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Policy Name: Principal Investigator Responsibilities for Financial Oversight of Grants and Contracts
Policy Number: F/UNTHSC/RES/OGCM-016
Scope: All Researchers
Effective: 8/17/01
I. PURPOSE
To communicate to investigators their stewardship responsibilities
for fiscal management of grants and contracts awarded to the
UNTHSC.
II. POLICY
Principal investigators are required to exercise oversight of
the financial transactions and financial status of each grant
and contract sufficient to ensure that charges are reasonable
and necessary, allowable under the terms and conditions of the
award, properly allocated to and among multiple awards and funding
sources, and limited to the funds awarded for the project.
II. PROCEDURES
As a recipient of grant and contract awards from both Federal
and other sponsors, the UNTHSC is required to comply with numerous
rules and regulations promulgated by those sponsors. Among those
agencies are the Federal Office of Management and Budget, which
sets forth broad policies governing federal grant and contract
financial administration, as well as numerous individual agencies
which award grants and contracts such as the Public Health Services
(PHS) and the National Science Foundation (NSF), with their own
agency-specific regulations for administering grants and contracts.
Common to the regulations of all agencies is the fundamental
requirement that a particular grant or contract may only be charged
for costs related to that project. Fund availability or grant
expiration may not govern which grant or contract is charged.
If an investigator's activities are entirely funded by a single
grant or contract, there are no cost allocation issues. It is
often the case, however, that an investigator's research laboratory
is funded by multiple sources. Accordingly, it is necessary to
ensure that expenditures, whether they be related to personnel,
equipment, travel, supplies or other categories, are properly
allocated to the various grants and contracts.
The UNTHSC recognizes the importance of minimizing the administrative
burden on the faculty, and encourages the use of departmental
administrative and clerical personnel in carrying out routine
administrative activities related to grant and contract management,
such as transaction processing, ordering supplies, and processing
salary distribution requests and vendor invoices. At the same
time, however, the nature of sponsored project support is such
that grant and contract administration cannot be performed without
guidance and oversight by the investigator, particularly when
the project is supported by multiple sources. The principal investigator
best understands the scope of the project, the effort committed
to it by faculty and staff, and the relationship of that project
to other projects with which resources may be shared.
Accordingly, although the principal investigator may delegate
responsibility for day to day financial management of a grant
or contract to others within the unit, the investigator must
exercise appropriate oversight of the overall finances of the
project. This is necessary in order to ensure that charges to
each grant and contract are:
A. As they relate to personnel costs, consistent with the effort
expended by those working on the grant or contract,
B. As they relate to costs other than personnel, are appropriately charged
and allocated to the grant or contract,
C. Limited to the funds awarded for the project, and
D. In compliance with Federal and UNTHSC policies and procedures.
Carrying out these responsibilities requires that the principal
investigator clearly communicate instructions to those performing
the day to day financial administration tasks on how to allocate
charges among various funding sources. Additionally, the investigator
must regularly monitor the financial status of the grants and
contracts to ensure that the charges conform to the above requirements.
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