Award and Project Management - Office of Research

Principal Investigator(s)' Responsibilities

The Principal Investigator’s most important responsibility is to pursue and complete the research, training, or public service described by the funded proposal within the specified time frame. The award document will outline the rules and guidelines that govern the project and specify the required technical and financial reporting. The Principal Investigator(s) must understand the award agreement and execute the work under these guidelines. The PI is also responsible for the programmatic direction of the research project and for initial authorization of all expenditures charged to the award budget. The Principal Investigator is ultimately responsible for making prudent use of the award by ensuring that expenditures are appropriate and directly relate to the budget and intent of the award and comply with applicable University, state, federal, and agency regulations.

Before an externally funded research project is undertaken at Kennesaw State University, the Principal Investigator(s) and Co-Principal Investigator(s) must familiarize themselves with and agree to comply with all applicable policies on issues governing the conditions of the award including:

Intellectual honesty and research integrity
Conflict of interest
Use of human subjects
Use of vertebrate animals
Radioactive materials
Other controlled substances
Export controls (for research involving foreign nationals or travel outside the United States)
Laws and University regulations dealing with intellectual property and patents
- USG policy
- KSU policy

Intellectual honesty, conflict of interest, and conflict of commitment policies apply to all projects and are covered in detail by Kennesaw State University’s Faculty Handbook. Regulations governing other issues should be consulted as necessary.

Office of Research's Responsibilities

The Office of Research has the primary responsibility for providing the Principal Investigator(s) with financial information necessary to manage a sponsored project effectively and to ensure that the project complies with the financial terms of the agreement. The following list covers many of the activities included in that responsibility:

Issue invoices to funders
Prepare financial reports for the awarding agencies
Set up budgets and assign grants numbers
Refer the PI(s) to other University offices, as needed
Remain current on federal, state, and University policies related to grants
Train project directors and staff in research administration regulations and procedures
Serve as a liaison with auditors on financial matters
Implement approved budget revisions
Make all requests for no-cost extensions
Review and approve transactions
Initiate draw downs for sponsored programs accounts
Provide reports for project directors

Financial Management

The Kennesaw State University Research and Service Foundation is the official recipient of grant and contract awards from government agencies and other sponsors and is required to comply with numerous rules and regulations. The Federal Office of Management and Budget establishes broad policies governing grant and contract financial administration. Every government agency that awards grants and contracts (e.g., the National Institutes of Health and the National Science Foundation) has its own regulations for administering grants and contracts as do most non-governmental sponsors.

Although the Office of Research grants managers or departmental or administrative personnel may assist the PI in carrying out administrative activities related to the grant or contract, the PI must provide guidance and oversight. The Principal Investigator best understands the scope of the project, the effort committed to it by faculty and staff, and the relationship of that project to other projects with which resources may be shared. Therefore, project directors are ultimately responsible for all direct costs that are charged to their grant. In this usage, direct costs are expenses that can be identified specifically with a particular sponsored project or expenses that can be assigned to a project with a high degree of certainty. Deans, directors, and department heads have a corollary responsibility for assuring that all sponsored programs conducted within their units conform to the applicable guidelines.

Cost Allowability

In order for costs to be allowable, all agencies require that they be reasonable, allocable, consistently treated, and permitted according to the terms of the award. When dealing with multiple grants or contracts, neither the availability of funds nor a project’s expiration date allows discretion in which project may be charged for a particular expense. All expenditures, whether for personnel, equipment, supplies, or other categories must be properly allocated to the grant or contract benefiting from the expense. The project’s director, not the project’s sponsor, is responsible for ensuring that expenses budgeted and/or charged to an award are allowable. Definitions of expense allowability are established by the University, the sponsor’s policies, the project’s Notice of Contract or Grant Award, and by federal policy. In general, to be allowable, costs must meet the following tests.

Expenses must be reasonable:

Necessary for performance of the sponsored agreement
Understood as what a prudent person would do

Expenses must be allocable:

The expense must benefit the grant directly
The expense must be necessary to the operation of the grant
The expense must be assignable to the grant
If the expense benefits more than one sponsored project, the expense should be allocated to the different projects in proportion to the benefits received by each

Expense treatment should be consistent:

With policies applied to other federal and non-federal funds of the University
In treatment in like circumstances regardless of the funding source

The expenditures must conform to any limitations or exclusions established by the University or in the sponsored agreement as to types or amounts of cost items. Any expense that does not meet all of these criteria cannot be charged to the externally sponsored project.

Unallowable Costs

Most federal and non-federal sponsoring agencies issue policy guidelines defining acceptable expenses for their programs. Despite a great deal of commonality in content, variations in policy make it impractical to maintain a policy compendium. Individual agency or organization directives must be consulted for authoritative guidance; however, the following items are almost universally treated as unallowable expenses:

advertising (recruitment of study subjects may be allowed)
alcoholic beverages (unless the subject of the research project)
alumni activities
commencement and convocation expenses
entertainment expenses
personal uses of goods and services

Project directors are ultimately responsible for tracking expenditures to prevent disallowable costs and overdrafts. If unallowable costs are erroneously charged to a sponsored project, the project director must notify an accounts manager immediately. If the issue is not resolved, the PI’s home department will be charged with disallowed expenditures and overdrafts.

Procurement Cards

Allowable costs of less than $5,000 can be paid with a University Procurement Card.

Responsibilities – The project director is responsible for verifying that all procurement card purchases charged to his or her grant are in compliance with the award or contract. Additionally, the project director is responsible for following the procurement card policies of the Office of Fiscal Services.

Repeated violations of these policies will result in the revocation of procurement card privileges.

Invalid or Unauthorized Expenditures – Project directors are responsible for all charges booked to their project with procurements cards regardless of who holds the card. If invalid or unauthorized purchases are charged to a grant using a procurement card, the project director’s college or department budget will absorb the expense. Charges that cannot be paid by the college or department (i.e., expenses cannot be paid with state funds) will be the responsibility of the project director. The Office of Fiscal Services will create a receivables account in the project director’s name to collect funds that cannot be absorbed by the Director’s home department of college.

Procurement of Goods and Services (eProcurement)

Requisitions for goods and services are created through eProcurement (ePro), a module in PeopleSoft Financials for University System of Georgia institutions. ePro requisitions must be approved by the project director. This approval certifies that the cost is allowable and solely allocable to the grant. ePro requests must include an itemized receipt or invoice. Consult the ePro Reference Materials for answers to many questions.

Equipment Management

The Office of Research and the Office of Fiscal Services are responsible for establishing and maintaining accountability for equipment acquired under grants, contracts, and subcontracts for sponsored programs in accordance with sponsoring agency directives and University policy.

The acquisition cost threshold for what is considered non-expendable equipment may vary among sponsors. Most federal sponsors use the definition contained in OMB, 2 CFR, i.e., an acquisition cost of $5,000 or more per unit or the institution’s definition, whichever is lower. The threshold amount at Kennesaw State University is $5,000.

If your project includes funds for equipment, please contact your grants manager for assistance in obtaining quotations (bids) from vendors and placing orders. Office of Procurement oversees KSU’s purchasing policies. Questions about these policies or equipment purchased on a federally sponsored award should be directed to the Office of Research.

Receiving Requirements – The Principal Investigator is responsible for assuring that equipment received is as ordered and in good condition. Any discrepancies or damage should be immediately reported to the Procurement Department.

Maintenance – Responsibility for maintaining physical control of all equipment acquired under an award and safeguarding it against loss, damage, or unauthorized use rests with the Principal Investigator. Subcontractors or sub-grantees are also responsible for compliance with equipment policies and requirements as described in sub-award documents.

Equipment Transfers – Equipment owned by the federal government or other sponsors is subject to transfer to another institution when approved and directed by the sponsor agency. A request for transfer of such property can originate with a researcher transferring to another institution and requiring the equipment in the pursuit of continuing research or with the sponsor agency itself. A transfer originated by a faculty member requires the advance approval of the appropriate department head, dean, Vice President for Research, and, in some instances, the federal or sponsor agency. Agency- originated disposition or transfer instructions do not require such approval. However, if agency-directed or contemplated transfers are likely to impair continuing research or training projects at the University, such considerations should be brought to the attention of the agency promptly through the Office of Research in an attempt to dissuade the agency from making the transfer. Much of the property acquired on research or training awards becomes University (State of Georgia) property upon acquisition or by subsequent vesting of title. Disposition or transfer of such property is subject to University and state policies.

Travel

As budgeted in the project’s award, travel expenses are allowable if they are in direct support of the project. All travel reimbursements, both to University and non-University employees, are subject to state and University travel policies except when more restrictive policies and limitations may be imposed by a specific award. Federal travel regulations apply when required by federal awards. For more information, please refer to the Budget Development section.

Consultants

Costs of professional and consultant services rendered by persons who possess a special skill and who are not officers or employees of the University System of Georgia are allowable.

Hiring – The Office of Research and the Office of the Vice President for Operations are the only units on campus authorized to execute an agreement with consultants when sponsored funds are to be used. Requests to hire a consultant require the Consultant or Contractor Form (Sponsored Funds Only). Requests must be approved by the Office of Research prior to a consultant commencing work on a project.

Named Consultants – If a consultant is not specifically named in a grant and the agreement is $5,000 or greater, but a description of work is stated in the grant, then a Sole Source Form must be completed by the project director and submitted with the Office of Research Consultant or Contractor Form and a resume.

Payment – To initiate payment of a consultant/contractor, project directors should consult with their grants manager for assistance.

Lecture and Performance Agreements

Lecture and performance agreements are used when a guest lecturer speaks during a class, workshop, seminar, etc. Requests to hire a lecturer should be made using the appropriate forms found on the Contracts - Fiscal Services website. Requests to hire a lecturer must be fully approved prior to providing any service. Active Kennesaw State University employees cannot be paid as a lecturer.

Copy Charges

If your grant has an amount budgeted for on-campus photocopying, the project director should contact Copy/Print Services at KSU to request a copy code be created for charges to the grant. The project director must provide the grant name and grant speed chart number for the code to be established. At the close of the grant award, the project director is responsible for notifying Print Copy Services to terminate the charge code. If this code is used beyond the grant end date, the copy charges will default to the project director’s home department.

Fixed Price Contracts / Residual Balance Procedure

Most awards are cost-reimbursable. However, under some circumstances, a fixed-price contract may be negotiated. In those cases where an agreement is a fixed-price contract (generally research institutes and centers), provisions must be made by the Principal Investigator and/or department or center having primary responsibility for the project to cover any overdrafts or excess expenses.

Residual Balance Procedure

This procedure describes the treatment of residual balances associated with negotiated contracts funded from external sponsors. Please view the Residual Balance Procedure (PDF) for more information.

Post-Award Budget Changes (Rebudgeting)

Post-Award changes to project budgets require prior approval. Requests for changes are made with the Office of Research’s Administrative Action Request Form.

Recommended Purchasing Deadlines for Grants

All grant expenditures must be posted or encumbered on Kennesaw State University’s financial ledgers prior to the grant end date.

Last Month of Award – During the last 30 days of the award Project Managers should notify their grant accountant of any purchases (procurement card, ePro requisitions, travel, etc.) incurred. Notification should be provided immediately to assure that the expenses are posted to KSU’s ledgers prior to the award end date. In general, supplies and materials purchased for the project should be consumed by the award’s end date. Residual inventories of supplies valued at more than $5,000 are subject to specific requirements for their handling.

Grant-Specific Deadline(s) – You must reference the individual grant/contract for grant-specific deadlines set by funding agencies (i.e., narrative reporting, etc.). The Office of Research is responsible for all fiscal reporting. Please contact the Office of Research if you have any questions about these deadlines.

Review Process with the Grant Accountants

Expenses must be reasonable:

Expenses must be allocable:

Expense treatment should be consistent: