SPONSORED PROGRAMS COMPLIANCE
Patterns: Fast or Slow?
The PI has overall responsibility for both the technical and fiscal management
of his or her sponsored projects. This includes the management of the project
within the established budget, and assurance that the sponsor will be notified
when significant conditions related to the project change.
The sponsor also has an interest in seeing that projects are managed reasonably
in conformance with the established budget. Sponsors can and do recall
funding in situations where EITHER funds are being used too quickly OR
funds are not being used quickly enough.
Here are some scenarios, loosely adapted from reality:
The overdraft that ate Cleveland
A PI realized, as her project progressed, that she could reasonably
expand the scope of work in a new direction. Although she did not have
the funds to support this extension of the work, she discussed the situation
with the project Technical Monitor and began taking steps in the new
direction. The Technical Monitor was encouraging, but could not promise
Realizing that this new work might not be funded by the sponsor, the
PI sought and obtained additional gift support for her lab with the assistance
of the university's development office. She set those funds aside to
support the new work in the event that the sponsor did not provide the
While waiting to hear whether or not additional sponsored funds would
be provided, the spending on the project accelerated to a level that
would have produced a seven-figure overrun. At this point, the sponsor's
Administrative Officer (Grant/Contract Officer) became aware of the situation,
and questioned the allowability, allocability and reasonableness of the
expenses being charged.
Although this situation was ultimately resolved satisfactorily, it created
a serious problem for both the university and for the PI - a problem
that might have been avoided with better communication with the sponsor,
and closer monitoring of project expenditures to avoid the monster-sized
The great salamander migration
A multi-year project was designed to study the migration patterns of
a particular salamander. Much of the field and experimental work had
to be done during the time of year when salamanders are particularly
active, i.e., during the rainy seasons.
As she sometimes does, Mother Nature interfered with the PI's project
plans (and budget). A significant drought delayed the salamander's migratory
behavior, and made it impossible to conduct the work as scheduled.
At the end of the first year of the project, there was a large unexpended
balance in the project's accounts, causing the sponsor to wonder what
was happening. Upon an explanation of the circumstances, the sponsor
agreed to carry over the unexpended funds for the continuation of the
In this case, the Technical Monitor was well aware
of the reason for the large unexpended balance of project funds. The
Contract Monitor, however, had to authorize the carry-over of project
funds. Without proper communication, those "carry over" funds
could easily have been recalled.