All policies pertaining to Graduate Programs and the Office of Research and Projects must be approved by the Graduate Council. Policies relating to Graduate Programs and the Office of Research and Projects are reviewed in the Graduate Council's Education and Research Policies (ERP) Subcommittee annually to ensure currency and relevancy. ERP recommends appropriate revisions to the Graduate Council for approval. Policies approved by the Graduate Council are submitted for University approval as described on the SIUE Policies and Procedures Homepage.
The Authorized Organizational Representative for all externally sponsored grants and contracts at SIUE is the Dean of the Graduate School.
See also SIUE's Responsible Use Policy which covers permissible and impermissible use of university electronic and computing resources.
The principal investigator/project director of a grant usually serves as fiscal officer of the project. The principal investigator/project director must be familiar with institutional procedures and the granting agency requirements applicable to the specific grant. Responsibility for the expenditure of grants and contract funds rests with the fiscal officer. Over or improper expenditures of funds could result in embarrassment to the fiscal officer and the University. The Office of Research and Projects Fiscal Management works closely with the principal investigator/project director regarding expenditure of grant or contract funds.
The Office of the Research and Projects arranges for a new account and assumes responsibility for the administration of sponsored grant funds and assists the principal investigator in assuring that grant funds are expended in accordance with State, Federal and other regulations. ORP reports on the financial status of the account to the funding agency and copies are forwarded to the principal investigator/project director.
The principal investigator/project director has primary responsibility for the performance of the research/project in accordance with the proposal submitted. Because all factors affecting the project cannot be anticipated, changes in project procedures or objectives may be necessary. The requirements for reporting or obtaining approval for changes are usually specified in grants, contract documents, or other administrative information provided by the sponsoring agencies. Requests for changes in either the proposed project or budget must be approved in advanced by the Office of Research and Projects.
Most funding agencies require the submission of regular narrative/performance reports in addition to the regular financial reports during and/or after the completion of a project. The principal investigator/project director has the responsibility of completing the narrative/performance reports and for filing them prior to the agency's deadline. A copy of each report must be sent to the Office of Research and Projects prior to its submission to the agency.
Negotiations for subaward sharing are governed by the following considerations.
SUBAWARD (SUBRECIPIENT) MONITORING GUIDELINES
A subrecipient is a third-party organization performing a portion of SIUE's sponsored project or program. The terms of the relationship are documented in a subaward (subgrant/subcontract or consortium agreement). These guidelines are intended to assist responsible faculty and staff in ensuring (1) that the subrecipient is conducting its portion of the research in compliance with applicable laws and regulations and with the terms of the award and subaward, and (2) that the subrecipient's portion of the project costs is reasonable and allowable. Subrecipient monitoring is required by the federal government for federally funded subawards.
Roles and Responsibilities
1. Principal investigators (PIs) or their assigned grant accountants have primary responsibility for the monitoring of subrecipients to ensure compliance with federal regulations and with the terms and conditions of both the prime award and the subaward.
2. The Office of Research and Projects (ORP) has responsibility for ensuring that subaward agreements contain appropriate federal and other applicable regulations consistent with sound business practices and for collection of subrecipient federal audits, if necessary.
3. The ORP has responsibility for assisting PIs in reviewing invoices from subrecipients, questioning expenditures if necessary, and general cost allowability issues.
4. Resolution of complex subrecipient monitoring issues or the determination of courses of action will be done jointly by the PI, ORP, and other administrative officials as appropriate.
The federal regulations that describe subrecipient monitoring are general, but contain the following core elements of compliance:
* The routine receipt and review of technical performance reports.
* The routine review of expenses vs. budget.
* The option to periodically perform on-site visits, if necessary.
* The option to perform "audits," if necessary.
It is also important to note that there may be additional sponsor-specific or program-specific requirements that mandate collection and documentation of other kinds of assurances (e.g., on lab animals, human subjects, biohazards, etc.) during the course of a project.
SIUE's Subrecipient Monitoring Guidelines
Certain subrecipient monitoring requirements imposed upon federally funded subawards are set forth in OMB circular A-133.
Verification of the subrecipient's annual audit must be obtained from each subrecipient whose federal funding level exceeds $300,000. This is handled by ORP. Additional monitoring activity includes the following:
Collection of Technical Performance Reports - Technical Performance Reports should be reviewed and evaluated on a timely basis by the PI, unusual or unforeseen items should be investigated, and reports should be retained on file in the department for ready access by regulators. In some cases, subaward terms may require specified deliverables in addition to, or in lieu of, technical reports.
Review of Invoices and Expenses-to-Budget - For cost-reimbursement subawards, the subrecipient's invoices showing both current period and cumulative expenses-to-budget are generally required. PIs (or their assigned grant accountant) should compare the subrecipient's invoices to the established subaward budgets. Evidence of the regular review of invoices should be in place and retained on file. "Evidence" can be in the form of PI initials or an authorizing signature on invoices, e-mail communications, etc.
Clarification of Invoiced Charges - PIs (or their assigned grant accountant) should request explanations for any "unusual," "miscellaneous," "other," or apparently excessive charges invoiced by the subrecipient. If the explanations received are not sufficient to render a prudent judgment on the allowability of the cost, PIs may request detailed justifications from subrecipients. Examples of detailed justifications that may be requested from subrecipients are:
* Payroll records/data.
* Copies of paid invoices showing the cost of items purchased, and Vendor Justification Forms, if required by federal contract.
* Descriptions of services rendered by consultants, including hourly rates and time reports.
* Detail of travel charges incurred, stating the purpose, airfare, meals, ground transportation, unallowables, etc.
Costs determined to be unallowable or unreasonable should be disallowed. PIs should work with their assigned grant accountant to make such determinations. In extreme circumstances where questionable costs remain unresolved, it may be necessary to have an audit conducted. In such situations, PIs should contact ORP (see Audits, below).
Regular Contact - PIs are expected to maintain regular contact with subrecipients and conduct appropriate inquiries into program activities.
On-site Visits - On-site visits are a discretionary monitoring procedure. On-site visits conducted by the PI to evaluate both compliance with the scientific objectives of the project and the appropriateness of the subreceipient's administrative systems, processes, and charges should be documented via correspondence, meeting notes, trip reports, etc., and retained on file.
Audits - Discretionary audits of subrecipients are an acceptable monitoring procedure under federal regulations, and all of SIUE's cost-reimbursement subaward agreements contain "right-to-audit" clauses. Formal audits are performed very infrequently, however, and PIs should contact ORP before proceeding.
Technology transfer is the name given to the process of converting scientific findings from research laboratories into commercial or otherwise useful products. This may involve the selling of or simply sharing scientific knowledge so that it can be spread to other individuals and institutions who may develop it further.
Contact the Dean or Associate Dean for Research for assistance with issues regarding technology transfer.