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

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 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")
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