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Administrative Responsibilities

The Principal Investigator (PI) is responsible for the technical direction of the sponsored project and for the authorization of all expenditures charged to the project. Additionally, the PI is responsible for expending funds in compliance with agency, state, and University regulations and for ensuring that project-specific costs are reasonable, allocable, and allowable on the project. To aid the PI in meeting these responsibilities, the Research Administrator (RA) in the Office of Contracts and Grants (OCG) and the department must take the necessary steps to ensure that applicable restrictions are clearly defined, communicated, and understood when managing an award.

Training

With the OCG RA's support, the department and College Business Administrators serve in a stewardship capacity over sponsored research projects by monitoring expenditures to ensure compliance with regulations. The Division of Research provides training through the Research Administration Certification Program (RACP) to the department and College Business Administrators, certifying those who have completed the required core courses to enable them to review expenditure requests for compliance with agency and University restrictions. Only administrators who have completed RACP required core courses are authorized to provide a certifying signature on expenditure documents. If a department does not have a certified administrator, the College Administrator must certify that department's expenditure documents.

Documentation and Justification for Expenditures

Documentation is required to justify any expense charged to a sponsored award and should be adequate to support and justify that:

  • The expense provides a direct benefit to the award
  • The expense complies with any award restrictions and approval requirements outlined in the terms and conditions of the award
  • If needed, the expense qualifies as "unlike purpose and circumstance" on a federal award

Backup documentation and justification should be included in and uploaded with financial transactions to the PeopleSoft system and/or maintained in the department files for a minimum of five years AFTER award closeout or as outlined in the Records Retention guide.

Expenditures Flagged for Review

Some expenditure documents must be routed through OCG for approval or are flagged in the PeopleSoft system to remind users to take the necessary compliance measures. A listing of these documents can be found in the table below:

Purchase Requisition for Equipment during the last six months of the project

Flagged

Warning message: Equipment purchased late in the award may require Sponsor Prior Approval.

Voucher payment for material and supplies in the last three months of the award

Flagged

Warning message: Materials/supplies purchased late in the award may require Sponsor Prior Approval.

Contractors Service Agreement

Routed via OCG

For review and approval

Payroll and non-payroll expenditure correction/cost transfers involving grant cost center. 

Routed via OCG

For review and approval

PO Vouchers for subrecipient invoice payment

Routed via OCG

For review and approval

Expenses with unallowable account codes for sponsored projects

Flagged

Warning message: Verify the cost is approved in the budget or seek prior approval as needed

Expenses with an expired invoice date (outside of the grant period of performance)

Flagged

Warning message: The expense appears to be beyond the period of performance and is unallowable

Cost Allocation

PIs are responsible for assigning costs to the appropriate sponsored project cost center when the expenses are incurred. If a cost benefits two or more projects, the cost must be shared between the projects based on the proportional benefit to each. The Uniform Guidance §200.405(d) indicates that a cost is allocable to a project if the relative benefit of the goods or services can be assigned to that award in accordance with the relative benefits received. 

This standard is met if the cost:

  1. Is incurred specifically for the award;
  2. Benefits both the award and other work of the university and can be distributed in proportions that may be approximated using reasonable cost allocation methods; and
  3. It is necessary to the university's overall operation and is assignable in part to the award in accordance with the principles of this guidance.

Cost may not be allocated based on:

  1. The amount of available funds on an award;
  2. Budgetary convenience (to accommodate an award that is either over or under budget, budget is ending soon, etc.);
  3. Avoidance of the restriction imposed by law or terms of the award; or
  4. Offset (cost charged to budget A one-time and budget B the next time)

Expenditure Reconciliation

Project expenses are posted to the PeopleSoft accounting system general ledger. Each department will run its project accounting reports and is responsible for the timely reconciliation of expenses according to MAPP 05.04.02. The PI(s) may request a copy of the report for his/her award from his/her college/department business manager. Questions regarding any problem on the monthly accounting reports should be directed to the originating department (e.g., Payroll, Accounts Payable, General Accounting).

Delegation of Authority

A PI may delegate someone to sign on his/her behalf. The Uniform Guidance requires that the PI or his/her designee sign all expenditure documents. OCG can provide the PI and DBA a "Delegation of Authority" form. The PI may use the Delegation of Authority form to officially give an employee(s) authorization to sign on his/her behalf. Alternatively, the department may recreate another form of this document or the PI may use a delegation memo.