The principal investigator or project director (PI/PD) has overall responsibility for the conduct of the project described in the grant proposal. The associate comptroller and director of faculty grants provide help, but the PI/PD is expected to conduct all work in a responsible and ethical manner, to comply with the funding agency’s guidelines for expenditures and reporting, and to keep the College and the funding agency informed of any significant changes in the project.

When a grant is received, the director of faculty grants will send a copy of the grant letter and any budget information to Carol Kessel, Associate Comptroller. In the event that a PI/PD receives direct notification from the funding agency, copies of the grant letter and any other materials from the funder should be sent to both the director of faculty grants and the associate comptroller.

The associate comptroller will set up an account for the grant funds and inform the project director of the number. Budget line items will be designated according to the lines in the final approved grant budget. Principal investigators/project directors authorize expenditures against the grant budget and oversee the proper use of grant funds by all personnel involved in the project. The associate comptroller provides quarterly reports of the grant budget by line item to the PI/PD, who reconciles the report against his or her own record of authorized expenditures.

The Comptroller’s Office has overall responsibility for maintaining the financial records on the grant. These include posting charges, providing reports to the project director, and filing regular reports on the grant with federal agencies and requesting grant payments from those agencies. Additional responsibilities include:

• Complying with audit requirements – Federally funded projects are subject to an annual audit by the College’s auditors. In addition, federal agencies reserve the right to conduct their own audit of any project they fund. Grants from private funding agencies are audited as part of the College’s annual audit.
• Maintaining equipment inventory – The associate comptroller keeps records on all equipment purchased with federal funds for inclusion in a required annual inventory.
• Negotiating the facilities & administration (F&A) rate with federal agency representatives.
• The responsibilities of the principal investigator/project director include:
• Regular and timely reports – Most funding agencies require progress reports at least annually. Note that some federal funders, such as NSF, require that the reports be filed 90 days in advance of the anniversary date. Final reports must be filed within 90 days after the conclusion of the grant period.
• Adherence to funding conditions – It is assumed that all faculty members will comply completely with the conditions of the grants awarded, and that all disbursements will be made for the purposes and conditions of the awards. The College signs statements annually verifying the accuracy of the compliances.
  
  Important note: On projects funded by any agency of the U.S. Government, goods and services may not be purchased from any entity that is excluded from receiving federal funds through contracts, subcontracts, and certain other forms of financial assistance. Before committing to any purchases under federal grants, the project director/principal investigator must consult the Excluded Parties Listing System at http://www.epls.gov/ to ascertain that the prospective vendor has not been debarred. For further questions about this compliance, contact the associate comptroller or the director of faculty grants.
• Documenting expenditures – The federal government has been conducting an increasing number of audits in order to diminish the number of grant fraud cases. It is essential, therefore, that faculty members document all expenses.
• Responsible and ethical conduct of research – Faculty members must comply with the College’s Policy and Procedures for Review of Alleged Unethical Research Practices () as well as the Conflict of Interest Policy Pertaining to Sponsored Projects (). The Conflict of Interest Policy Faculty Disclosure Statement () must be completed annually.

Other Grant Administration Issues

Overhead return: If a grant is approved with the full amount of F&A (indirect costs) requested, 20% of the recovered indirect cost will be placed in a separate, restricted fund for the principal investigator/project director to use for his or her own research, travel, equipment, etc., but not for his or her salary. The associate comptroller will assign the account number and inform the PI/PD.

Personnel funded by grants: See also “Information for Budget Preparation.” Hiring personnel for grant-funded position must follow normal College procedures with respect to advertising, recruiting, offers of employment, rate of pay, etc. Refer to the Trinity College Handbook for Administrative Staff. The appointment letter for administrative staff hired for grant-funded positions may not be issued by faculty. Letters of appointment are issued by the Director of Human Resources, the President, or the Dean of the Faculty, depending upon the nature of the assignment.

Supplemental grants: If the funding agency makes supplemental grants—as NSF does to support student assistants in ongoing research projects—the application for such support should go through the institutional approval process described in the previous section.

Budget changes: Most funding agencies will permit some budget adjustments among approved categories, if approval is requested in advance. Certain federal agencies, e.g., NSF and NIH, have guidelines in place that permit a grantee institution to transfer grant funds from one category to another within limits without prior agency approval. Project directors should discuss any anticipated budget changes with the associate comptroller as soon as possible.

No-cost extensions: Extensions in the project period that do not involve additional funds are called no-cost extensions. They are usually necessary when work on the project takes longer than anticipated—not simply because grant funds remain at the end of the original project period. Most federal funding agencies provide up to a year’s extension as a routine matter, but require review and approval of subsequent extensions. Contact the director of faculty grants and the associate comptroller as soon as possible, because extension requests may be subject to deadlines.

Change of principal investigator or PI’s level of effort and Changes in objectives or scope of the project: A change of either type will require the advance approval of the funding agency. The principal investigator should discuss plans with the director of faculty grants as soon as possible.

Grant transfers: When a principal investigator leaves Trinity with substantial time and money remaining in a funded research project, in most cases transferring the grant to the new institution is the appropriate course. Contact the director of faculty grants and the associate comptroller as soon as possible; transfers may take some time to complete.