I was just framing a similar answer. The key is that the institution is the applicant and the institution is the awardee. The only thing that I would add to what Kristy said is that, as the awardee, the institution has clear reporting responsibilities to the sponsor as part of its acceptance of the award. This includes program reports as well as fiscal reports. Kristy discusses the fiscal risks well below. But having an unaffiliated PI creates a host of potential program report risks that could negatively affect the institution. Again, common sense dictates that you not rely on an unaffiliated individual to meet the institution's program report obligations. The institution's control over the PI's future pay checks and evaluations can assist an affiliated individual in remembering to complete required reports in a timely manner on behalf of the institution. As has been discussed here before, all affiliated PI's will not necessarily remember and will not be easily coaxed to remember. How much harder, then, would it be to get reports out of unaffiliated PI's? Glen C. Clarke Associate Director Research and Sponsored Programs Office SUNY Cortland (607) 753-2511 fax: (607) 753-5590 xxxxxx@cortland.edu -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Kristy Ford Sent: Friday, February 08, 2008 1:11 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] Eligibility to Submit Grants I cannot quote the regs on this, but how can an organization be an applicant if the PI is not part of that organization? There would need to be a relationship established between the PI and the applicant organization through a subaward or consulting agreement. However, the applicant org. still needs to have someone "in charge" of running the project and ensuring that objectives are being met who is actually an employee of the organization. If the PI is not an employee of the organization, you could encounter audit issues or may not even get awarded. The agency could make the argument that if the PI is not part of the organization, then why is the organization even applying? Obviously the org. does not need any funds since they are not doing any work. It's pretty much common sense based on an understanding of the relationship between subawards and consultants and the applicant organization. You have to remember that awards to organizations are also tracked via the EIN.! This links all aspects of the financials together, which would include the PI. If the PI is not associated with that EIN at all, I feel that it leaves you open to audit issues. Remember, auditors now want to see that full circle trail of the funds in the financial system, which includes monies that non-employees will use through implementation of a subaward or consulting agreement. If the PI is not an employee and there's no subaward or consulting in the budget, the trail stops at a certain point and could be questioned. Now, I could be looking too deeply into it, but when it comes to issues that could negatively impact an audit or cause auditors to question, I would air on the side of caution. I feel it is best to find someone at your institution willing to lead the project and subcontract or consult with the non-employed individual. It makes it clean. A-110 defines a recipient as "an organization receiving financial assistance directly from federal awarding agencies to carry out a project or program." That's about the only thing that I can think of without searching that defines the role of an award recipient and therefore predetermines the necessary relationship of PI and recipient. If there are any other opinions on this, I'd be interested in others' thoughts. Kristy Kristy Ford Grant Management Manager Office of Sponsored Programs/MHUMC 4750 Waters Ave. Suite 212 Savannah, GA 31404 (912)350-6379 >>> Peter Koch <xxxxxx@CCHMC.ORG> 2/8/2008 11:50 AM >>> Greetings list-servers! I have seen the various questions and replies about institutional policies regarding who can serve as a "PI." There is some variation in how people approach this, but there are also many commonalities. Clearly most would agree that PIs should be qualified for the work proposed, meet the sponsor eligibility requirements, etc. Many also stipulate that some sort of "academic" appointment is a requisit. My question relates specifically to individuals that do not have a "paid" employment relationship or "paid" academic appointment with the applicant organization. I have never been able to locate any specific "regulatory" citation (Sponsor-specific, or general Federal) that stipulates what the formal relationship between the applicant organization and the PI "must" be. So, for instance there is nothing I am aware of that says the PI must be an employee of (i.e. get a paycheck from) the applicant organization. Would anyone out there care to chalenge that statement? If so, can you provide the reference? For all those institutions that allow "non-employees" to submit proposals, do you have a standard agreement that you get them to sign prior to letting them submit? Thanks. - Pete Peter C. Koch, MBA Assistant Vice President Sponsored Programs Cincinnati Children's Hospital Medical Center 3333 Burnet Avenue, TCHRF-3303, MLC 7030 Cincinnati, Ohio 45229-3039 Phone: (513) 636-4583 Fax: (513) 636-1392 E-mail: xxxxxx@cchmc.org ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
