Written by Justo Torres, Director, Contracts and Grants
The management of a contract or grant is a partnership between science, administration and funder. In other words, it is a partnership between faculty, unit administrators, central-office administrators and the entity funding the contract or grant. As with any partnership, knowing who is responsible for what is critical to success.
In the case of federal contracts or grants, the government expects institutions to interpret and apply the Uniform Guidance in an autonomous manner. Their expectation is for us to manage HR actions, travel decisions, procurement, billing, invoicing and cash management, cost allowability and other administrative actions. They have set the rules and they expect us to independently and consistently interpret and apply them. They expect us to own the day-to-day operational decisions of a project.
On the other hand, there are cases where sponsor approval is required. If a previously undisclosed foreign trip is planned, or if the PI intends to purchase equipment not in the original proposal, sponsor approval may be appropriate. Likewise, any significant changes to the technical aspects of a project or the disengagement of key personnel would require sponsor approval or notification. Planning to subcontract a portion of the award not previously disclosed to the sponsor would also require approval.
You might be tempted to think, “when in doubt, I should ask the sponsor.” While this is logical, this is wrong. When institutions reach out to federal sponsors for guidance or approval on matters they deem the institution’s responsibility, they may perceive there to be a lack of administrative oversight over contracts and grants. This could invite questions about the institution’s ability to manage grants and encourage audit oversight.
When in doubt as to whether sponsor approval is required, it is best practice to reach out to your college research office, SPARCS or Contracts & Grants for advice. In most cases, if sponsored approval is deemed necessary, it will be through SPARCS and/or the college research office anyway.
Additional guidance on this topic can be found in the Research Administration and Compliance, Manage Project page.