Principal Investigator Guide
- Conflict of Interest
- Cost of Research
- Ethical Conduct in Research
- Gifts to Support Research and Other Gifts to UHD
- Office of Research and Sponsored Programs
- Persons Authorized to Be Principal Investigators and Co-principal Investigators for UHD
- Proprietary Research
- Sponsored Projects at UHD
- Administrative Review and Approval of Proposals
- Budget Negotiation
- Cost Sharing
- Human Subjects
- Proposal Preparation
- Supplemental Funds Request
- Subcontract/Subrecipient Awards From UHD
- Project Maintenance
- Award Acceptance
- Budget Changes
- Business Negotiations
- Change in Principal Investigator
- Extensions to Sponsored Agreements
- Intellectual Property
- Leave of Absence of Principal Investigator
- Submitting a Revised Budget
- Transferring a Grant to Another Institution
- W-9 Form
Faculty and authorized professional research staff are encouraged to seek external financial support for specific projects undertaken to further the mission of UHD in teaching, research and public service. Sponsored projects enhance and expand the educational opportunities available to UHD's students, facilitate research, scholarly inquiry, and the development of new knowledge, contribute to the academic achievement and stature of the institution, and assist UHD in fulfilling its responsibilities to the state and to the nation.
The primary responsibility for the origination, development, and preparation of proposals rests with the Principal Investigator (PI) (faculty member with the rank of Professor, Associate Professor, Assistant Professor, or Instructor; or professional research staff with the title of Director). All proposals are expected to be germane to the interests and expertise of the PI and shall be consistent with and contribute to the mission of UHD. While awards for successful proposals are made to UHD, the PI is responsible for the management, execution, and completion of the project, including submission of all required reports. ORSP provides information, assistance, and technical support to the PI during this process.
This policy is established to comply with the regulations of the Public Health Service (PHS) and the National Science Foundation (NSF). It is the responsibility of UHD to promote objectivity in research by requiring that an employee of UHD who applies for grants or cooperative agreements for research or other educational activities or otherwise submits a proposal for sponsored funding ensures that there is no reasonable expectation that the design, conduct, and reporting of research will be biased by any significant financial interest of a PI responsible for the research or other educational activity. Based upon federal regulations and UHD's objective to maintain a research environment that promotes faithful attention to high ethical standards, this policy relating to conflicts of interest is to be administered in conjunction with Texas laws setting forth standards of conduct, Texas Government Code, Chapter 572, and the UH System Administrative Memoranda on Ethical Conduct of Employees (Interim)
UHD expects external Sponsors to pay the actual costs of conducting the Sponsored project and these costs should be included in the request unless the sponsor limits certain kinds of costs. These costs include both the direct and the indirect cost obligations incurred by UHD in the conduct of a project.
Scholars and research personnel of UHD are expected to adhere to the highest ethical standards for all research and scholarly work. It is the responsibility of every PI to maintain the integrity of research projects by keeping accurate, permanent, and auditable records of all experimental protocols, data, and findings.
Misconduct in science and other scholarly activities is absolutely incompatible with the standards of UHD and all allegations of such behavior will be handled promptly. UHD's policy regarding ethical conduct in research may be found by clicking here.
Proposals to foundations for research projects should be coordinated through UHD's Office of Institutional Advancement prior to submitting a proposal. This office will have additional information about specific foundation guidelines that will assist in preparing the proposal. Solicitation of philanthropic gifts from foundations, individuals, or other sources for non-research activities and the processing of non-cash gifts of equipment and other items of use in research programs are also coordinated through the Office of Institutional Advancement.
The Office of Research & Sponsored Programs (ORSP) serves as the coordinating office for externally funded research proposals submitted by UHD and projects awarded to UHD. The goal of ORSP is to assist faculty and professional research staff in their efforts to secure external funding and successfully complete their funded projects.
ORSP provides technical assistance to PIs during proposal preparation (budget, special instructions, etc.), serves as an information source for and monitors compliance with applicable UHD and Sponsor policies and requirements, handles administrative matters with sponsors, including contract negotiations approves grant expenditures and serves as a liaison with the Grant Accounting section of Business Affairs during the billing, audit, and close-out of a project. All proposals are reviewed before submission to the Sponsor and PIs are notified of any omissions, necessary corrections or other items that might strengthen the presentation to the potential sponsor.
The following services are provided by ORSP:
- Assist the UHD research community in processing research proposals to outside funding
- Review of Sponsor guidelines
- Review of compliance issues for UHD
- Completion of Sponsor's Representations and Certifications
- Review budget
- Serve as liaison between UHD and Sponsor
- Check status of pending proposals
- Notify PI when additional technical information is requested by Sponsor
- Negotiate revised budget
- Provide additional budget detail
- Receive and negotiate incoming awards
- Read and review terms and conditions of incoming awards; contact Sponsor and negotiate unacceptable terms
- Notify PI of special terms and conditions and obtain approval of final agreement
- Provide award information to Grant Accounting for creation of a cost center number for the project
- Prepare and negotiate subcontracts to outside entities, as needed
- Serve as liaison between PI and Grant Accounting
- Initiate requests for authorization to spend available funds to facilitate continuity of the project
- Assist in the management of complex projects
- Provide training for new personnel and staff
- Approve grant expenditures
- Serve as liaison between PI and sponsor
- Assist with routine requests to sponsor (no-cost extensions, rebudgeting requests, leave of absence of PI, etc.)
- Remind PIs of specific requirements for submission of progress reports
- Assist PI in transferring to another institution by transferring active research projects
- Assist in the submission of final reports to sponsor by notifying the PI of any delinquent reports.
- Serve as the repository for information pertaining to research funding
When UHD accepts a grant or contract from an external sponsor, UHD assumes responsibility for the proper performance of the stated project, for the fiscal management of the funds received, and for accountability to the sponsor. Since the institutional responsibility for meeting these obligations is vested in the Principal Investigator, only individuals in the categories shown below are authorized by UHD to be Principal Investigators or Co-Principal Investigators for sponsored projects.
Tenure or Tenure-track Faculty (Professor, Associate Professor, Assistant Professor, and Instructor) or Directors. In rare instances others may be authorized, and then only with the prior written approval of the Vice President for Academic Affairs.
If a department wishes to request PI status for an individual not included on this list, a request should be made in writing via ORSP, the applicable Dean, and the Provost, to the Vice President for Academic Affairs. The request should include a vita and a statement regarding why it would be beneficial to UHD for this person to serve as a PI or Co-PI on the project in question.
As a public institution, it is not in UHD's mission to conduct proprietary research, develop exclusive or proprietary data for a sponsor, conduct any "work-for-hire", or permit a sponsor to direct or control research projects. UHD's facilities and equipment may not be used by a sponsor's employees or for the specific benefit of a sponsor. The purpose of research is the discovery and dissemination of new knowledge; UHD will not assume the role of an advocate or a social action agency.
Publication of new knowledge developed under sponsored projects is a fundamental step in the research process. UHD will ensure that it retains the right to publish all work done under sponsored projects and PIs are encouraged to use all appropriate channels to disseminate the results of their work. Publication delays of a reasonable period are allowed only to permit the filing of a patent application, where applicable.
Proposals to external funding sources for sponsored projects must be submitted through the Office of Research & Sponsored Projects (ORSP) and awards received must be processed by ORSP when one or more of the following criteria are met.
- A specific program of work or research is proposed to or required by the sponsor
- The sponsor requires an authorized institutional signature
- The sponsor requires or expects one or more progress reports, a final report, financial reports and/or a formal accounting of how the funds were expended
- There are intellectual property, confidentiality and/or publication conditions associated with the receipt of funds.
- Most frequently these proposals involve research projects but any program requesting support by an external sponsor that satisfies these criteria shall be submitted through ORSP.
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Prior approval for proposals must be obtained by using the Notice of Intent to Submit Form.
The summary information contained on the completed form facilitates administrative review and approval, and thus helps to expedite processing.
It is the responsibility of the PI to ensure that all approvals are obtained prior to the proposal being submitted to the sponsor. ORSP can help with this. These approvals include:
*Notice of Intent to Submit Form. This form needs to be submitted prior to the proposal being developed. The Authorization Form will be submitted with a copy of the completed proposal. It will be signed by the PI, Co-PIs, Chair, and the Dean. Approval by the Chair(s) and Dean(s) indicates to the Unit Head of Research and Sponsored Programs that they are willing to commit the time and effort of the PIs and any other required resources, so identified.
It is very important to identify the development of any new academic programs or courses. If the project does involve this, the Unit Head of Research and Sponsored Programs will review this information with the applicable Department Chairs and Deans before providing approval to the PI. The PI should ensure that this approval has been granted prior to developing the proposal.
Authorized Institutional Representative: This is the individual designated by the President to sign proposals and accept gifts, grants and contracts on behalf of UHD. Currently, the Director and Unit Head of ORSP are the individuals designated by the President.
Preliminary budget negotiations are often conducted between the PI and the technical contact for the sponsor to determine an appropriate level of funding for the program proposed by the PI. these preliminary discussions are encouraged. The PI should contact ORSP, however, for established rates for fringe benefits, indirect costs or other budgetary matters that may impact the total support required for the project. It is important for the PI to know how much the project is going to cost before contacting the sponsor.
The PI should not attempt to negotiate rates for indirect costs or fringe benefits that are different from the federally approved rates for UHD, nor should it be implied that a reduction in the approved rates would be acceptable to UHD. Indirect costs represent substantial, real expenditures incurred by UHD to support each research program, and if these costs are not fully paid by each sponsor, UHD must subsidize them from other institutional resources. In the event that a sponsor indicates to the PI that it does not wish to pay these costs in full, ORSP should negotiate with the sponsor regarding this issue, not the PI.
If formal budget negotiations are required, ORSP will conduct the negotiations, including the confirmation of approved salary, benefits, and indirect cost rates. ORSP will seek the PI's input and concurrence for any modifications proposed by the sponsor.
This section provides guidance that will facilitate compliance with federal cost sharing requirements as set forth in OMB Circulars A-21 and A-110. This guidance applies to both Federal and non-Federal Sponsored programs.
Cost sharing means that portion of project or program costs that are not borne by the Sponsor.
There are two types of cost sharing that occur on sponsored projects. The two types of cost sharing are:
Mandatory Cost Sharing: is that commitment to participate in the cost of the project required either by Statute or by Administrative regulation. The requirement for such cost participation will be explicitly set forth in Sponsor announcements or guidelines, will be a requirement for eligibility to participate in the project and will be specifically identified within the University’s proposal.
Voluntary Cost Sharing: is the University’s participation in the cost of a project when there was no commitment within the University’s proposal to share in the cost of the project or when the University’s actual participation in the cost of the project exceeds the cost sharing commitment made as a part of the University’s proposal.
The obligation for cost sharing is predominately associated with Federal grants and cooperative agreements. In accordance with OMB Circular A-110, cost sharing must meet all of the following criteria:
- The cost sharing must be verifiable and auditable within the University’s accounting system.
- The cost sharing must not be included as contributions for any other Federally assisted project or program.
- The cost sharing is necessary and reasonable to accomplish project or program objectives.
- The cost sharing is allowable in accordance with the applicable cost principles (OMB Circular A-21),the terms of the agreement and UHD policies.
- The cost sharing must be funded from non-Federal sources, unless authorized by Federal statute.
- The cost must be incurred during the term of the agreement.
Any University commitment to share in the cost of a project should be identified early in the proposal process. Therefore, the following Cost Sharing Form must be submitted, if applicable, with other mandatory documentation when submitting a proposal:
The University commitment and the cost associated with the commitment must be in accordance with University policy and must be approved in advance by the Vice President for Administration and Finance.
UHD faculty, staff, students or employees who propose to engage in any research involving the use of human subjects must have prior review and approval of that activity by the UHD Committee for the Protection of Human Subjects (CPHS). CPHS is responsible for ensuring that UHD safeguards the rights and welfare of subjects who may be at risk through participation in such activities. These requirements apply to both funded and non-funded research regardless of whether the research is performed at UHD or other locations. For further information, please refer to Human Subjects website.
In the event that the PI plans to respond with a proposal to a sponsor's one- time program opportunity (i.e. Requests for Proposal [RFP], Requests for Quotations [RFQ], Broad Agency Announcements [BAA], etc.) the sponsor's website should be sent to the ORSP. ORSP can begin to provide assistance in the completion of any administrative forms and will remind the PI that the project must be approved by the Provost through the Notice of Intent Form .
Requests for additional funding on an existing project are processed as proposals through ORSP.
The following items are required:
- Statement of work for the additional effort
- Updated certification for all compliance issues, if required.
The cost center number of the current grant should also be provided.
ORSP has the overall responsibility for issuing and monitoring subcontracts/subrecipient agreements under sponsored project awards. ORSP will maintain documentation relative to a subcontract/subrecipient agreement placement and any modification thereof.
ORSP will negotiate all subcontracts and subrecipient agreements in accordance with standard business practices and, as appropriate, the Federal Acquisition Regulation and/or OMB Circulars A-21, A-110, and A-133, and all documentation will be placed in the subrecipient file. These agreements will comply with all standard and special provisions of individual awards. After the subcontract/subrecipient agreement is fully executed and work has commenced, it is the responsibility of the PI to:
- Review and approve all invoices from the subcontractor/subrecipient to determine if the charges are appropriate
- Prepare a voucher to make payment for all appropriate charges
- Monitor the progress of the subcontractor/subrecipient and
- Obtain all required deliverables from the subcontractor/subrecipient.
Documentation for these activities should be maintained by the PI.
Award documents take many forms depending upon the type of sponsor and project. Grants, contracts, and cooperative agreements are typical to sponsored projects. These documents require review and signature by the Authorized Institutional Representative. Currently, the Unit Head of Research and Sponsored Programs is authorized to sign on behalf of the institution. ORSP is responsible for award document processing. Additionally, a Sponsored Research Agreement is required when UHD and/or a UHD representative agrees to enter an agreement with an entity to perform specific research work on a grant and, in turn, the entity agrees to sponsor funding for said research activities. Please see the following link for access to the UHD Sponsored Research Agreement: Sponsored Research Agreement EDITED -- WORD 2014
Upon receipt of fully executed award documents or other proof of award, ORSP forwards information to Grant Accounting within Business Affairs for assignment of a cost center number (formerly called account number) and setup of the account. Once the Principal Investigator receives notification of the project account number and effective date from Grant Accounting, funds may be encumbered or expended against the project.
ORSP plays a role in the post-award phase of Sponsored project activity. ORSP serves as a central point of contact for Sponsor grant or contract officers regarding administrative matters throughout the duration of the project and approves project expenditures. ORSP also serves as facilitator and advocate for Principal Investigators in all matters pertaining to the non-technical management of their grants and contracts. In addition, ORSP coordinates compliance with each Sponsor's requirements for interim and final research technical reports. Principal Investigators are responsible for submission of all required reports in a timely fashion.
If the original budget needs to be revised and the sponsor guidelines do not allow for it, a request will need to be made to the Sponsor in writing. Most sponsors allow the university to approve budget changes. The request must be processed through ORSP.
ORSP reviews the terms and conditions of every award received. Terms and Conditions are negotiated in accordance with UHD policies.
Federal Awards: Terms and Conditions are usually predetermined, however, negotiations may be required.
Non-Federal Awards: Normally, most non-federal projects require negotiations, especially those agreements with industrial Sponsors. Such topics as inventions, publication rights, liability, and ownership of research results are usually the subject of negotiation. The negotiations are coordinated between ORSP, the Sponsor, the PI, and, as appropriate, the UH System Office of General Counsel. ORSP leads and facilitates the negotiations with the Sponsor.
If a change of PI is required on a project, a letter of request must be sent to the sponsor. The letter should be endorsed by the current PI, the proposed PI, and UHD. The letter should outline the qualifications of the new PI. This request is routed through ORSP.
Date extension requests must be submitted through ORSP to the sponsor. The request should be in writing and should provide a justification for the extension. The justification should relate to the completion of the scientific objectives not that funds are remaining. Requests for no cost extensions to NSF must be submitted through FastLane. Requests for no cost extensions must be submitted to the sponsor prior to the expiration date of the agreement. Most agencies require that the request be submitted 45 days prior to expiration. These type of requests generally take one to two months for the sponsor to process and approve. The processing time should be considered when deciding when to submit a request.
Requests for extensions on non-federal projects should be submitted in writing and routed through ORSP. The requests should include a programmatic justification for the extension. UHD has no provision for extending these projects without Sponsor approval. As with federal awards, these requests should be made prior to the expiration date and with ample lead time. A three-month lead time is suggested in order to have an approved extension prior to the original expiration date.
University research can result in the invention of new technology or the creation of new copyrighted material. Such results may have commercial value. While the production of commercially valuable intellectual property is not necessarily the purpose of university research or the duty of anyone engaged in research, the Board of Regents desires that both society and each component university under the governance of the board use all knowledge to the greatest possible benefit. Accordingly, when appropriate, each component university will protect all intellectual property rights in technology and copy-righted material and use diligent efforts to make productive use of such rights for the good of the public, the creator, and the System. When this result is achieved by the attraction of private risk capital, or by the transfer or licensing of rights in technology or copyrighted material, income may be realized, which the board will seek to distribute in a manner fair both to the creator and to the component university at which the intellectual property was developed. Financial return, however, always remains secondary and incidental to the public service aspect of developing and disseminating knowledge for public use. The board delegates management of intellectual property to the component university at which it is generated.
If the PI is planning to be away from UHD, he/she will need to notify the sponsor in writing of the absence. The letter will need to address how oversight will be maintained during the absence. This letter needs to be signed by ORSP.
During the course of business negotiations it often becomes necessary to reduce or adjust the budget initially proposed. If this is the case, the PI should send the revised budget and any other pertinent information (a revised budget explanation or revised statement of work or project duration may be appropriate) to ORSP for processing prior to sending the revision to the sponsor. Any major changes in the budget that would involve additional faculty or staff should be approved by the applicable Department Chair(s) and Dean(s).
Transferring a grant to another institution is a complicated process and requires proper timing to allow for the transfer and to allow for start-up at the new institution. Some sponsors have specific forms that must be completed to obtain a transfer. Other sponsors have no formal guidelines for transfers. There are general procedures that need to be followed at UHD to prepare for a transfer. The following steps should be followed to prepare for a grant transfer: An arbitrary expiration date should be selected for the project. In order for UHD to relinquish the project, Grant Accounting must be able to determine the residual funds remaining after all obligations have cleared. It takes at least 30 days after the chosen expiration date to obtain this information.
If equipment was purchased and is going to be moved to the new institution, approval must be obtained from the Department Chair, Dean, and the Provost. Once the grant is relinquished, any new funding will be secured through the new institution. Grants from NSF require completion of an NSF Grant Transfer Form. Once the grant has been relinquished, the sponsor will re-award the grant to the new institution.