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University of Wyoming
Roles and Responsibilities for Sponsored Project Management
Table of Contents
D. Policy Statement
The purpose of this policy is to establish guidelines for the roles and responsibilities of Principal Investigators (PI), their academic unit, Research and Economic Development and Sponsored Programs in the administration and management of sponsored projects. An understanding of the roles and responsibilities related to sponsored projects will result in more effective and efficient management including meeting project deadlines, reducing duplicate efforts, complying with regulations and grant/contract terms, achieving budget expectations, and establishing accountability.
The University of Wyoming (UW) PI and administrative unit are responsible for complying with and enforcing the policies and procedures outlined herein. Any penalties, disallowances, or losses of funding caused by non-compliance with this policy will be the responsibility of the administrative unit in violation of the policy.
This policy applies to all PIs, personnel that have been designated PI roles and responsibilities (hereinafter referred to as "designee"), relevant administrative unit(s), Research and Economic Development and Sponsored Programs
1. Office of Management and Budget Circular A-21, Cost Principles for Educational Institutions
2. Office of Management and Budget Circular A-110, Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
3. University of Wyoming Sponsored Research Audit Report
1. Administrative unit is the part of a school, college, department, division, center, institution section or large program at UW.
2. Application is the form(s) or document(s) required by external agencies or entities when applying for funding for a sponsored project. The words "application" and "proposal" are used interchangeably throughout this policy.
3. Facilities and Administrative Costs ("F&A", also referred to as indirect costs, overhead and G&A), for sponsored project costing purposes, are those that are incurred for common or joint objectives (research, instruction, public service, or patient care) and, therefore, cannot be identified readily and specifically with a particular sponsored project, an instructional activity, or any other UW activity. F&A rates are negotiated with and established by our cognizant federal agency.
4. Personnel Activity Reporting (PAR) System is a system of monthly, after-the-fact confirmation reports that document the percentage distribution of effort for the period reported and substantiates salary charges to sponsored projects.
5. PostAward is the period from actual receipt of an award document or fully executed agreement through final project technical and financial reporting, closeout from the accounting system, and audit resolution.
6. PreAward is the period of time during which a proposal is developed, reviewed, submitted to a funding agency, and, if necessary, negotiated prior to actual receipt of an award document or fully executed agreement.
7. Principal Investigator/Project Director is typically a faculty member who submits or submitted an application or proposal that was accepted and funded by a sponsoring agency. The Principal Investigator has primary responsibility for technical compliance, completion of programmatic work, and fiscal stewardship of sponsor funds.
8. Proposal is a document in which the prospective principal investigator describes his/her plan for a research, training, or other project and requests financial support. The words "proposal" and "application" are used interchangeably throughout this policy.
9. Sponsored Projects are research, instructional, or public service activities related to the mission of UW and sponsored by external agencies or entities. F&A cost recovery is not a factor in determining whether funding is a sponsored project. Application/award issues that require administration by Sponsored Programs include any one of the following:
- the award is a grant or contract from a governmental entity;
- sponsor support is directed to satisfy specific, programmatic objectives that are to be accomplished within a specific time and budget framework;
- the sponsor is entitled to receive some deliverable, such as a detailed technical report of research results, a report of expenditures, or other reports;
- there is a provision for audits by or on behalf of the sponsor;
- the funding is for a project with compliance requirements including but not limited to human subjects, animal use, biohazards, and biosafety;
- publication restrictions, patent, or licensing rights or rights to the use of research data are a condition of the award.
D. Policy Statement
The Office of Research and Economic Development is the coordinating office for externally funded activities at the UW and serves faculty and staff by assisting in the preparation, review and execution of applications and proposals, negotiation and execution of mutually binding agreements, and the administration of UW's funded projects. The following is provided to clarify the responsibilities of Research and Economic Development, Sponsored Programs, PIs, and their academic units in both PreAward and PostAward activities.
2. PreAward Responsibilities
Sponsored projects are funded by a wide array of sponsors including Federal, state and local governments, federally-funded laboratories, non-profit associations and organizations, associations and foundations, and for-profit corporate entities. The application process varies depending on the sponsor, and each one will have unique requirements. The PreAward process requires Research and Economic Development, the PI, and the academic unit that is pursuing sponsored project funding to be responsible for various activities in the process.
a. Research and Economic Development
- Provide pre-submission assistance and review of proposals.
- Review proposal documents to ensure that all institutional proposal requirements and sponsoring agency rules and regulations are observed.
- Provide institutional approval prior to submittal(s).
- Review award documents for comprehensiveness, appropriate use of language and compliance with guidelines and requirements set by sponsoring agencies, UW and the State.
- Negotiate terms and conditions and budgets for all UW extramural awards.
- Accept awards and execute agreements on behalf of UW.
- Act as primary administrative contact point for all sponsoring agencies.
- Interpret and disseminate major sponsor policies and forms within UW.
- Facilitate the transfer of a PI's proposals or awards from other organizations.
- Maintain administrative and costing information necessary for the proper preparation of a proposal for extramural funding.
- Prepare routine and ad-hoc reports.
- Facilitate submission of timely information requested by sponsoring agencies.
b. Principal Investigator(s)/Project Director(s), Designees and Academic Unit
- Contact Research and Economic Development to inquire about funding opportunities.
- Contact sponsor for appropriate application forms if not available from Research and Economic Development.
- Prepare application for sponsoring agency, including the budget and technical portions of the application and all appropriate assurances for UW approval and submission to sponsoring agency.
- Prepare institutional forms and coordinate process for internal approval ("routing") of application. Include all sponsor specific application guidelines to facilitate the review process.
- Communicate with Research and Economic Development if there is a question regarding the appropriate F&A cost rate, e.g., on- or off-campus rate.
- Obtain all appropriate approvals, e.g., all signatures required on the UW Greensheet Routing Form. Include in routing materials any additional forms and any special approvals for human subjects, lab animals, hazardous materials, biosafety agents, or cost share. At the time of submission, the proposal should be complete administratively and scientifically for the final review and signature.
- Answer project-specific questions of the sponsoring agency.
- Prepare, obtain institutional approval, and submit timely information requested by sponsoring agency (e.g. Just-In-Time requests by NIH).
- Communicate with Research and Economic Development deadlines which impact submission of materials requested by sponsoring agency.
3. PostAward Responsibilities
PostAward administration is a joint effort on the part of the PI, designee, departmental administration, and Sponsored Programs. Each area has specific responsibilities to ensure that UW complies with Federal, state and sponsor guidelines. Failure to comply with the required guidelines or regulations may jeopardize UW's ability to qualify for future funding.
Sponsored project awards are legally and mutually binding agreements between the sponsoring agency and the University of Wyoming. Although the agreement is with the institution, the PI has primary responsibility for achieving the technical success of the project, while also complying with the financial and administrative policies and regulations associated with the award. Although PIs may have administrative staff designated to assist them with the management of work and project funds, the ultimate responsibility for the management of the sponsored project work and funds remains with the PI. Inherent in this responsibility is the obligation to adhere to all terms and conditions of the award and to adequately document all expenditures and budget modifications in accordance with sponsor regulations.
a. Research and Economic Development
- Review and negotiate subrecipient agreements(s), prepare subrecipient agreement(s) when subrecipient is documented in the award or when requested by the PI or designee, verify budgets, assure compliance with policies and guidelines as they relate to subrecipient agreements, and serve as a liaison between funding agencies, academic unit and PIs.
b. Sponsored Programs
- Review the award notice for special terms and conditions, including prior approval requirements, matching funds, and cost sharing.
- Set up project in the financial system and establish the appropriate budget for the project, in accordance with the sponsor's award notice.
- Monitor selected expenditures in the financial system, within established parameters, as to allowability, allocability, and appropriateness.
- Work with PI or designee to obtain approvals for equipment purchase, travel, no-cost extensions, or other items that may require sponsor approval.
- Research, analyze, and clarify for faculty and staff various University, State, and sponsor policies, procedures, and regulations.
- Manage billing and cash collection activities and perform appropriate follow-up when payments are past due.
- Review and approve, as appropriate, all subrecipient invoices related to the project ensuring compliance with Sponsor cost principles.
- Prepare interim and final financial reports.
- Work with PIs and/or UW State/Federal Reporting/Property Accounting as necessary to complete invention and/or property reports when specifically requested by sponsors.
- Administer the Personnel Activity Reporting (PAR) system.
- Coordinate all financial audit matters relative to sponsored projects.
- Prepare routine and ad-hoc reports.