Awards are accepted by VCU on behalf of the Principal Investigator (PI). While the PI assumes the responsibility for financial oversight and completion of the work, the University remains legally responsible for the award. All awards must conform to university policies and procedures.
The receipt of an agreement for negotiation and signature (bilateral award) or an award notification directly from the sponsor (unilateral award) prompts the Division of Sponsored Programs to generate a Compliance Data (CD) record in RAMS-SPOT based on the approved Funding Proposal (FP). The CD is a mechanism allowing PI/SS to provide updated project-specific information regarding the use of human and/or animal subjects; use and/or creation of intellectual property; activities related to export concerns, etc. This information will be evaluated by the Division of Sponsored Programs against the proposed scope of work and the terms of the award.
The Division of Sponsored Programs Post Award is responsible for the creation of the RAMS-SPOT Award (AW) record. All awards must be assessed for internal compliance requirements; award terms and conditions; reporting requirements; and internal and/or sponsor restrictions. The Division of Sponsored Programs Post Award team will notify Grants and Contracts Accounting and Effort Reporting when an award has been finalized and is ready for Banner set-up.
Delays are typically related to receipt of Compliance Data; Financial Conflict of Interest reporting, including the need for Financial Interest Report (FIR) completion/update and the management of an identified conflict; completion of PI Training; receipt of human and/or animal subject approvals; coordination with the Export Compliance Program; and resolution of sponsor-imposed restrictions.
Some sponsors may require a specific follow-up action or submission of documentation shortly after an award has been made. Common sponsor restrictions include: submission of a revised budget; submission of human and/or animal subject approvals; fellowship activation; reporting on funding awarded for a restricted purpose; or reporting related to the achievement of milestones/deliverables/accruals.
|VCU policy or compliance notice||Policies, procedures and compliance notices|
|Related VCU systems||RAMS-SPOT|
While sponsored funds may allow a great deal of freedom to conduct a project, they almost always require a concomitant level of responsibility for proper stewardship. Each sponsored project must have a designated leader, a principal investigator (PI) or project director, who has the obligation to see that the terms of the grant or contract are fulfilled.
Although the university is legally accountable to the sponsor as the official recipient of a grant or contract, the principal investigator or project director is responsible for the proper fiscal management and conduct of the project. To assist the faculty member in this very important responsibility, the university provides supporting administrative services and has established policies and procedures to help meet both sponsor and university administrative requirements. The university is, ultimately, legally and financially responsible and accountable to the sponsor for the performance of the sponsored activity and the proper use of funds, but without the full cooperation and vigilance of the PI, the university would fail in its stewardship role. In the truest sense, therefore, the sponsored programs process is a joint effort between the PI and the university; both must do their part well in order to achieve success.
It is very important that the PI reviews the official award and understands all requirements. The PI must comply with all terms and conditions imposed by the sponsor and ensure that project funds are managed efficiently and effectively within approved budgets. The PI must initiate all required approvals for budgetary and programmatic changes that may be necessary during the project. The PI is likewise responsible for the preparation and timely submission of technical reports and any other required deliverables.
In addition, the PI must ensure that all project members are familiar with and comply with the intellectual property and publication clauses of the award, with federal policies regarding research safety and research subjects safety, protections and integrity, as well as with applicable U.S. export control regulations. Inventions and copyrightable material produced under sponsored projects must be governed by the specific terms of the award received from the sponsor and must be handled in accordance with university policy.
Projects are conducted as a function of the appropriate area (department, school or institute). If the project is over expended, or if an expenditure is disallowed by an auditor, the university will ask the PI to cover this cost. It is the responsibility of the PI to ensure that over-expenditures and disallowances do not occur.
The PI has responsibilities to the sponsor, the department, the school or institute, and the university to ensure that the requirements of the sponsored project are met and that university policies and procedures are followed.
See the Subrecipient(s) section of this navigator for guidance on initiating a subrecipient agreement with an external collaborator.
VCU is committed to fostering an environment of uncompromising integrity and ethical conduct. As such, all university members are expected to adhere to the highest ethical standards of professional conduct and integrity. Our core values and principles include: respect, honesty, excellence, responsibility and accountability, stewardship and compliance. These core values provide an overarching framework that applies to the conduct of research and scholarly activities carried out by university members.
|VCU policy or compliance notice||See Responsible Conduct for Research (RCR) for full list|
|Related VCU systems||Additional information available on the Integrity and compliance website|
|Responsible VCU unit(s)||Division of Research Compliance|
Invoices and financial reports are prepared by Grants and Contracts Accounting and Effort Reporting as required by the terms of the award.
|VCU policy or compliance notice|
|Responsible VCU unit(s)||PI / Study staff / Grants and contracts accounting and effort reporting|
At the discretion of Grants and Contracts Accounting and Effort Reporting, a pre-award account may be granted prior to award acceptance. The PI’s department assumes all risk in covering expenditures in advance of receipt of the official award.
|Associated document/form||Request for banner index number|
|VCU policy or compliance notice|
|Responsible VCU unit(s)||PI / Study staff / Grants and Contracts Accounting and Effort Reporting|
Expenditure of funds is not authorized prior to the official start date listed in the award, unless pre-award spending is explicitly allowed. This start date is predicated upon acceptance of all terms of the award by both parties. Effective dates for grants are usually set by the sponsor and specified in the award. Contracts are not as predictable and the start date in some cases may be determined by the date of last signature. The final signatory may be the university or the sponsor, depending on the contract.
|VCU policy or compliance notice||G and C post award financial administration - Pre-award costs|
|Responsible VCU unit(s)||PI / Study staff / Division of Sponsored Programs / Grants and Contracts Accounting and Effort Reporting|
Post award team4
1 Government and nonprofit-sponsored proposals, administrative actions and agreements;
Team assignments by school/college can be found here
2 Industry-sponsored and non-federal clinical trial proposals, administrative actions and agreements
3 Material transfer agreements, data use agreements and confidentiality nondisclosure agreements
4 Award review, processing and distribution (all funding sources), subaward agreements and modifications (when VCU is PTE) and non-financial closeout