This guidance is based on UCOP’s Contract and Grant Manual, Section 10-340, (which details Deans, Department Chairs, and Directors (including ORU Directors) responsibilities and duties related to review of proposals for extramurally sponsored grants, contracts, and other agreements.
By reviewing any proposal intended to be submitted seeking extramural support for projects conducted in their units, and approving (prior to January 1, 2018, by reviewing/signing Datasheet, and since January 1, 2018, by reviewing and approving proposals in Cayuse SP) the respective Dean, Department Chair, or Director verifies/certifies the following:
- an individual’s eligibility for Principal Investigator status;
- verification of the consistency of the proposed project with the educational, research, and/or public service objectives of the organizational unit;
- determination that the appropriateness and acceptability of faculty/researcher time, space, equipment, and University financial commitments contained in proposals for sponsored projects;
- ensuring that project scope of work is consistent with internal University policies, with externally imposed sponsor terms and conditions, and with the organizational unit’s educational, training, and/or other objectives; and
- identifying appropriate funding sources to cover project costs not covered by the project sponsor’s funds or by other funds available to the Principal Investigator.
It is after verification of the above that the Chair/Director/Dean will approve the Internal Processing Form (IPF) in Cayuse SP to move the project (proposal or award) forward. This process provides Dean/Director/Chair’s authorization for Sponsored Programs to accept, within University policies, award(s) that may result from the proposal.
These responsibilities may not be delegated to staff. If the Dean, Department Chair, or Director is unavailable to review and approve proposals, or if the Dean, Department Chair, or Director has a personal financial interest in the proposed sponsor of a project, then another academic member of the unit should be delegated to do review/approve the proposal.
The following may be helpful for the Dean, Department Chair, or Director in deciding whether they are able to endorse a proposal to proceed.
- Financial Resources
Are the resources required to carry out the project currently available? Have cost sharing or matching commitments been made? If so, are appropriate resources available for these commitments? (SPO requires documentation of all financial cost sharing commitments to be submitted with the proposal.) If two or more units are involved, are the cost sharing responsibilities of each clearly understood and documented?
Is the space needed for the project adequate and available for the full project period? If additional space or facilities will be required, have appropriate commitments been made to assure their availability for the project? Have the Deans and Chairs of other involved units been consulted?
- Faculty and Staff Time
Are the time commitments proposed by the faculty reasonable to achieve the goals of the project in light of teaching and other University responsibilities? Is release time likely to be required? If so, can it be approved? Will any faculty time be committed as cost share? This should be clearly indicated in budget for the proposal. Approval in Cayuse by the Chair or Director of the Academic Unit indicate approval of any faculty time commitments listed. Will the principal investigator/project director and other key personnel be available throughout the proposed term of the project? If the project involves staff employees, are they available and properly funded for the entire project period?
- PI Status
If the proposed principal investigator (PI) does not have “Regular Eligibility”, or “Eligibility by Special Request” to be a PI, as detailed in PPM 230-02, the Dean/Chair/Director is required to seek “Eligibility by Exception”, following the requirements of PPM 230-02, as a part of the proposal package.
Is the proposed project acceptable under the principles of University Regulation 4 regarding faculty salaries and investigations of a purely commercial nature? Is the proposed project appropriate for the principal investigator/project director(s), the administering unit, and the campus to undertake? Does it serve the University missions of expanding knowledge and educating students? Is there significant graduate student involvement? If not, why? If the project involves other units on campus, have the chairs and deans of those units been consulted?
The Guide to Research Compliance for Principal Investigators and Department Administrators provides a single reference for all the accounting, safety and ethical guidelines that must be taken into consideration on sponsored projects.
The Principal Investigator is responsible for:
- Scientific integrity and management of the project.
- Financial management of project funds, including recovery of full indirect costs. Full cost recovery is necessary to support the University’s physical and administrative capacity to perform extramural projects.
- Adherence to all University policies.
- Adherence to externally-imposed sponsor terms and conditions including reporting and record keeping requirements contained in the award document. The award document is the funding agency’s official obligation of funds for a project. Many awards cover a multi-year project period made up of several shorter (usually 12-month) budget periods. Funds often are awarded in budget period installments.
By certifying the Cayuse SP Internal Processing Form (IPF) for Contract and Grant Proposals the Principal Investigator certifies to all of the following:
- That the information submitted within the proposal/application is true, complete and accurate to the best of his/her knowledge;
- That any false, fictitious, or fraudulent statements or claims within the proposal/application may subject him/her personally to criminal, civil, or administrative penalties;
- That he/she agrees to accept responsibility for the scientific conduct of the project and to provide the required progress reports to the sponsor if a grant is awarded as a result of the proposal/application;
- If the sponsor follows PHS COI, the Principal Investigator/ Project Director, and all Investigators (with responsibility for the design, conduct, or reporting of research) on this project, each have completed (1) the on-line educational training requirement, as well as (2) the on-line financial interest disclosure;
- That he/she will comply with sponsor and University policies and regulations;
- That he/she has read, and he/she is, or will be in compliance with and abide by all the items included here;
- The reasonableness of the kinds and levels of resources proposed and overall funding for the budget included for any subawardee(s)/subcontractor(s) listed in the proposal;
- That he/she has examined the proposal for completeness and accuracy (including the truthfulness of the scientific claims made, biographical data, and budget estimates), and explicit acknowledgment has been given to those who substantially contributed to the preparation of this proposal.
- That he/she understands that willful provision of false or misleading information can subject the investigator and the University to severe monetary penalties.
- That if the proposal is submitted to a Federal agency either directly or indirectly (i.e., through another organization), he/she and all Key Personnel are in compliance with applicable Federal financial disclosure regulations;
- That if the proposal is submitted to a non-government organization that is not on the financial disclosure exemption list (see Section 7, above), he/she has completed and attached the state financial disclosure form (Form 700-U);
- That he/she has read and will abide by the University policy on “Integrity in Research,” dated June 19, 1990 (available at https://policy.ucop.edu/doc/2500496/IntegrityInResearch);
- That if the proposal is submitted to a Federal agency either directly or indirectly through another organization, neither he/she, nor any person who will receive compensation under the anticipated award, is currently debarred, suspended, nor proposed for debarment from receiving Federal support for research. Further, he/she will notify Sponsored Programs if any person who will receive or is receiving compensation under the subject award is debarred or suspended from receiving Federal funds prior to the project’s expiration date;
- That if the proposal is submitted to a Federal agency either directly or indirectly through another organization, and if he/she or anyone funded by the project have engaged in any lobbying efforts for this project, he/she has done so on their own time and at their own expense and have not used any federal funds for this purpose. Further, if lobbying activities related to this project have been paid from a non-federal source, he/she will complete and submit Standard Form LLL, Disclosure of Lobbying Activities;
- That if this project involves human subjects, he/she has read and will abide by and will ensure that those working on this project abide by applicable University and federal policy on the protection of human subjects;
- That if this project will involve laboratory animals, he/she has read and will abide by and will ensure that those working on this project abide by applicable University policy on the care of laboratory animals;
- That all direct charges to the contract or grant directly relate to the activity supported and are reasonable and allowable; that expenditures are consistent with all special terms, conditions, or limitations that apply to expenditures under the particular contract or grant; and that expenditures do not exceed the total funds authorized for a given period under the contract or grant. (In many cases the contract or grant may also specify expenditure limits by budget category or line item);
- That he/she will be accountable for deficits or disallowances that occur under a contract or grant in accordance with campus procedures;
- That he/she will keep adequate records related to the activities on this project and is aware that all such records, including laboratory notebooks, are the property of the University;
- That if this proposal contains any information that needs to be kept confidential by federal or other reviewers and administrators, he/she has marked such information appropriately;
- That if this project will involve patient records, he/she will keep such records confidential;
- That if this project involves nonexempt use of recombinant DNA molecules, he/she will ensure that the research will be approved by the relevant campus biosafety committee;
- That if the proposed research involves the taking, importation, or use of protected marine mammals, or any endangered or threatened species, he/she will comply with the applicable federal and/or state regulations and obtain the necessary permits and authorizations;
- That he/she will comply with all applicable University policies for the conduct of research involving biohazards, carcinogens, hazardous or toxic wastes, or controlled substances;
- That he/she will comply with all applicable University policies regarding nondiscrimination;
- That if this is a proposal that will result in a contract under which he/she will provide technical advice to the federal government, then he/she does not believe that performance of this service will give him/her an unfair advantage in competing for other government contracts, nor does he/she believe that he/she will be unable to render impartial advice or assistance;
- That if this is a proposal that will result in a federal contract in excess of $100,000, he/she has not employed or retained any person or company to solicit or obtain this contract;
- That if this is a proposal that will result in a federal contract in excess of $100,000, he/she has not offered any gift, discussed any job offer, or solicited any proprietary information or source selection information from any federal official who is involved in awarding this contract;
- That he/she is eligible to be a Principal Investigator on a UC Davis project;
- That the salaries included in the proposal budget are in compliance with UC salary scales (see Academic Personnel Manual and Staff Salary Scales Manual);
- That the employee benefits budgeted in the proposal are either based on actual benefits rates or campus composite rates, exclusive of leave accrual;
- That either applicable federally-negotiated indirect (F&A) cost rates have been used or an approved waiver is currently on file or has been requested for the F&A rate used in calculating the budget;
- That graduate student fee remission and/or non-resident tuition, if allowable, has been included for eligible Graduate Students assigned, or expected to be assigned, to the project in accordance with campus policy;
- That the cost of living adjustments do not exceed recommended levels, or if they do they have been adequately justified;
- That the sponsor or an agent acting on behalf of the sponsor will have access to the facilities where the project is conducted, and be permitted to review technical and financial project records;
- That he/she has the technical ability to conduct the project, and that research space, including any special utilities, transportation requirements, or facilities, is available to conduct the project and necessary approvals have been authorized; and
- That each Co-Principal Investigator and Key Person listed on this project is aware that his/her names have been included in the proposal and that each is willing to provide support to the project.
The Principal Investigator should review and understand the contract or grant requirements and restrictions of each specific award and contact Sponsored Programs for any needed clarification and guidance. If the terms of an individual award are stricter than federal guidelines and University policy, the terms of the award take precedence. For example, travel expenses are allowable under federal and University policy, but may be specifically excluded or limited by your specific award.
It is important upon receipt of the fully executed award for the Principal Investigator and the Administering Unit to review the terms and conditions, make note of important conditions including, but not limited to, reporting deadlines, unallowable costs, areas that may require prior approval such as re-budgeting or no cost time extensions, publications may require sponsors review prior to dissemination, etc.
The Principal Investigator must regularly monitor the award to ensure adherence to award terms and conditions. Financial Ledger Reviews should be performed at least once a month. The offices of record for expenditures is the Contracts and Grants Accounting (CGA) office. Upon receiving a fully signed and executed award from the office of contracts and grants, Extramural Accounting will establish a specific account and fund number for the project. The administering unit charges all costs to this number at the direction of the PI or PD. The budget for expending funds is allocated to sub-budget categories based on amounts in the proposal budget agreed to by the university and the funding agency.
Principal Investigators and others committing effort must certify that effort after the effort has been expended. It shows the actual effort, as a percentage of time, spent on the project. Effort reporting ensures that the effort charged or committed to each research award has actually been met. Effort reports are tracked in the Effort Reporting System (ERS). For more information about Effort Reporting, please visit Contracts and Grants Accounting (CGA) Effort Commitment and Cost Sharing pages and UC Davis Directive.