

Reviewing and approving subrecipient invoices to confirm costs are allowable, reasonable, and aligned with work performed;
Monitoring the technical progress of subrecipients to ensure timely and satisfactory completion of project objectives;
Reviewing subrecipient technical and financial reports;
Monitoring and approving subrecipient requests for rebudgeting, extensions, or scope changes, as appropriate; and
Working with OSP to initiate subaward amendments when changes in funding, time, or scope are required.

To ensure effective stewardship of pass-through funds, PIs and departmental staff involved in projects with subrecipients should follow established subaward management processes, including:

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