- Short-term absence of principal investigator: If the PI will be absent from the project for short periods of up to three months, s/he must notify appropriate officials of the sponsor about arrangements for the conduct of the project during his/her temporary absence.
- Long-term absence of principal investigator: If the PI will be away for more than three months, s/he must obtain approval from the sponsor at least 30 days before the anticipated absence begins. When such an absence is necessary, the PI should draft a letter detailing the dates of the anticipated absence and the individual who will serve as substitute PI while the PI is absent. This letter should be submitted to the Grants Manager in Grants and Contracts Administration to be signed before it is sent to the sponsor.
- Change in level of effort: If the PI devotes substantially more or less effort (25% or more) to the project than originally anticipated when the award was made, sponsor approval is required. The PI must notify Grants and Contracts Administration if this occurs.
- Substitution of principal investigator: If a PI retires, resigns, is reassigned. or relinquishes active direction of a project, the sponsor must be notified. The department chair will either coordinate negotiation for a substitute PI to continue the project or terminate it. The department chair should also notify Grants and Contracts Administration (PI Variance Form).
- Contracting or transferring the project effort: No significant part of the research or substantive effort may be transferred or subcontracted to another agency without prior sponsor approval, including instances where a PI accepts employment with another institution. The PI must coordinate the subcontract/transfer approval process through Grants and Contracts Administration in such circumstances (see policy checklist form).
Changes in Direction/Management
Prior sponsor approval is required for a change in objectives, scope, PI, or project effort on some grants and contracts; especially those that are federally funded.
- Changes in Objective or Scope
Principal investigators must obtain sponsor approval before changing the objective or scope of any grant or contract. Examples, though not all inclusive, are as follows:
- Change in specific aim approved at time of the award
- Any change from approved use of animal or human subjects
- Shifting emphasis of research from one area to another
- Applying a new technology from what was originally proposed
- Transferring the performance of substantive work to a third party (subcontractor)
- Change in those designated as "key personnel" by the sponsor
- Significant re-budgeting
- Changes In Principal Investigator
Sponsors often base decisions to award funds on the expertise of the PI. A change in PI is an important consideration in the sponsor’s decision to continue funding the research.
- Cost and No-Cost Time Extensions
As soon as the principal investigator determines that a project's performance will require additional time, with or without the need for additional funding, a written request cosigned by the PI and the appropriate University authorizing official must be submitted to the sponsor. Extensions that require additional funding must be processed through the Office of Sponsored Programs (OSP).
No-cost time extensions must be processed though Grants and Contracts Administration. Some federal projects allow a one-time, twelve-month, grantee-authorized extension in which the appropriate Grants and Contracts Administration manager notifies the sponsor that Clemson University is extending the project. The federal agency must receive the request with the supporting reasons and revised expiration date at least 30 days before the original expiration date specified on the award. The PI must submit the request to Grants and Contracts Administration. (See Appendix for the format on no-cost time extensions).
Sponsor approved extension requests should be submitted to Grants and Contracts Administration at least 45 days prior to the original end date.
No-cost time extensions may not be requested just to spend unobligated balances.
- Revising Active Project Budgets
Occasionally, an active project’s budget requires revision due to unforeseen circumstances. Some sponsors are very firm, allowing no budget changes without sponsor approval, while others are quite liberal in allowing the PI complete control over the budget. The PI should notify their college post award coordinator as soon as s/he recognizes the need for a budget change. In addition to sponsor requirements, the PI or his/her designee must send a request, comprehensively justifying the solicited revisions to Grants and Contracts Administration. CPAC's will also prepare the budget amendment on the child budget to reflect the needed changes.
If the facilities and administrative cost rate of a project is based on modified total direct costs (MTDC), the transfer of funds from any non-equipment budget class to an equipment budget class will reduce facilities and administrative costs. This reduction is necessary because the University does not charge facilities and administrative costs on equipment in programs using MTDC.
Likewise, transferring funds from equipment to another budget class increases facilities and administrative costs. Fund transfers of this nature could result in a loss of facilities and administrative cost recovery, since the facilities and administrative costs specified in the original award cannot be increased without sponsor approval. Facilities and administrative costs are not affected by budget class changes if the rate is based on total direct costs (TDC).
Requests for budget revisions should be processed through Grants and Contracts Administration, who will forward the requested revision to the sponsor if necessary. When the sponsoring agency delegates approval or disapproval authority to the University administration, the director of Grants and Contracts Administration will act on the re-budget request.
- Cost Transfers/Corrections
The Department of Health and Human Services (DHHS) has warned that frequent, tardy and unexplained (or inadequately explained) transfers; especially those which involve projects with overruns or unexpended balances; raise serious questions about the propriety of the transfers. Clemson University’s record keeping system and controls are also suspect when costs are frequently transferred.
Documentation of transfers/corrections must contain a justification for the transfer and an explanation of how the error occurred and why the expenditure was not correctly charged the first time. The PI or his/her designee must sign all correction forms. DHHS specifies that an explanation stating "to correct error" or "to transfer to correct project" is neither sufficient nor satisfactory. DHHS also requires the documentation for the adjusting/correcting entries to be readily available at the time of audit.
A federal awarding agency may restrict the transfer of funds among direct cost categories or programs, functions and activities for awards in which the federal share of the project exceeds $100,000, and the cumulative amount of such transfers exceeds or is expected to exceed 10 percent of the total budget as last approved by the federal awarding agency.
Transfers of charges to and between government grants and contracts should be kept to a minimum. Account numbers should be properly reflected on requisitions, appointment forms, time sheets, etc. when initiated and when work orders are placed at service centers within the University.
To help ensure that cost transfers will meet audit requirements, any transfer of cost into or between federal government grants and contracts must meet several criteria to satisfy audit requirements:
- The transfer must be current (less than 90 days old). The area vice president must approve any cost transfers for payroll charges submitted more than 90 days from the date of the original charge.
- The transfer must be a proper and allowable charge to the grant or contract receiving the charge.
- The transfer must be supported by documentation, which contains a full explanation of how the error occurred and why it was not initially charged to the proper account.
- The transfer must be accompanied by justification for the need for the transfer.
- The transfer must contain a certification by the principal investigator(s) of the project(s) involved of the correctness of the charge being transferred.
- The transfer must be identified as a cost overrun or an account correction.
- Cost overruns should be transferred to a non-sponsored account with the same account type (field 2 of the account number).
- If supply charges are reclassified to equipment, a copy of the direct voucher and the invoice should be included with the correction. The decal number should be indicated on the form if the correction adds value to existing equipment.
Since audit dissallowances must be covered by other non-restricted funds in the department, individuals who process the correction should always obtain approval from the chairperson of the department.
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