i. Definition/Role of the Principal Investigator (PI)
ii. Role of the Sponsored Research (SR) Development Specialist
iii. Role of the Sponsored Research Contract and Compliance (SRCC) Analyst
iv. Role of the Sponsored Research Administration (SRA) Grant Specialist
v. Role of SDSU Administration
A single PI or project director must be identified for every proposal. While there may be any number of “co-investigators,” there must be one individual who is ultimately responsible for conducting the project or program, completing required reports and deliverables, and is the single point of contact for the funding agency and SDSU if the proposal is funded.
In accordance with CSU Executive Order 890, SDSU has defined a PI as a faculty member of the university, an adjunct faculty member or research faculty member. Faculty may or may not have tenure, while adjunct faculty have no additional support from the university other than approval to submit proposals and conduct research utilizing university resources. Research faculty are not tenured.
Some colleges and departments have specific guidelines on PI status; the PI should check with her/his department and/or college to ensure that he/she meets any specific eligibility requirements.
Students submitting proposals must be sponsored by a faculty member who acts as the designated PI. The student may be listed as a co-investigator, but may not be the point of contact for the project.
Some colleges and departments may allow an SDSU staff member to serve as a PI, with the approval of the SDSU vice president for research.
In some circumstances, an SDSU Research Foundation management employee may serve as PI, with the approval of the SDSURF executive director and the SDSU vice president for research.
The PI has responsibility for understanding funding opportunity guidelines when applying for extramural funding. The PI must also comply with university policies regarding the review and approval of proposal submissions. To act as a PI, he/she must meet certain criteria which are outlined in CSU Executive Order 890. The PI must be prepared to perform the activities described in the proposed project if the application is chosen for an award, and to work collaboratively with research foundation post-award and sponsor agency staff to ensure successful administration and progress of the awarded project. If the project includes the use of human/animal subjects, environmental health and safety issues, or requires disclosure of significant financial interests or conflicts of interest, the PI must comply with SDSU policies related to these areas.
The PI has dual responsibility for complying with the financial and administrative policies of the award while achieving the technical success of the project. Even though the PI may have administrative staff to assist in the management of sponsored projects, the ultimate responsibility for the successful completion of the scope of work and the management of research dollars rests with the PI.
In addition to completing the scope of work as prescribed in the funded proposal, the PI must responsibly initiate expenditures on the award, ensure timely submission of expenses for reimbursement, submit required progress reports, and comply with applicable sponsor rules and regulations during the day-to-day operation of the project and when making any changes to the scope of work or funded budget.
The PI will maintain a close working relationship with the sponsored research administration (SRA) grant specialist assigned to manage her/his funds. The PI will also have a good understanding of the procedures associated with initiating financial transactions, making budgetary changes and revising the scope of work. In addition, the PI is responsible for retaining and storing of all programmatic technical materials and reports in accordance with SDSU Research Foundation record retention requirements (see Fund Closeout K).
Satisfactory progress on individual grants and contracts is determined by the funding agency on a project by project basis. Any issues and/or concerns with the performance of a PI regarding adherence to SDSURF policies and procedures will be initially addressed with the PI by sponsored research administration and/or human resources depending on the issue. If the PI is non-responsive or if the response does not result in adherence to research foundation policies and procedures, the situation will be referred to the dean of the college and/or the vice president for research as necessary for assistance and resolution. SDSURF relies upon the university’s evaluation procedure for faculty as the formal process for performance evaluations.
The assigned SR development specialist will work collaboratively with the PI throughout the development, submission, and subsequent award (or declination) of proposals. The development specialist will:
- ensure that the PI follows the guidelines of the funding opportunity;
- develop budgets that are prepared accurately and comply with sponsor, university, and RF requirements;
- ensure that proposals are reviewed and approved appropriately;
- ensure that any additional materials or processes are completed after the proposal has been submitted;
- assist with the transition of the proposal to SR administration if the application is chosen for an award.
The SR development specialist will facilitate the review of compliance materials by the Division of Research Affairs or other designated university departments. If the application is declined by the sponsor, the SR development specialist will assist the PI with resubmission of the proposal if he/she decides to resubmit the application.
The assigned SRCC analyst works collaboratively with the PI, SR development specialist, SR grant specialist and the SDSU Division of Research Affairs in awarding/prioritizing of new projects. This collaborative effort includes ensuring that compliance-related issues such as animal and human subjects, conflicts of interest, financial disclosures, and any other compliance matters are current prior to awarding proposals. Analysts also work in tandem with SR Development, SR Administration and the PI to develop new sub-agreements and amendment documents for sub-recipient entities.
SDSU Research Foundation is committed to assisting PIs in the administration of sponsored research and other activities. SDSU Research Foundation has multiple sponsored research administration offices located both on and off-campus to provide PIs with on-site administrative support. PIs are generally matched with an SRA grant specialist located in the sponsored research administration office closest to their project offices. The assigned grant specialist will typically manage all of the SDSU Research Foundation and The Campanile Foundation funds associated with each PI, allowing the grant specialist to have a better overall picture of a PI’s financial resources and providing PIs with one individual to assist them in the management of their funds.
Throughout a project's duration, the grant specialist establishes and monitors funds, provides PIs with an outline of sponsor regulations, SDSURF policies and procedures and reporting requirements for each fund, and monitors expenditures to ensure compliance with federal regulations, agency specific requirements and SDSU Research Foundation policies and procedures. The grant specialist also provides services related to overall award management including ensuring fiscal reports are submitted in a timely manner, acting as a liaison between the project and the sponsoring agency and interpreting SDSU Research Foundation and sponsor regulations and policies.
SRA grant specialists also conduct "Orientation Meetings" for PIs to provide an overview of SDSU Research Foundation services available to assist them in the startup and management of their projects and/or review the specific requirements of a new award.
All externally funded grants and contracts are awarded to SDSU Research Foundation for the benefit of SDSU. Accordingly, appropriate SDSU Research Foundation officials are required to review and approve proposals before an award can be accepted. Proposals are reviewed and approved using SDSURF’s InfoEd system-to-system software, which includes electronic routing functionality.
The administrators with whom a faculty member must interact during the development and routing process include, at a minimum, her/his dean, who is required to review and approve the proposal. For proposals that include SDSU and/or SDSURF space needs, or require cost sharing, the faculty member’s department head will also need to review and approve the proposal. In addition, the director of the Division of Research Affairs, the university’s officially designated representative for grants and contracts must approve proposals before they are submitted. Although the research foundation obtains this approval for the faculty member, the director of DRA may have substantive questions pertaining to the content of the proposal and may contact the faculty member prior to approving the project. Faculty members will be informed that there is a highly detailed review of all proposals before they are submitted to funding agencies.
Other SDSU administrators become involved as circumstances require. For example, if an interdisciplinary proposal is being submitted, at a minimum, the deans of all proposed project directors must review and approve the proposal. If faculty members from other colleges are serving as co-investigators on projects, these proposals must also be reviewed and approved by respective college deans. Similarly, if the College of Extended Studies will be expected to play a role in the project after it is funded, the CES dean must review and approve the proposal. Other administration officials who may have to review certain proposals include:
- Associate Vice President of Operations, Business and Financial Affairs. This approval is required on proposals that meet the specific criteria below:
- Total grant or contract amount is over $250,000
- Indirect cost recovery rate is less than 25% on grants greater than $100,000
- Cost sharing requirement greater than $20,000 (not including foregone indirect costs) This approval is required before the proposal is submitted in accordance with the memorandum dated March 18, 2015, from Tom McCarron, Vice President for Business and Financial Affairs and CFO to Bob Wolfson, Executive Director, SDSURF, Subject: Grant and Contract Proposal Review Policy, on file with Sponsored Research Development department.
The following administrators may need to review informational proposal reports after submission, depending on what SDSU resources are needed:
- Vice President, Academic Affairs. Review is needed when university resources (staff time, equipment, money) are committed to the project as a match or cost-share.
- Associate Vice President, Facilities Planning and Operations (SDSU). Review is needed when additional university space is requested to conduct a project or if renovation of facilities is contemplated.
- Associate Executive Director, Facilities Management (SDSU Research Foundation). Review is required when new or additional research foundation space will be needed to conduct a project or if renovation of existing research foundation space is necessary. The amount of square footage, if known, should be identified, along with any special requirements the project may have (chemical hood vents, climate control, etc.).
- Institutional Review Board (IRB). The Institutional Review Board must review all projects that intend to use human subjects. Faculty members must submit a protocol to IRB and have the research approved by the board prior to acceptance of an award. Additionally, for National Institutes of Health proposals, faculty and other key personnel must certify that they have been educated on the proper use of human subjects for research projects. Both procedures are conducted independently of the research foundation. Review is required when a proposal includes the use of human subjects.
- Institutional Animal Care and Use Committee (IACUC). Faculty members who intend to use animals in their research projects must submit a protocol to the IACUC. Approval must be obtained before an award can be accepted. The IACUC chairperson (or designee) will review reports of proposals that include the use of animal subjects.
- Conflict of Interest Committee. When the sponsor of a proposed project is a private firm, the faculty member must disclose whether he or she has any financial interest in the firm. This is done on a Form 700-U. The faculty member submits the form to the chair of the Conflict of Interest Committee for review and a determination as to whether a conflict of interest exists. The research foundation is responsible for following up to ensure the Form 700-U has been submitted, reviewed and approved by the Conflict of Interest Committee. 2 CFR Part 200.112, Conflict of Interest requires that all Federal awarding agencies must have policies addressing conflicts of interest. As recipients of federal funding SDSU and SDSU Research Foundation must disclose in writing any potential conflicts of interest and have a policy on conflicts of interest. PIs and any key personnel involved in Federal projects must complete a Financial Disclosure form and submit it to the SRD or SRCC department, which will forward it to the Division of Research Affairs for review and determination of conflict of interest.
- Other Administrators. In some instances, other administrators may have to review a proposal after it has been sent to the sponsor. For example, if radioisotopes, toxics, or biohazards will be used on the project, the faculty member must submit applicable Environmental Health and Safety documents to the environmental safety officer. If diving is part of the project, the diving safety officer must receive certification before the project can begin. If patentable items may result from work performed on the project, the signature of the university’s patent administrator will be needed on the routing form. The university’s technology transfer office is also involved in review of patent and intellectual property concerns. In each of these cases, faculty members should briefly explain on the routing form the nature of their work. Reports are provided to these individuals after submission of the proposal to the sponsor.
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