Office of Sponsored Projects

Post-Award Conduct and Project Management


PIs should reference Post-Award Finance's website for information about rules and requirements governing sponsored funding. PIs are responsible for obtaining sponsor approval for any actions requiring such approvals.

Conduct of Research

The Principal Investigator:

  • Is responsible for all actions required to manage and complete the scientific and programmatic (technical) aspects of the sponsored project.
  • Initiates programmatic changes to the project and seeks approval from the sponsor via request to OSP when required.
  • Initiates the hiring or assignment process, approves the selection or appointment of individuals to the project, and communicates staff changes to his/her department.
  • Ensures the integrity and safeguarding of notebooks and scientific data.
  • Ensures the completion, accuracy, and timeliness of programmatic reports.
  • Initiates requests for and monitors subrecipient agreements prepared by OSP.
  • Ensures the quality, timeliness, and programmatic performance of subrecipients.
  • Initiates a materials transfer agreement with OSP when transferring materials to or from the University with another source.


Budget Management

While the PI retains primary responsibility for financial accountability, the PI or department head can delegate an authorized representative to act on his/her behalf for departmental account/project management. Accounts should be managed by persons trained in these responsibilities. The appropriate office in UTHealth Finance and Business Services is responsible for account management at the University level and is responsible for all payments, invoices, financial reporting, etc., to the sponsoring agency.

The Principal Investigator:

  • Initiates purchases.
  • Determines whether expenditures are allowable, allocable, and reasonable; approves expenditures; and provides scientific justification for the transaction, if necessary.
  • Adheres to Cost Accounting Standards, such as consistency in allocating costs.
  • Initiates the approval process for cost sharing and/or matching and ensures that cost sharing obligations are met from allowable and verifiable sources, including those by third party collaborators, if included in approved budget.
  • Initiates requests for rebudgeting as the sponsor requires.
  • Initiates cost transfer requests. When salary transfer requests are made, the PI must ensure these are based on actual effort expended and not merely as budgeted, per OMB Circular A-21.
  • Identifies and corrects any account deficit.
  • Reviews subrecipient invoices for appropriateness, monitors progress of the work, and approves payment of subrecipient invoices.
  • Provides financial monitoring; identifies and resolves errors in the account in a timely manner; and certifies or documents a monthly review of ledgers. If appropriate and required at budget period end, the PI requests that remaining balances are carried forward.


Program Income

Program income is gross income earned by a grant or contract from activities part or all of which is borne as a direct cost by the grant or contract. Examples of program income include: 1) fees earned from services performed under the project; 2) funds generated from sales of commodities such as tissue cultures, cell lines and research animals; and 3) income from publications, registration fees, consulting, and sale of educational materials.

The Principal Investigator:

  • Must understand the definition of program income, when applicable.
  • Identifies all program income and notifies the PAF team when program is anticipated/received.
  • Initiates the processes and proposes the allocation of program income.
  • Monitors receipt of program income.
  • Reviews program income reported to the sponsor by the PAF Team.


Effort Reporting

To ensure compliance with the effort reporting policy, PIs must sign and certify effort for themselves and employees using ecrt™, in accordance with UTHealth's Time and Effort Reporting Guidelines, designed in compliance with OMB Circular A-21.

Project Transfer

All awards are made to the University and not to the individual investigator. In the event a PI leaves the University, he/she must notify Co-PIs, faculty participants, the department head and dean of such departure in advance and seek appropriate next-step instructions from the department head, dean, and PAF.

  • If the PI wishes to take the grant/contract with him/her to their new institution, the PI must request and document written approval from his/her department head and dean in order to have the project officially relinquished.
  • Upon approval of the transfer, the PI must provide PAF with a memo confirming agreement to the transfer and other materials necessary to obtain appropriate sponsor permission.
  • If the transfer request is denied, or the PI chooses to leave the award with the University, the PI must notify PAF of their departure as soon as possible and assist with the proper sponsor notification. Such notification will either be a replacement investigator, or termination of the award.

Inventions and Intellectual Property

Intellectual property is any invention, creation, discovery, scientific or technological development, computer software, or other forms of expression of an idea arising from the activities of personnel covered by System policy. The System policy does not apply to faculty-authored written or visual work, except computer software, produced in the author's professional field, and such faculty-authored work is owned by the creator.

The development, ownership, management, use of, and marketing of any intellectual property developed at the University is governed by the Intellectual Property Policy of The University of Texas System.

The University's Office of Technology Management (OTM) provides inventors an avenue to explore the opportunities for their inventions, coordinates appropriate legal protection for the intellectual property, and undertakes the technology transfer activities, while ensuring that new products and methods are made available to the citizens of Texas and generating a royalty income for the University.

The Principal Investigator:

  • Adheres to the principles and policies outlined in the University’s Intellectual Property policy and the Conflict of Interest policy.
  • Ensures that all employees working on the project also comply with the policy.
  • Initiates the disclosure process and completes the Invention Disclosure Form in order to notify OTM.
  • Assists in preparing patent applications.
  • Assists in the processing of copyright registration or other intellectual property protection.


Implementing a Small Business Subcontracting Plan (if required)

When applicable and required by the sponsor’s requirements, the PI should work with Procurement Services to develop a Small Business Contracting Plan. Generally, SBCPs are required for all federal contracts over $650,000.

The Principal Investigator:

  • Directs purchases that are consistent with the project budget and the approved SBCP.
  • Interacts with Procurement staff regarding progress toward achievement of Plan goals and reviews periodic reports about goals.
  • Provides an explanation when Plan goals are not achieved.


Project Closure

The Principal Investigator:

  • Prepares the final programmatic (technical) narrative report, which may include contributions by subrecipients or collaborators.
  • Submits any close out documentation needed in order for the PAF team to submit financial status reports on a timely basis.
  • Prepares and submits final invention statements, when required.
  • Provides information on other close out reports, such as for patents (to Office of Technology Management) and on equipment (to Capital Assets Management).
  • Retains the scientific data in accordance with the University’s Research Data Retention and Access policy (HOOP 92).


Regulatory Compliance and Ethics

Ethical conduct and adherence to the laws and regulations which apply to the University is the responsibility of each faculty and staff member. Personnel must be aware of the legal and ethical standards applicable to their job responsibilities and must perform duties and responsibilities in accordance with the provisions of federal and state laws; regulations and policies; the Rules and Regulations of the Board of Regents of the UT System; and the policies of UTHealth. The University's Standards of Conduct Guide details staff responsibilities for compliance.

The Principal Investigator:

  • Is responsible for adhering to all educational and training requirements as required by the University.
  • Adheres to protocols and policies for research subjects, and notifies CPHS or AWC if changes are made to protocols.
  • Meets continuing CPHS/AWC protocol review requirements and assists with inspections.
  • Adheres to chemical, biological, physical, and radiation safety requirements, and notifies the appropriate office if deviations or accidents occur.
  • Adheres to the policies and procedures for using investigational new drugs and/or devices for clinical research.
  • Ensures adherence to record retention policy for all financial and scientific documentation.
  • Takes responsibility for cooperating in the audit process, whether internal or external audit staff is involved.
  • Takes responsibility for accounting of PHI disclosures, as required by HIPAA.
  • Takes responsibility for understanding and compliance with all institutional and sponsor policies, practices, and procedures.

Please refer to the Conduct of Research (HOOP 168) for a comprehensive list of University policies governing research performed at UTHealth.