1. Role of the Principal Investigator (PI)
Authority and Responsibility: As the Sponsored Programs Administrator for CSUEB, the Foundation has the legal responsibility and authority for running the grant and expending grant funds. The Foundation in turn grants to certain faculty and MPP’s the authority to act as the Foundation’s Principal Investigator (“PI”) of a sponsored program. The primary responsibility of the Principal Investigator is to ensure sponsored program success. The success of the program is measured not only by the intellectual merit of the research or the technical results, it is also measured by our commitment to judiciously manage award funds and deliver on all obligations in accordance with the award. The authority granted by the Foundation to the PI is inextricably tied to the responsibility of conducting the grant in accordance with the approved proposal and budget as well as the all other guiding policies and regulations.
Who can be PI: One Principal Investigator is named to each sponsored program. If there is a strategic need for an Co-Investigator, that can also be added. Only one PI is appointed to each program to ensure clear lines of accountability and authority. Only CSUEB faculty or MPP’s in good standing may be Foundation Principal Investigators. The status of "good standing" is accorded to individuals who have not been cited for serious violations of Foundation or University regulations and policies.
Difference between a Principal Investigator, Project Director, and Project Coordinator?
The role of PI and PD are interchangeable and should be the same person. It can sometimes be confusing when grants had two different people as PI and PD as some sponsors view the PD as the primary individual running the program. Therefore, when additional management is needed on a grant, we do not use the term PD, but rather Project Coordinator (defined below).
Employee or Partner? Under CSU Executive Order 890, the Foundation “shall be the employer of the Principal Investigator and other employees with regard to work performed in furtherance of each Sponsored Program….[t]his applies regardless of whether the employee is being paid directly by the University or Auxiliary [the Foundation]”.
While EO 890 classifies a PI as a Foundation employee, we feel the relationship is more of a partner with the Foundation., The Foundation prefers whenever possible to operate as partners with Principal Investigators to run sponsored research and programs. The partnership model is possible when both partners are working collaboratively toward fulfilling our collective responsibilities to the sponsor, something both the PI and the Foundation have a vested interest in fulfilling.
Some projects are of the size and scope such that there requires additional project management in addition to the PI. In these cases, a Project Coordinator can be built into the project to assist the PI with project management. Another faculty or MPP may be appointed as the PC, or an employee hired by the foundation to fill that role. The PC is often the individual responsible for running the sponsored program on a day-to-day basis. However, the PI is ultimately the individual responsible for project performance. The PC reports directly to the Principal Investigator and is eligible to receive purchasing authority.
Only one faculty or MPP may act as the Principal Investigator for a sponsored program because of the need for clear lines of authority and responsibility. All other CSUEB faculty or MPP-level individuals with a substantive technical role in the program may be named as co-investigators. Co-Investigators may also act as the Project Coordinator if it does not conflict with their other responsibilities.
There are two kinds of signature authority: Program Authority and Purchasing Authority.
Program Authority: Only Principal Investigators may receive program authority for their sponsored program. This authorization enables the PI to approve requests for personnel actions, rebudgeting, and changes in project scope. Program authority is also required for submission of any official reports or requests to the program sponsor if the report or request needs to be certified by the university program official. The institutional official is the Foundation.
Purchasing Authority: Only PI/PD’s, co-investigators, and project coordinators may receive purchasing authority for their sponsored program. This authorization enables an individual to initiate and authorize expenditures against sponsored program funds. As Sponsored Program Administrator, the Foundation is the final approver of all program expenditures.
Training & Certification: Receipt of purchasing authority is contingent upon any training or certification required by the Foundation. This training and certification will cover sponsor and Foundation requirements that must be understood prior to spending program funds. Anyone granted purchasing authority has a fiduciary duty to the Foundation to spend the money solely for the benefit of the program and not for the personal benefit of others.
Limits to Purchasing Authority: The purchasing authority conferred is subject to all Foundation purchasing requirements and procedures. These requirements and procedures are established to ensure compliance with various sponsor, state, and federal rules and regulations concerning prudent and responsible use of program funds. For example, federal and state rules require that Foundation purchasing procedures provide for competition and cost & price analysis for certain purchases/contracts. An individual has no authority to purchase, or authorize others to purchase, unless all required forms and procedures are completed and followed as set forth in Section 4 (The Rules on Spending) below.
Principal Investigators are responsible for monitoring the expenditures of their programs to ensure budget compliance. Budget compliance requires that: 1) individual line items of cost are not exceeded if specific amounts are set by the sponsor, and 2) the total overall budget is not exceeded. The Foundation will enter the approved budget in the Foundation accounting system. The PI should monitor his/her actual and planned spending closely on a spreadsheet and on a regular basis, cross-check against the expenditures and balances on the program’s PeopleSoft spending account. Because it is the PI, not the Foundation, who commits all expenditures and personnel assignments, budget overruns are the responsibility of the PI and his/her college.
Access to PeopleSoft: The PeopleSoft financial reporting system provides information on program expenditures which have been paid by the Foundation. Using PeopleSoft, PI/PDs are able to run financial reports which summarize such expenditures. This is an essential tool for PIs to use in tracking and planning expenditures against their approved program budget.
As explained in Section 2 of the SPG, upon receipt of the Grant/Contract Approval Form, the Foundation Grant Analyst will submit a request to University IT to give the PI/PD access to the PeopleSoft system. University IT will email the access information to the PI/PD directly. The PI/PD will have to send an email request to the Foundation Grants Analyst if an admin staff or budget analyst should need access to their program financials. The Foundation will provide guidance to the PI with regard to access/use of the PeopleSoft system. Any PI needing assistance with this should call and make an appointment with the Foundation Grants Analyst.
Staff: The PI is the official supervisor of program staff, with responsibility to manage their activities. The PI must work with Human Resources anytime there is a need to hire, discipline, or terminate any employee. It is critical none of these actions take place prior to the involvement and approval of Human Resources due to the sensitive nature of these activities. Please refer to Foundation HR for more information on PI/PD roles and responsibilities regarding staff.
Contractors: “Contractors” include subcontractors, consultants, independent contractors, and vendors. The PI/PD’s role over contractors is to act as the technical representative of the Foundation. This means PI and PD are responsible for the technical direction and monitoring of all contractors paid by the sponsored program. Part of these responsibilities includes closely tracking contractor activities to ensure required timelines and deliverables are met. The PI or PD is also responsible for reviewing and approving invoices from contractors. The signature of the PI or PD on the Check Request Form certifies that the goods or services have been satisfactorily received or rendered; the amount charged is reasonable and correct; and the cost is appropriately chargeable to the fund indicated.
The Foundation should be immediately notified of any contractors who fail, or refuse to meet the requirements of their contractor agreement. The PI/PD is not authorized to execute any new agreements or make any changes to existing contractor agreements. All changes of work plans, deliverables, or budgets must be requested through Foundation SRP.
The PI is responsible for the production and delivery of all reports and deliverables required by the award. It is the PI’s responsibility to review the award for all requirements related to reports and deliverables, ensure that all reports and deliverables are completed, and deliver such reports and deliverables to the sponsor prior to applicable award deadlines. The Project Coordinator may help prepare all the required reports and deliverables, but it is the responsibility of the Principal Investigator to review and approve all reports and deliverables prior to delivery to the sponsor. Any signatures required by the Institution/Organization/Company official should be directed to the Foundation.
Notwithstanding the foregoing, the PI may request the Foundation’s assistance in preparing any official financial reports specified in the award. All other reports remain the responsibility of the Principal Investigator. Copies of all annual and final reports along with proof of delivery should be forwarded to Foundation SRP (electronic copies and PDFs are acceptable) for the official grant file.
Time and Effort Certification: Pursuant to CSUEB Written Policy Section 3.3, all sponsored program employees who are paid directly by University payroll must complete and sign a Time and Effort certification every quarter. It is the PI’s responsibility to ensure that he/she and all program staff on University payroll complete, sign and submit the form to the Foundation by the following dates:
|Fall Quarter||Due January 15|
|Winter Quarter||Due April 15|
|Spring Quarter||Due June 30|
|Summer Quarter||Due September 15|
CSU Overload Policy: The University has set forth an Additional Employment Policy which “establishes reasonable limits on the total amount of employment an individual may have within the CSU system.” Since the Foundation is an auxiliary of the CSU system, employment with the Foundation (including release and overload) counts towards total CSU employment. The current maximum is 125% time-base.
Complying with the 125% Rule: The PI is responsible to inform their Dean of all load they receive on grants/contracts to ensure Academic Affairs is aware of all assignments to ensure the maximum 125% time-base is not exceeded. Faculty and staff are to inform their PI of all load they receive from both the University and Foundation grants/contracts to ensure the maximum 125% time-base is not exceeded. Since this is a policy enforced and administered by CSUEB, please contact CSUEB Academic Affairs for additional guidance or help with compliance.
One of the most important roles of the PI is to ensure the safe and responsible conduct of sponsored programs. The PI should not authorize any activities that present an unreasonable risk of injury or harm to life or property. Furthermore, the PI is responsible for communicating any elements of risk that may be present in activities required by the sponsored program to all potential participants.
The PI is also responsible for ensuring compliance with all rules and regulations concerning staff, participant, human subject, animal, and environmental safety. Adherence to IRB guidelines, research or lab protocols, and any other requirements established by the sponsor, Foundation, or University must be strictly implemented and continually monitored for staff compliance by the PI.
Human Subject Program Participants: All researchers using human subjects doing non-exempt research are required to pass an online research training course. This includes not only the principal investigator but also all co-investigators, research technicians, research assistants, or student assistant who have contact with the research subjects. Programs with human subjects must obtain IRB approval and require all participants to sign an informed consent form prior to participation in the program. Further information on human subject research requirements can be obtained from the CSUEB Office of Research and Sponsored Programs which handles IRB and human subject matters.
Contact with Minors: All program staff who will have contact with minors during program activities must submit to and pass fingerprinting and background checks. Staff will also need to have current tuberculosis immunization shots and be certified TB-negative. These are strict state requirements prior to contact with any minors. Contact Foundation Human Resources to learn the steps to gain the necessary clearances.
Participant Travel and Off-Site Activities: Programs which require participants to travel or engage in off-site activities outside the office or classroom must obtain Foundation approval prior to the proposed travel or activity by submitting a Participant Travel & Special Events Form. The form should be submitted at least two weeks prior to the requested travel or special event.Special event insurance may need to be purchased (this will be a direct cost to the program) and if so, the proposed activity must not occur until the insurance is in place. If approved by the Foundation, the program must have all participants sign the Foundation Waiver of Liability prior to allowing participation in the travel or activity. It is possible for some programs that both the Informed Consent and Foundation Waiver of Liability will be required.
Use of Equipment: Equipment purchased from project funds may only be used for authorized sponsored program purposes. Equipment purchased with federal funds or furnished by the federal government are subject to additional requirements as set forth in OMB A-110 Section 34.
Equipment Tagging and Audits: On delivery of new equipment or theft sensitive items, the PI should arrange with the Foundation for the equipment to be tagged with a numerical identification sticker. This identification, with a description of the item and its location, is entered in the property inventory records maintained by the Foundation. Annual equipment inventories are conducted by the Foundation. An Equipment Inventory Control Form is sent to the PI who enters information about the equipment's current location, usage and condition and returns the form to the Foundation.
Moving, Damaging, or Losing Equipment: Inventoried equipment is assigned to a specific worksite location. Prior approval is required before moving inventoried equipment to another campus site or off campus or disposing of it in any manner. A Request to Borrow Equipment must be approved by the Foundation prior to removing equipment from its assigned worksite. The PI must immediately report to the Foundation all instances of damage, destruction of, or theft of inventoried equipment. In the case of theft, a police report must be sent to the Foundation along with a written account of the circumstances.
Equipment Maintenance: The PI is responsible for establishing equipment maintenance procedures based on manuals and instructions furnished by manufacturers. In the absence of such instructions, the PI should establish a reasonable maintenance program based on experience and judgment.