Sponsored Program Compliance
7. PI Responsibilities in the University Sign-Off Process
Routing, Approval and Certification
Even prior to submitting a proposal for sponsored funding, the PI has defined responsibilities during the University "sign-off" process. While the sign-off (i.e., routing) process may be viewed as cumbersome, especially during that 11th hour when a deadline looms, it is a critical and necessary step. It is during this process that the University and PI are assured that:
- The proposal is in line with the University's mission and objectives;
- Appropriate personnel and facilities are available to carry out the project;
- All reasonable and allowable costs have been included, and the proposal adheres to sponsor proposal guidelines;
- All policy and compliance issues have been addressed.
The Proposal Sign-Off Form is the University's internal review form that authorizes proposal submission. Specific signatures on this form signify that the proposal has been reviewed for certain considerations, such as obligations of space and/or personnel. Sign-off requirements vary with each School/College; consult the ORPA Guide on Submission of Sponsored Project Proposals or the relevant Dean's Office.
Regardless of the School/College requirements, the PI's responsibilities during the sign-off process remain constant. It goes without saying that the PI maintains the responsibility for preparing the scientific proposal and budget, and obtaining the required and appropriate approvals as dictated by Department, School and University policy. What is often not recognized is the responsibility of assuring and certifying to various conditions on the Sign-Off Form. Some of the certifications on the Sign-Off Form are required by law; falsely certifying may invoke civil or criminal penalties.
Of particular note:
- Conflict of Interest: All investigators (key individuals responsible for the administration, design, conduct and reporting) are required to make an annual disclosure to their Dean of outside remunerative and other activities related to their teaching, research and administrative responsibilities. This disclosure is required when a significant financial interest related to that proposal exists. For certain federal agencies, it is a requirement that such disclosures are submitted in advance of proposal submission.
- Debarment and Suspension: This regulation requires that applicants for federal funds certify that neither they nor their researchers are debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from covered transactions (e.g., grants and contracts) by any federal agency.
There are other certifications on the Sign-Off Form such as the adherence to federal lobbying requirements. A full description of the meaning and significance of these certifications can be found in the ORPA Manual (currently under revision). Falsely certifying may invoke action against the PI and key personnel not only by the involved federal agency, but by the University. PI's are to take sign-off requirements seriously.
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