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Roles & Responsibilities
University of Rochester Principal Investigator
The Principal Investigator is the primary individual in charge
of a research grant, cooperative agreement, training or public
service project, contract, or other sponsored project. The Principal
Investigator reports to a Chair, Unit Chief or Director (or other
designated official) and is responsible for adequately communicating
to his/her Department/Unit Head and Department Administrative Staff
on all aspects of his/her sponsored programs portfolio.
PROPOSAL PREPARATION AND SUBMISSION
General
The Principal Investigator confirms that the entire proposal
meets requirements outlined in the Program Announcement, Request
for Application, Request for Proposal, or other application instructions.
Requirement examples include dollar limits, page limitations, font
or electronic file type and size, deadlines, and mailing addresses.
The Principal Investigator may delegate this responsibility to
Departmental Administrative Staff. If the Principal Investigator’s
unit lacks Departmental Administrative Staff for proposal preparation
or other sponsored programs administration requirements, he/she
assumes these responsibilities or seeks support from the respective
Department/Unit Head or Dean.
Technical Proposal
The Principal Investigator:
- prepares the technical proposal and may collaborate with others
in its preparation.
- identifies the need for subrecipient agreements.
- if on- or off-campus space in addition to that already assigned
to the Principal Investigator is needed, the Principal Investigator
identifies the need and requests it from her or his supervisor
and other appropriate University manager.
- is responsible for keeping his/her CV
or biosketch updated, with the assistance of departmental administrative
staff.
- procedures used are consistent with sound
research design and do not unnecessarily expose subjects
to risk/harm.
- design is appropriate to the proposed question.
- reasonably expected to result in important
knowledge.
Proposal Budget The Principal Investigator:
- prepares or directly supervises the preparation of the budget
and its justification.
- selects the appropriate facilities and
administrative rate from the negotiated and clinical
trial rates, under guidance from ORPA and/or the Dean’s
Office.
- obtains a facilities and administrative
cost waiver from the Dean’s Office, if appropriate;
- requests matching funds or identifies in-kind contributions
from appropriate University officials, when necessary or appropriate.
- proposes cost sharing through contributed effort or other approved
mechanisms and seeks
approval
from appropriate University officials.
- identifies shared facilities and administration cost recovery
if faculty from other schools/colleges are significantly involved
and seeks approval from appropriate University officials.
- identifies all available financial resources
in direct support of this or other research endeavors (other
support) either at proposal submission or “Just In Time” in
accordance with sponsor requirements.
- identifies anticipated program income.
Regulatory Requirements
The Principal Investigator:
- prepares the appropriate forms (either
at proposal submission time or “Just In Time” in accordance with sponsor
requirements) from the Research Subjects Review Board (RSRB)
or the Western Institutional Review Board (WIRB) or UR Privacy
Board, the University Committee on Animal Resources (UCAR), the
Radiation Safety Office and/or the Office of Environmental Health
and Safety (EH&S), if the proposal involves:
- human subjects;
- live animals as subjects;
- recombinant DNA, infectious agents, narcotics or biological
toxins;
- human blood or body fluids;
- radioactive materials and/or ionizing or nonionizing radiation-producing
equipment; or
- hazardous materials
- Protected Health Information (PHI).
- if necessary, obtains additional collegiate or departmental
approvals, for example Cancer Center Protocol Review or General
Clinical Research Center Review.
- completes an Intellectual Property Agreement (IPA) prior to
conducting sponsored research.
- if a potentially significant conflict of interest situation
exists, the Principal Investigator prepares a Conflict Disclosure
Form and submits it to his/her supervisor and Dean.
- affirms that he/she is not excluded or debarred from receiving
Federal funds, and is not delinquent in student loans.
- ensures
that other investigators involved in the project sign the University
Proposal Sign-Off Form.
Proposal Routing Form
The Principal Investigator:
- prepares, or directly supervises the preparation of, the University
Proposal Sign-Off Form. (The Principal Investigator must be the
person who checks the boxes on the sign-off; this responsibility
may not be delegated.)
- if other departments or schools/colleges are involved, the
Principal Investigator provides this information, and ensures
the appropriate signatures are included in the University Proposal
Sign-Off Form approval. The Principal Investigator may delegate
responsibility for obtaining other necessary signatures on the
Sign-Off Form.
- signs the University Proposal Sign-Off Form. This responsibility
cannot be delegated and the signature certifies that each item
on the form is filled-out completely and accurately.
- works with Purchasing Services and Departmental Administrative
Staff to develop a small business contracting plan, if necessary.
ACCEPTANCE OF AWARD
Preaward
The Principal Investigator requests contingent accounts, if necessary.
The Department/Unit Head will authorize and approve the contingent
account. (Department Administrative Staff should be cognizant of
the need/use for contingent accounts to minimize cost transfers
and/or reallocations.)
Negotiations with Sponsor
The Principal Investigator:
- negotiates and approves the project work scope.
- in collaboration with Department Administrative Staff and the
Office of Research and Project Administration (ORPA), the Principal
Investigator modifies the project budget in line with the award
budget provided by the sponsor. (Department Administrative Staff
should be involved in any budget modification, as this can impact
other budgeting and effort issues on other projects or departmental
accounts.)
- notifies the Department/Unit Head and ORPA about the changes
in project scope and budget.
- notifies the appropriate regulatory office if changes to project
scope will affect approved protocols.
- obtains approvals if cost sharing becomes necessary.
Acceptance
of Award
The Principal Investigator reviews the internal Notice of Award
(NOA) that stipulates the approved budget and the terms and conditions
of the award, and further delegates to Departmental Administrative
Staff the review of the NOA for accuracy.
CONDUCT AND MANAGEMENT OF THE PROJECT
General
Principal Investigators should reference the Faculty Sponsored
Compliance web site (http://www.rochester.edu/orpa/resource) or
contact appropriate university offices to obtain information about
rules and requirements governing sponsored funding. Principal Investigators
are responsible for knowing what actions require sponsor approval
and for obtaining that approval with involvement from ORPA.
Individual faculty - as principal investigators, research directors,
and mentors - encourage their students and other research personnel
to participate in educational programs on the responsible conduct
of research or research ethics.
Implementing a Small Business Plan (if required)
The Principal Investigator:
- directs purchases that are consistent with the project budget
and the approved Small Business Plan (if required).
- or his/her delegate interacts with Purchasing Services staff
regarding progress toward achievement of Small Business Plan
goals and reviews periodic reports about goals.
- provides an explanation when small business plan goals are
not achieved.
Conduct of the Research
The Principal Investigator:
- is responsible for all actions required to manage and complete
the scientific and programmatic aspects of the sponsored project.
- initiates programmatic changes to the project and seeks approval
from the sponsor when required.
- initiates the hiring or assignment process and approves the
selection or appointment of individuals to the project, and is
responsible for communicating staff changes to Departmental Administrative
Staff.
- ensures the integrity and safeguarding of notebooks and scientific
data.
- ensures the completion, accuracy and timeliness of interim
programmatic (technical) reports.
- initiates and requests subrecipient agreements prepared by
ORPA.
- ensures the quality, timeliness, and programmatic (technical)
performance of subrecipients.
- if using or providing biological materials to or from another
source, initiates a materials transfer agreement with the Office
of Technology Transfer.
Budget Management (while the Principal
Investigator retains primary responsibility for financial accountability,
the Principal Investigator or the Department/Unit Head can delegate
an authorized representative to act on his or her behalf for account/project
management. In any event, accounts must be managed by persons trained
in these responsibilities.)
The Principal Investigator:
- initiates purchases.
- at the time expenditures are requested, determines the allowability
and reasonableness of all expenditures, approves them, and provides
scientific justification for the transaction, if necessary. In
both budgeting and charging of expenses, the Principal Investigator
adheres to Cost Accounting Standards, such as consistency in
allocating costs.
- initiates the process of documenting cost sharing and/or matching
and for ensuring that cost sharing obligations are met, allowable
and verifiable, including those by third party collaborators.
- initiates requests for rebudgeting as the sponsor requires.
- initiates cost transfer requests; when salary transfer requests
are made these are based on reflected effort and not budget (per
OMB Circular A-21).
- identifies and proposes a resolution of any account deficit.
- approves payments of subrecipient invoices and reviews invoices
for appropriateness within progress of the work scope.
- uses ledger and/or departmentally-prepared reports for financial
monitoring, identifies and resolves errors in the account in
a timely manner, and certifies or documents a monthly review
of ledgers. (A suggested format is located on the Finance/ORACS
web site.)
- if appropriate and required at budget period end, the Principal
Investigator requests that remaining balances are carried forward.
Program Income
The Principal Investigator:
- understands the definition of program income.
- identifies all program income and notifies ORPA when program
is identified.
- initiates the processes and proposes the allocation of program
income.
- monitors receipt of program income.
- reviews program income reported to the sponsor by the Office
of Research Accounting and Costing Standards (ORACS).
Effort Reporting
To ensure compliance with the effort reporting (Plan Confirmation)
policy, Principal Investigators sign and certify to all personnel
action forms (800, 510, 610, 710).
Inventions
The Principal Investigator:
- adheres to the principles and policies
outlined in the University’s
Intellectual Property Policy and the Faculty Conflict of
Interest Policy.
- initiates the disclosure process and completes the Invention
Disclosure Form in order to notify the Office of Technology Transfer
.
- assists in preparing patent applications.
- assists in the processing of copyright registration or other
intellectual property protection.
Project Closure
The Principal Investigator:
- prepares the final programmatic (technical) narrative report,
which may include contributions by subrecipients or collaborators.
- reviews final financial statements or reports provided by ORACS
or Departmental Administrative Staff and submits, via Departmental
Administrative Staff, close out documentation in order for ORACS
to submit financial status reports on a timely basis.
- provides information on other close out reports, such as for
patents (to ORPA) and on equipment (to Property Accounting).
- retains the scientific data in accordance
with the University’s
(Interim) Policy on Access and Retention of Data.
Regulatory Compliance
The Principal Investigator:
- if a potentially significant conflict of interest situation
exists, prepares a Conflict Disclosure Form in order to notify
her or his supervisor and Dean.
- is responsible for adhering to all educational and training
requirements of the RSRB and UCAR.
- adheres to research subjects protocols and policies, and notifies
the RSRB if changes are made to protocols.
- meets continuing RSRB protocol review requirements and assists
with inspections.
- adheres to chemical, biological, physical and radiation safety
requirements, and notifies the appropriate office if accidents
occur.
- adheres to the policies and procedures for using investigational
new drugs and/or devices for clinical research.
- will participate in the annual cost sharing certification (if
applicable),the periodic space and equipment survey.
- is responsible for adherence to record retention policy for
all financial and scientific documentation.
- is responsible for cooperating in the audit process, whether
internal or external audit staff is involved.
- is responsible for accounting of PHI disclosures, as required
by HIPAA.
- is responsible for understanding and compliance with all institutional
and sponsor policies, practices, and procedures.
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