Investigator's Survival Guide
Proper fiscal stewardship and compliance for sponsored projects requires a cooperative effort between the central administration offices and the academic unit or center where the sponsored project is conducted. However, the Principal Investigator is ultimately responsible for ALL aspects of their sponsored project, including scholarly activity and proper fiscal stewardship. The purpose of this guide is to provide a quick reference for the most critical topics.
The Principal Investigator (PI) should:
- Notify and work with College Grants Officer to develop proposals and budgets with sufficient time for review and approval.
- Budget full F&A or the maximum allowed by the nonprofit or governmental agency.
- Send a final version of the proposal application and route a fully certified Internal Approval Form (eIAF) to the Office of Sponsored Projects Administration (OSPA) at least three business days prior to the sponsor deadline.
- Complete a Financial Disclosure Form each March and update during the year as necessary.
Internal Approval Form
- A complete and fully certified Internal Approval Form is required three business days prior to a proposal submission deadline.
- All faculty, other investigators, and post-doctoral scholars/fellows are required to certify the eIAF.
Conflict of Interest
- For the purpose of this regulation (AR 7:2), Investigator is defined as the project director or principal investigator/program director, co-investigator, collaborator, senior/key personnel, faculty associate, postdoctoral scholars, postdoctoral fellows, and any other person, regardless of title or position, who is responsible for the design, conduct, reporting, or proposing of research or other activity that is sponsored by an extramural agency.
- All Investigators must have completed the on-line Financial Interest Disclosure before a proposal is submitted. Financial Disclosures are completed each March and updated as changes occur (including reimbursed travel for PHS funded projects) during the year. In addition, a new account will not be established until all Investigators have completed the Disclosure and taken the COI Education Course.
The following should be kept for reference:
- Sponsor’s Award: Become familiar with award and sponsor restrictions, due dates of technical reports, and other deliverables.
- Project Account Data Record (PADR): An internal record of project information such as start and end date, sponsor ID, WBS Element (grant account), Budget and Cost Share, summary of terms and conditions, and the last WBS Element revision.
When the WBS Element (grant account) is established, the following should be coordinated with the department business office:
- Record grant personnel effort correctly to the WBS Element and cost share fund, if applicable.
- Charge supplies and travel correctly.
- Coordinate with Central Purchasing for equipment and other vendor service purchases.
- Coordinate with OSPA if subawards need to be issued.
The following should be performed routinely:
- Review the monthly PI Report and verify all expenditures charged to the grant are allocable, reasonable, and allowable.
- Review for over-expenditure, CAS items, and line items with no budget.
- Review, approve, and sign subaward invoices.
- Review and verify with department business office that personnel effort is updated and modified as effort levels change. If sponsor approval is required, contact OSPA.
- Certify effort when required and assist the department business office in meeting the university deadlines.
Project costs not borne by the sponsor; also known as matching or in-kind contributions.
- Policy: UK will only provide cost sharing when required by the sponsor or in exceptional situations when approved by authorized officials.
- Acceptable Expenditures: Costs normally treated as direct costs on sponsored projects may be used to meet a cost sharing commitment and costs normally treated as F&A may not.
- Effort Commitments: The presumption is a PI will need time and effort to complete the scope of work on a sponsored project. If the award does not include funds for PI effort, the presumption is the PI’s department will cost share the effort. Visit the link below for examples where PI effort might not be cost shared. http://www.uky.edu/EVPFA/Controller/files/BPM/E-50-2.pdf
When the Principal Investigator signs the invoice and the business officer submits the invoice for payment, this indicates the following circumstances have been met:
- The amount being paid is commensurate with the work being performed.
- The reports have been received from the subawardee.
- The invoice is dated during the period of performance of the subaward.
- The amount to be paid doesn’t exceed the subaward total.
- The invoice expense detail coincides with the original budget of the subaward (attachment A or B).
- There are remaining funds to pay the invoice.
- Cost sharing is part of the invoice, if required, and a copy forwarded to Sponsored Projects Accounting for reporting purposes.
Responsible Conduct of Research
Other items Principal Investigator should be aware of and perform routinely:
- Seek and maintain approvals for human subjects or animal research.
- Verify project staff have the required research education.
- Verify project staff have sponsor required Responsible Conduct of Research training.
UK Comply Line 877.898.6072
Toll-free telephone number to report unusual, illegal, or dishonest activity.
Animal or Human Research 866.400.9428
Toll-free telephone number to report allegations or concerns.