Principal Investigator/Project Director Responsibilities For Financial Management Of Sponsored Projects Policy

Scope

Principal Investigators/Project Directors (PI/PD) of all sponsored projects, whether funded from federal or non-federal sources.

General Policy Statement

As a recipient of grants and awards from the federal government and other third-party sponsors, Syracuse University (the “University”) is required to provide accurate, timely, and complete disclosure of the financial results of sponsored awards and programs. The United States Office of Management and Budget (OMB) Uniform Guidance requires an adequate internal control structure be in place at the University to support appropriate and prudent spending of sponsor funds. This Policy sets forth the internal control requirements for Principal Investigators and Project Directors involved with financial management of individual awards.

Reason for Policy/Purpose

The University must comply with the OMB Uniform Guidance and related federal regulations governing financial management of sponsored projects. This Policy sets forth the duties and responsibilities of Principal Investigators and Project Directors regarding financial management of sponsored projects.

Policy

1. Principal Investigator (PI) or Project Director (PD) Duties and Responsibilities The PI or PD is ultimately responsible to: (1) oversee the overall finances of his or her award; (2) ensure compliance with University and sponsored award financial management practices; (3) direct financial transactions; and (4) monitor the financial status of each sponsored project.These responsibilities are required to ensure that the costs charged to each award:
   • Comply with sponsor and University policies and procedures, meaning the costs are:
     • allowable under the terms and conditions of the award; and
     • necessary for completion of project objectives;
   • Do not exceed the proportionate benefit received by the award, meaning:
     • personnel costs are consistent with the effort as certified by the individuals working on the award; and
     • other costs, including institutional contributions (cost sharing), are appropriately allocated;
   • Are made in a timely manner;
   • Are limited to funds awarded; and
   • Are adequately documented.
2. Allowable Costs Executing these financial management responsibilities requires that the PI or PD be aware of costs that are and are not allowable under federal regulations, University policies, and the terms of an award, and clearly communicate instructions to those performing the day-to-day administrative tasks on how to allocate charges among various funding sources.
3. Delegation of Duties The PI or PD may delegate responsibility for the day-to-day financial management of a project to one or more individuals within the department, program, or unit; such delegation does not relieve the PI or PD from the stated responsibilities associated with award management. The University encourages the use of unit or departmental administrative staff to perform routine activities related to award management, such as ordering supplies, processing salary distributions and vendor invoices to minimize the administrative burden of award management on the PI or PD.The PI or PD is not responsible for the preparation and submission of financial reports. Those are the responsibilities of the Office of Sponsored Accounting.
4. Enforcement PIs or PDs who consistently fall short of the above responsibilities to adequately manage sponsored projects as determined by the Offices of Sponsored Programs or Sponsored Accounting may be subject to University sanctions by the Vice President for Research, including, but not limited to, loss of privileges to apply for external support.

Appendices (as applicable)

1. Procedures Procedures for financial management of sponsored projects or programs can be found in the Pre-Award Manual published by the Office of Sponsored Programs and available at http://osp.syr.edu/Sponsored%20Programs%20Resources/Procedures%20and%20Guidelines/preaward-manual.html.
2. Other Related Policies and Documents
   • http://supolicies.syr.edu/admin/unallowable_costs.htm
   • http://supolicies.syr.edu/admin/cost_sharing.htm
   • http://supolicies.syr.edu/admin/cost_transfer.htm
   • http://provost.syr.edu/faculty-support/faculty-manual/
   • http://supolicies.syr.edu/admin/effort_reporting.htm

Date: June 26, 2014
Amended:April 25, 2016