Sponsored Programs Administration

Principal Investigator

• Determines financial charges that are allocable to the sponsored project.
• Attests to the allowability and reasonableness of all expenditures when initiated.
• Initiates hiring/assignment of personnel working on the sponsored project.
• Responsible for the completion, accuracy and timeliness of all technical reports.
• Initiates and approves subcontract agreements and payments.
• Participates with the Departmental/Center Financial Administrative Officer in the process of documenting cost sharing/matching costs.
• Initiates requests for rebudgeting of costs on the project.
• Initiates and proposes resolution of any cost overrun occurring on the project.
• Reviews and approves interim financial reports prepared by Research Finance.
• Identifies and allocates any program income (such as revenue from sales and services of goods developed in conjunction with a sponsored project).
• Ensures compliance with all applicable financial regulations by project personnel and reports instances of non-compliance to the appropriate Compliance Officer.

Departmental/Center Financial Administrative Officer

• Reviews financial transactions on sponsored programs to ensure that the transaction occurs within the project period.
  • The cost of the transaction is reasonable.
  • The transaction represents a reasonable allocation of the cost.
  • Funds are available in the sponsored program to support the transaction.
  • The transaction is treated consistently with regard to direct/indirect cost purposes if the transaction occurs on a federal project.
• Prepares and/or approves financial, human resources and other documents for sponsored projects in the following areas
  • Cost sharing/matching.
  • Provides or maintains databases or files to support sponsored project activities.
  • Prepares documents and provides information for appointment of individuals to sponsored project(s).
• Processes financial transactions and reviews and analyzes Financial Reports for sponsored project(s)
  • Assigns correct account codes, provides information and processes purchase documents.
  • Prepares and initiates processing of cost sharing/matching documents.
  • Prepares documents and provides information for rebudgeting.
  • Prepares requests for cost transfers and forwards to Research Finance for review, preparation and processing.
• Provides information and prepares documents to resolve project cost overruns
  • Processes documents to record program income.
  • Prepares documents and provides information for compliance with the effort reporting policy.
  • Provides information for interim and final financial reports.
  • Provides information for closing documents.
• Assesses risk associated with financial transactions on sponsored projects and as needed, seeks the advice and approval of higher authority, such as the Dean's Office, Division of Sponsored Research or OCGA/Department of Finance, Academic and Research Enterprise.
• Reports instances of financial noncompliance with applicable regulations to the appropriate Compliance Officer.

Department Chair or Center Director

• Maintains local oversight for the allowability and reasonableness of all project expenditures.
• Oversees all rebudgeting activities on sponsored projects.
• Provides oversight on all aspects of program income.
• Provides oversight on the implementation of University and federal financial policies and regulations at the unit level.
• Ensures financial compliance with applicable regulations for sponsored projects within department/center and reports instances of noncompliance to the appropriate Compliance Officer.

Dean's Office (or Designee)

• Approves source of cost sharing/matching funds.
• Provides local oversight for federal costing regulations issues such as correct identification of costs as direct or indirect costs.
• Identifies funds to cover project cost overruns.
• Provides guidance in sponsored project matters that cannot be resolved at the department level.
• Promotes University Compliance Program regarding research grants management.
• Investigates instances of financial noncompliance and reports discovered instances of noncompliance to the University Compliance Officer.

Compliance Officer

• Informs the University community about the Standards of Conduct and ethical obligations under the Compliance Program.
• Monitors compliance activities, including policies and procedures, and training and education programs.
• Serves as a resource to the University on matters of compliance.
• Maintains a help line for compliance matters.

Executive Administration

• Promotes University Compliance Program.
• Oversees policy formulation in the following areas.
• Matters relating to direct and indirect charging on sponsored projects.
• Effort reporting on sponsored projects.
• Cost sharing.
• Rebudgeting on sponsored projects.
• Recording and disposing of program income.
• Cost transfers.
• Record retention.
• Works with others in instances of financial noncompliance to resolve.

Internal Audit

• Provides information, analyses, and counsel to assist management in ethically, effectively and efficiently fulfilling their management responsibilities.
• Examines, evaluates and reports on the adequacy and reliability of existing internal controls.
• Recommends, as necessary, actions to improve; automated and manual systems of processing revenues and expenses, financial reporting, compliance with laws, regulations and internally developed polices and procedures and the safeguarding of assets.

Sponsored Programs Administration (SPA)

• Proposes policies and procedures to senior administration to comply with grants management regulations.
• Administers sponsored programs (budgetary actions, liaison with sponsor).
• Shares responsibility for training of researchers and staff in preparation of grant/contract applications and in management of sponsored research.
• Coordinates with various compliance offices to assure that specific proposals and projects have been reviewed and approved for compliance.
• Responsible as authorized official for certifying that institution is in compliance with applicable regulations.
• Responsible for implementing and interpreting sponsor and VU policies and procedures for compliance with applicable regulations.
• Shares responsibility with Research Finance, Academic and Research Enterprise, for formulation, implementation, and interpretation of policies regarding allowable costs and for training researchers and staff on proposing and expending allowable costs.

Research Finance (RF)

• Shares responsibility with DSR and Office of Research for formulation, implementation, and interpretation of policies regarding allowable costs and for training researchers and staff on proposing and expending allowable costs.
• Prepares invoices and letter of credit draws to sponsors on a timely basis.
• Prepares quarterly financial reports for federal agencies as required.
• Prepares interim and final financial reports in coordination with departments.
• Pre-audits certain financial transactions to ensure compliance with applicable regulations.
• Performs risk analysis for certain categories of expenditures to ensure compliance with applicable regulations.
• Identifies reportability of program income.
• Monitors levels of program income.
• Provides institutional oversight on cost transfers.
• Processes payments of approved subcontractor invoices.
• Approves or recommends approval of, carry forward of unexpended funds.
• Resolves payment problems with sponsors, in conjunction with Research Finance.
• Prepares, negotiates and administers the institution's indirect cost and fringe benefit rates in conjunction with the Department of Finance and other university departments.
• Assists departments in the proper development and administration of service center rates.
• Provides training as it pertains to the financial administration of sponsored projects to different constituencies.
• Provides oversight regarding financial compliance.
• Works with Compliance Officer and others to resolve instances of discovered financial noncompliance

PRINCIPAL INVESTIGATOR ELIGIBILITY

The policy of Vanderbilt University is that only full-time faculty members may routinely serve as Principal Investigators or Project Directors on sponsored programs. Certain  other titles are allowed to serve as Principal Investigators as described under Special Conditions below. Exceptions to this policy may only be made with the prior approval  of the Vice Provost for Research and Innovation.  Proposals for external funding will not be submitted by the University if they do not comply with this policy.

Full-time members of the faculty, for purposes of this policy, include the following titles:

• Professor, Associate Professor, Assistant Professor, University Professor, Senior Scientist, Research Scientist, Research Professor, Research Associate Professor, Research Assistant Professor

RATIONALE

The intent of this policy is to ensure that the responsibilities and authority vested in the role of Principal Investigator  are reserved for full time members of the University Faculty. Responsibility for setting the direction of Vanderbilt research rests squarely with the Faculty, who are primarily responsible for the quality of the research and the reputation of the University.  Vanderbilt's research directions are charted by University Faculty with a view towards their impact on the education of undergraduate  and graduate students. In this sense, research is an integral part of Vanderbilt's educational mission. Faculty whose appointments include public service obligations are held similarly accountable for the direction of outreach and extension activities in order to preserve the public trust. And, because of the significant degree of authority vested in the Principal Investigator relative to a wide range of administrative matters, including the allocation of human, financial, and facility resources, the responsibilities of being Principal Investigator must be primarily reserved to the Faculty.

DEFINITIONS

Principal Investigator (PI): This title identifies the individual responsible for the conduct of the project.  This responsibility includes the intellectual conduct of the project, fiscal accountability, administrative aspects, and the project's adherence to relevant policies and regulations. A project may have multiple individuals as PIs who share the authority and responsibility for leading and directing the project, intellectually and logistically. Each PI  is responsible and accountable for the proper conduct of the project. The presence of more than one identified PI on a  project diminishes neither the responsibility nor the accountability of any individual PI.

Co-Principal Investigator: This designation refers to individuals who share the responsibility for the project with the Principal Investigator  and therefore requires the same qualifications.

Co-Investigator  : This title designates key personnel for a project, but without the oversight responsibility of a Principal Investigator. Individuals do not need to meet the qualifications of PI under this policy, but should be considered key to performance of the project.

Project Director: This title is a synonym for Principal Investigator on non-research sponsored programs or for "program-project" grants.

All of the above titles are recognized as having official responsibility for the sponsored program. Sponsors generally will require approval of their substitution.

SPECIAL CONDITIONS

Persons with the following titles are authorized to be Principal Investigators within the  identified limitations as determined by the department/center, or the college, in which the  person is appointed:

Senior Research Associate: Limited to research projects related to an individual's official duties.*

Senior Lecturer: Limited to scholarly projects related to an individual's official duties* under his/her respective college's policy guidelines  (which are approved by the Vice Provost for Research).

Librarian or Associate Librarian: Limited to projects related to an individual's official duties* and which will enhance the mission of the libraries.

Emeritus Faculty: Participation as a Principal Investigator is conditional on the availability of departmental  resources as determined by the department chairperson or center director.

*"Official duties" means those duties specified at appointment or subsequently modified in writing.

STUDENT-INITIATED PROJECTS

Certain sponsored programs have as their purpose the support of postdoctoral, graduate, (and occasionally undergraduate) education or research through  student-initiated projects, (e.g., doctoral dissertations, predoctoral, postdoctoral research fellowships). For these sponsored programs, the following conditions apply:

1. A full-time faculty member, as identified above, must serve as Faculty Advisor.
2. The Faculty Advisor shall retain the responsibilities of a Principal Investigator under this policy.
3. The postdoctoral associate or fellow, graduate, or undergraduate student shall be responsible for the intellectual conduct of the project within the oversight of the Faculty Advisor.
4. The proposal to the sponsor may name the postdoctoral, graduate, or undergraduate student as Key Personnel, as long as the Faculty Advisor is named as the responsible individual (i.e., Principal Investigator, Project Director or Faculty Advisor). If required by the sponsor, the student may be named as PI. The proposal should acknowledge the student's authorship of the proposal, as appropriate.

OTHER ACADEMIC TITLES

Titles modified with the terms of "acting", "adjunct", "courtesy", or "visiting" do not confer the right to serve as a Principal Investigator. When these modifiers are used, special one-time approval for a specific project and duration may be provided under the Exceptions provision. Since "visiting" and "courtesy" appointments are for individuals whose primary responsibilities rest outside the university, these modified titles would require exceptional justification. Research Associates, Lecturers, or Senior Assistant Librarians may be designated as temporary Principal Investigators to oversee an existing funded project while the authorized PI is away on leave or extended travel without formal approval from the Vice Provost for Research. The normal approval of the department, SPA, and the sponsor is sufficient.

NON-ACADEMIC TITLES

When a sponsored program will be administered by a non-academic unit, or when the PI will serve in an administrative role only, the Vice Provost for Research and Innovation may approve an appropriate non-academic staff member to serve as Principal Investigator/Project Director. It is expected that the staff member proposed by the unit will be a regular full-time exempt employee with managerial or supervisory responsibilities.

NON-SPONSORED PROJECTS

For internal grant programs (i.e., project grants from institutional rather than external funding sources) the application of this policy shall be left to the discretion of the Director of the respective grant program, although this policy's rationale must be considered.

CONFLICT OF INTEREST DISCLOSURE STATEMENT

As a matter of Vanderbilt University policy and federal regulation, it is required that Principal Investigators and key personnel on sponsored projects must have completed a Conflict of Interest and Commitment Policy form, also known as the "annual disclosure statement." The disclosure form may be obtained from the Designated Representative in each college or unit or by contacting the Office of the Vice Provost for Research and Innovation and/or the Office of the Dean of Faculty. The Vanderbilt University Conflict of Interest Policy is available here.

RECOGNITION OF AUTHORSHIP IN PROPOSALS

The title of Principal Investigator is primarily a designation of institutional responsibility for the conduct of a sponsored program. As such, the title does not necessarily represent the principal authorship of the proposal document. The Vanderbilt Code of Academic Integrity applies to sponsored program proposals. Therefore, it is important that authorship is appropriately attributed in all proposal documents.

This attribution may be handled in any number of ways; the most common ways are described here:

1. If the authors are all listed as Principal Investigator, Project Director, Co-Principal Investigator, or Co-Investigator, no further action is necessary.
2. If the proposal has been prepared on forms provided by the sponsor, such as those of a governmental agency, the authors may be identified in the Personnel section of the narrative, or as a footnote to the narrative.
3. If the proposal has been prepared without forms provided by the sponsor, as may be the case with a foundation or corporate sponsor, the authors may be identified on the cover page, or by using the methods described above.