The PI (defined to include surrogate PI) has sole responsibility for accomplishing the technical goals of the project. These technical goals must be accomplished in compliance with financial and administrative policies and regulations as provided by CUA and the sponsor. CUA’s default position is compliance with federal regulations for all sponsored awards, federal and non-federal. Although a PI may have support staff, whether research or administrative, to help them achieve their research objectives, it is always the PI’s ultimate responsibility to ensure that all activities and personnel on a project comply with all relevant policies and regulations. To ensure that other staff is working to appropriately support the sponsored award goals, the PI should meet with their respective administrative and research staff at least monthly to review research progress, direct expenses and budget availability for their sponsored awards.

The fundamental responsibilities of the PI at CUA during the post-award phase include:

  • Executing the sponsored project as outlined in the award documents;
  • Reviewing grant budgets and all expenditures at least monthly to assure their appropriateness;
  • Authorizing only those expenditures that are reasonable and necessary to accomplish the project goals and are consistent with the sponsor’s terms and conditions;
  • Spending no more than the amount authorized by the sponsor for the budget period and requesting any appropriate no-cost extension (NCE) well in advance of the Project End Date;
  • Resolving any amount expended in excess of the award amount;
  • Reporting project progress to the sponsor as scheduled and providing timely response to requests from Sponsored Accounting staff for any requested Effort Certifications, Progress Reports, Final Financial Reports (FFR), Grant Closeouts and any other documentation that may or may become necessary;
  • Complying with all CUA Policies and procedures related to project management and personnel practices;
  • Maintaining all supporting files and documentation for three (3) years beyond the end date of the award;
  • Complying with all applicable sponsor rules, regulations and/or terms and conditions of the award;
  • Ensuring that all expenses are allowable, allocable and applicable to the grant charged (See OMB Circular A-21, Section J). If unsure, call Sponsored Accounting;
  • Supervising research staff assigned to the award;
  • Procuring needed services and supplies to further the research goals of the award and in compliance with CUA policies and procedures;
  • Approving subrecipient invoices quickly when requested by Sponsored Accounting;
  • Completing all Progress and Technical Reports as such reports are neither reviewed nor monitored by Sponsored Accounting;
  • Reviewing, at least monthly, grant financial summary (1Grant) and run the Drilldown tool to review specific financial activity;
  • Reviewing weekly PCard software (ESP), completing needed reallocations and receipt uploads within the required timeframe; and
  • Properly completing Cost Transfer Forms as needed and directed.

The PI is responsible for knowing and following the applicable policies and rules, including:


Surrogate PIs


To avoid potential conflicts of interest, it is Catholic University practice to not allow a faculty member to be the Principal Investigator (PI) on an externally funded project if that faculty member has any connection to the funder. In these situations, a Surrogate PI would be named by Catholic to manage the project.

Situations that could require a Surrogate PI:

  • The potential Catholic University PI has a business relationship with the funder (employee, stockholder, owner, etc.)
  • The potential Catholic University PI has a family relationship with anyone at the funding organization, especially if that person would make financial decisions regarding the funding.
  • Any other situation where a conflict of interest might exist (financial or otherwise), or there is the potential for a conflict.

Naming of the Surrogate PI:

  • The Surrogate PI does not need to be from the same academic department/school as the faculty member with the conflict.
  • The Surrogate PI should not be someone over whom the faculty member with the conflict has any supervisory role.
  • The Surrogate PI should have reasonable familiarity with the subject matter of the project.
  • The choice of the Surrogate PI should be made by the Vice Provost for Sponsored Programs in consultation with the Chair and/or Dean of the department/school of the faculty member with the conflict.

Responsibilities of the Surrogate PI

The Surrogate PI steps into the shoes of the PI and is responsible for knowing and following all of the applicable policies. The surrogate PI should pay special attention to certain aspects of the policies.

  • The Surrogate PI maintains the full responsibility for the financial and reporting aspects of the award.
  • The Surrogate PI ensures that the decisions made on the direction of the research conform with the objectives of the award as laid out in the statement of work. It is important that inputs into these decisions made by the funder are weighed against the potential for the faculty member with the conflict to benefit at the expense of the grant objectives or university interests.
  • The Surrogate PI should ensure that any intellectual property developed during the execution of the award is reported to the University Director of Technology Transfer.
  • The Surrogate PI should make an annual report (verbal or written) to the Director of Sponsored Programs regarding project progress.
  • The Surrogate PI shall ensure that the person who has been conflicted out of the PI role has no undue role or undue influence on the tasks and decisions that are the responsibility of the Surrogate PI.