Approved by: The President
History: Issued              -- September 19, 2005
Revised            -- July 30, 2015
Last Reviewed -- August 1, 2019
Related Policies: Compensation from Sponsored Awards and Effort Certification Policy; Cost Sharing Policy; Cost Transfers Policy; Post-Award Principal Investigator Handbook; Reporting Financial Irregularities Policy; Service Center Policy; Sponsored Award Costing Policy; Sponsored Award Management Policy; Subrecipient Monitoring Policy
Additional References: Office of Sponsored Programs
Responsible Official: Provost tel. (202) 319-5244

 

I. Policy Statement

 

The University is committed to complying with all regulatory and sponsor requirements with respect to Sponsored Awards (defined below). To promote compliance and efficient award administration, all applications or proposals for Sponsored Awards must be processed and coordinated through the University's Office of Sponsored Programs, must be made in the name of the University, and must be approved and/or signed in advance by the Provost or his/her designee. The Principal Investigator (PI) for each Sponsored Award has primary responsibility for all aspects of that award. That responsibility includes financial management, effort reporting, subrecipient monitoring, award closeout, and compliance with all specific award terms and applicable federal Office of Management and Budget (OMB) requirements¹.

II. Definitions

 

A. Contract means an agreement executed by a sponsoring agency requiring the University to perform certain services in exchange for agreed-upon payment terms. The term "contract" is used interchangeably with the terms "grant" and "award" for purposes of sponsored awards.

B. Grant means a financial award to the University, under the oversight of a Principal Investigator, for purposes of research, training or other projects as dictated by the sponsoring organization. The term "grant" is used interchangeably with the terms "contract" and "award" for purposes of this policy

C. Principal Investigator (PI) means the person responsible for performance of the activities specified in the grant or contract. Usually this person is named in the grant or contract agreement.

D. Sponsored Award means a grant, contract or other method of funding provided to the University by an external entity (such as the federal government or a private foundation or company) and for which there are actual or implied conditions or expectations that the University must meet. Such conditions and expectations often include, but are not limited to:

  • Sponsor control of the scope of the project;
  • Technical, financial, or progress reporting; 
  • A cost sharing component;
  • Recoveries for facilities and administrative (i.e. indirect) costs; and/or
  • Re-granting or subcontracting of some of the funds to other entities.
  • Sponsored Awards often involve activities such as research, teaching/training, or the provision of services by University personnel to other entities.

III. Award Management Responsibility

 

While the PI may delegate day-to-day administrative activities for an award, the PI retains primary responsibility for the supervision of all award activity, including financial management, effort reporting, subrecipient monitoring, award closeout, and compliance with all specific award terms and applicable federal OMB requirements¹ as set forth in the following University policies:

___________________________________________

¹ For awards effective December 26, 2014, following OMB Uniform Guidance (2 CFR §200). For awards effective before December 26, 2014, follow OMB Circular A-21, Cost Principles for Educational Institutions (2 CFR §220) and/or OMB Circular A-110 (2 CFR § 215).