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What are my responsibilities as PI?

The PI must work with their academic department to meet the obligations and responsibilities of managing funds. The PI’s responsibilities include:

1. Accounting for the spending of sponsored award funds with the assistance of the Department Administrator.

The Medical College of Wisconsin, as a recipient of federal funds, must comply with OMB Circular A-21 “Cost Principles for Educational Institutions”. A-21 incorporates Cost Accounting Standard (CAS) 501, which requires that the College’s methods for estimating costs in pricing a proposal be consistent with the College’s practices for accumulating and reporting costs in the accounting records.

The principal investigator and department are responsible for preparing the proposal budget in a manner that complies with OMB Circular A-21 and CAS 501 requirements, which includes submitting a proposal budget with line items that are consistent with the Expenditure Types available in the College’s accounting system and that represents the best estimate of actual costs to be incurred in performing the sponsored project.

Through the use of Expenditure Types the principal investigator and department administrative staff are responsible for recording expenditures in the College accounting system at a level which provides a meaningful comparison for any significant amount of estimated cost in the proposal budget.

2. Comply with all funding regulations and terms and conditions of each award

With the assistance of their Department Administrator and the Office of Sponsored Programs, the PI is required to stay in compliance with regulations on allowable expenditures, carryforward of unobligated balances, close out of funds, timely reporting and other terms and conditions set forth in the award.

3. Give special attention to monitoring the following:
   1. Cost Sharing
      The policy of the College is to include cost sharing in a proposal only when required by the funding agency or necessary to improve the proposal’s competitive position.
      
      The principal investigator is responsible for insuring that Cost Sharing Commitment Forms from each contributing department are included in the proposal package submitted to the Office of Grants and Contracts. The Cost Sharing Commitment Forms require approval by the Department Chair or authorized designee.
       
   2. Effort Reporting
      Effort as defined by the federal government and the College is time an individual spends on an activity, expressed as a percentage of the total time an individual devotes to MCW compensated professional activity. Total effort cannot be more or less than 100% and is not based on a 40-hour workweek.
      
      A person’s total percent effort includes effort committed to externally sponsored projects (including effort funded by the sponsor and effort supported by cost sharing), internally sponsored projects, teaching, patient care, community engagement, administrative activities, and/or other contributed effort.
      
      Once the award is funded, a determination must be made as to whether the proposed level of effort commitment is appropriate and the salary distribution is consistent with the committed effort. If the level of effort for key personnel needs to be adjusted by more than 25% based on the percent effort indicated in the original accepted budget and noted in the NOA, the sponsor must be notified of the level of effort change. If the percent of effort devoted to the award is greater than the salary support contributed by the sponsor, a Cost Sharing Commitment Form must be completed. The percent total of all salary allocations for an employee must equal 100%.
       
   3. Cost Accounting
      The Medical College of Wisconsin, as a recipient of Federal funds, must comply with OMB Circular A-21, “Cost Principles for Educational Institutions.” These regulations incorporate Cost Accounting Standard (CAS) 502, which requires educational institutions to ensure that costs incurred for the same purpose in like circumstances are treated consistently. CAS 502 is intended to prevent the overcharging of costs to Federally sponsored projects.
      
      The College has developed a policy for proper charging of sponsored award funds. Included in the policy is a discussion on Allowable costs, Unallowable costs, Normally direct costs, the Allocation of direct costs among multiple sponsored agreements, Normally indirect costs, and Charging normally indirect costs as direct costs. These rules are also referred to as Cost Accounting Standards.