PI & OSR Responsibilities

1. OSR Post Award:Roles and Responsibilities of Principal Investigator and Support Services Provided by the Office of Sponsored ResearchCatherine Spaur (cspaur@wcupa.edu, 610.436.3060)Laura Vassallo (lvassallo@wcupa.edu, 610.430.5606)Grants Development SpecialistsOffice of Sponsored Research www.wcupa.edu/research/Filano HallWest Chester University of PAApril 24, 2014

2. PI & OSR Responsibilities Once a grant is awarded, all activities conducted during that grant are referred to as Post-Award. What is the role of the Principal Investigator? • A PI is responsible for the overall conduct of a sponsored project, including all technical, programmatic, financial, compliance and administrative aspects. The PI will ensure that a sponsored project is carried out in compliance with the terms, conditions, and policies of the sponsor and WCU. What is the role of OSR during post-award? • Ensure compliance with federal, state, sponsor, and University regulations • Assist the PI in understanding all terms and conditions of the award. • Consult on specific questions about the management of the grant • Serve as intermediary between the PI and the sponsoring agency.

3. Notice of Award • Grant is not considered awarded until a formal Notice of Award is received from the sponsor. • The notice will include: • Performance period for grant • Awarded budget • Points of contact: Program Officer and Grants Officer • Activities requiring prior approval • Report/deliverable requirements • Special terms and conditions – human subjects, publications, etc.

4. Terms and Conditions of Award • Policies will differ from sponsor to sponsor. A transaction may be legitimate for one grant, but unallowable on another. • WCU and PASSHE regulations are in full compliance with federal law and in fact, may be stricter than the federal government. Therefore, always follow the terms and regulations as listed in this order: • Notice of Award Terms • University and PASSHE Policies & Procedures • Sponsor Policies • Federal Policies • OSR will conduct a post-award meeting with the PI at the time of award. This meeting is an opportunity to discuss the terms of the award and any concerns the PI may have.

5. Records Management • Maintain all documentation and data used in the project for at least 3 years from the date of project close-out. • Records may include: schedules, correspondence, meeting documentation, financial, personnel, lab notes, expense receipts and computer files. • If questions of research misconduct arise, the documentation will help demonstrate appropriate conduct. • The PI may rely on notes to complete progress reports and effort reports. • These records will also be made available to external auditors for review. 

6. Regulatory Requirements • PI must receive and provide training to staff and student participants on the grant in the ethical and responsible conduct of research. • In the near future, all WCU employees and students will have access to the Collaborative Institutional Training Initiative (CITI). This comprehensive course is designed to fulfill the Federal Government agencies requirements for formal training in the responsible conduct of research. • Ensure compliance with all IRB regulatory requirements (e.g., human subjects, use of animals, biohazards, workplace health and safety requirements). • For more information go to: http://www.wcupa.edu/research/formsAndPoliciesIRB.asp

7. Personnel Hires, Consultants and Subawards • Follow WCU guidelines in hiring student workers and staff. • Consultants:   All University purchases greater than $18,900 must be competitively bid by Business Services. • Do not make commitments for services/consultants prior to receiving required WCU approval.   • OSR will develop subaward agreements with the subaward institution. • The PI is responsible for ensuring that the consultant and/or subawardee perform as detailed in the final agreement.

8. Effort Reporting • Effort reporting is the federally-mandated process by which the salary charged to a sponsored project is certified as being reasonable in relation to the effort expended on that project. • Applies to all WCU employees and student workers who receive compensation through an externally sponsored project. • Effort is not based on a 40-hour workweek, nor is it based on full time equivalent. Effort is expressed as a percentage of the total amount of time spent on work-related activities (instruction, research, patient care, administration, etc.) for which the University compensates an individual. • WCU collects effort reports three times a year. These reports are not given to the sponsor. They are internally maintained for auditing purposes.

9. Sponsor ReportingRequirements • The Notice of Award will dictate what reports and/or deliverables are required. Due dates will be listed in the Notice of Award. • Federal agencies monitor report schedules and will bring overdue reports to the University's attention. For example, NSF sends emails to the Provost when a PI is late in submitting a report. • Delayed reports may impact the PI and even WCU; a pending proposal may not be reviewed until delinquent reports are submitted, or, in an extreme case, the PI may be barred from future support. • Please share electronics copies of all reports and deliverables with OSR.

10. Travel & Export Control • Before travel, ensure that travel is allowable under grant terms. • The PI should manage travel activities, expenditures, records and reimbursements as outlined in WCU’s travel policy. International travel must be approved in advance. • US Export Control Laws restrict the transfer of certain materials (including university owned laptops), technology, related technical data and certain services to internationals and outside the US. • Guidance is available at the International Programs website: www.wcupa.edu/international/travelforms/

11. Prior Approval • Grants do not always progress as planned and changes in the project may have to be made. Before making any changes, please check with OSR for sponsor prior approval. • What usually requires prior approval: • Change in objectives or scope of work • Change in PI or co-PI and key personnel • Change in PI or co-PI level of effort • Contracting or transferring significant part of research • Adjustments to cost sharing commitments • Reallocation of budget • Extension of grant performance period • If you need to change something in your project and are unsure if prior approval is required – ask OSR

12. No Cost Extension (NCE) • If you cannot complete the project on time, please contact OSR at least 60 days before the end of your grant period. • A no-cost extension may be requested from the funder. A NCE means that no additional funds will be required from the funder, the scope of work will remain the same and the project period will be extended to allow completion of all deliverables. • Be prepared to discuss: • Why the extension is requested • How much of the award funding remains, why and how will it be spent during the NCE • What will be accomplished in the extended period with the remaining funds

13. Project Close Out • PI submit final technical report as dictated in the Notice of Award. • Final Invention or Patent Report: PI certify whether or not an invention has been made during the course of the project. • Final Property Report: Final inventory of equipment purchased, fabricated or furnished by the sponsor during the period of the project. • Final Financial Report: This report will be generated and submitted by Restricted Funds

14. Non-compliance Consequences • Disallowance of charges • Reduction in award amounts • Withholding of payments • Withholding of awards (for an individual PI or the entire institution) • Suspension and debarment (for an individual PI or the entire Institution) • Prosecution under the False Claims Act