Roles & Responsibilities
- Perform scientific or technical work
- Ensure project work is conducted in an ethical manner and in line with applicable UH policies & procedures, governmental rules and regulations, and sponsor requirements
- Ensure safety and welfare of research subjects, personnel and the public
- Ensure propriety of project expenditures and procurement
- Certify cost share and effort reporting
- Comply with reporting requirements
- Comply with and respond to external audit requests in a timely manner
- Comply with and respond to periodic internal compliance review requests in a timely manner
- Perform analysis with ORS Form S-5 to determine that a subaward is appropriate, and retain the form in the project files
- Obtain all applicable items on the UH-issued Subaward Checklist from the subrecipient and comply with the UH-issued subaward process
- As applicable, approve substantive changes to the subaward in a timely manner
- Ensure subaward invoices are appropriate
- Conduct subrecipient monitoring, as applicable
- Advise PI on allowability, prior approval and procurement requirements and follow sponsor-approved budget
- Create procurement documents and authorize project purchases
- Maintain procurement records for inventory
- Review and authorize personnel forms (e.g., UH PNF, RCUH Attachment B)
- Ensure availability of project funds
- Ensure that project expenditures are recorded in the university financial system in a timely manner
- Review monthly Pcard logs and reconcile monthly ledgers to make sure expenses are allowable, and that there are sufficient funds in the account
- Approve Pcard expenditures
- Monitor continuation accounts and move expenses out in a timely manner
- Comply with and respond to external audit requests in a timely manner
- Review information received from subrecipients for completeness and accuracy
- Review substantive changes to the subaward and advise PI of any problematic financial issues
- Process encumbrances and payments to subrecipients
Chancellor / Dean / Director/ Chairperson
- Ensure PI’s compliance with all applicable regulations, policies, procedures, and award terms and conditions
- Ensure PI’s compliance with and timely response to external audits and periodic internal compliance reviews
Office of Research Services
- Provide technical advice regarding applicable UH policies & procedures, governmental rules and regulations, and sponsor requirements
- As the UH authorized organizational representative, act as institutional liaison for post-award changes requiring sponsor approval or modification
- Issue sponsor invoices on a monthly basis, or per sponsor requirements
- Request payment in sponsor electronic systems, as applicable
- Coordinate external compliance audits and perform periodic internal compliance reviews
- Coordinate special reporting requirements of federal agencies (e.g., ARRA, CARES)
- Subawards – As the UH authorized organizational representative:
- Perform risk assessment on subrecipient
- Prepare subaward and attachments once all required documents have been received
- Negotiate subaward terms and conditions with subrecipient, if necessary
- Formally acknowledge and accept UH-issued subawards
- Distribute copies of fully executed subawards to the subrecipient, PI and FA, as appropriate
Conflicts of interest
Conflicts of interest (COI) refer to situations in which a PI’s financial, professional or other personal interest may influence, or appear to influence, the PI’s judgment in fulfilling their responsibility to UH. UH has a responsibility to ensure that all extramurally-funded activities do not threaten the integrity of the university and its faculty’s activities.
PIs are responsible to file a COI disclosure at least annually. Any changes to previously made disclosures must be made within 30 days of the change.
For more information, see AP 12.304 or the ORC web page here.
Conflict of interest (COI) training must be completed at least once every four (4) years and immediately when:
- UH COI policies and procedures are revised;
- An investigator is new to UH or newly added to an ongoing United States Department of Health and Human Services Public Health Service (PHS)-funded research project; or
- An investigator is not in compliance with UH COI policies and procedures, or a COI management plan.
COI training is available through the Collaborative Institutional Training Initiative (CITI) COI module. Site access is provided with your UH username and password. If you do not have a CITI account, you may create one by affiliating with UH as your institution.
If you have any questions regarding COI disclosures or training, please email email@example.com.
Financial compliance / audits
PIs are responsible to inform ORS Financial Compliance at firstname.lastname@example.org of any significant problems which have the potential to impede attaining the goals of an award. Types of significant problems include adverse events, budgetary concerns, or unanticipated problems with facilities, personnel or laboratory resources. Information that ORS reports to the sponsor may include a description of the problem and any proposed solutions which may have received appropriate concurrence or approval from the provost, chancellor and/or Vice President for Research and Innovation.
As an entity that expends more than $750,000 in federal funds, UH is required to receive an annual Single Audit. The purpose of this audit is to provide assurance to the federal government that UH is capable of managing its federal awards in accordance with laws, regulations, policies and procedures, and award terms and conditions. ORS is responsible for coordinating audit requests between the external auditors and applicable UH staff. UH staff is responsible for fulfilling audit requests as soon as possible after receipt to ensure timely completion of the audit.
All extramural awards are subject to audit by sponsors upon request. Any request for sponsor audit or visit should be emailed to ORS Financial Compliance at email@example.com. As the authorized organizational representative for UH, ORS will be the primary contact to the auditors. ORS will work with the PI if a PI’s input or response is required by the sponsor.
PIs should work with their FAs to conduct a reconciliation of project accounts at least every month with the following in mind:
- All expenditures must support the purpose of the award, and be allowable, reasonable and allocable.
- All outstanding charges and committed expenses should be reviewed to ensure there are sufficient account funds and to avoid overcommitment of funds (i.e., expenditures exceed the total award amount).
- Payroll and other expenses should be appropriately charged.
- Missing expenses or discrepancies should be resolved in a timely manner so the project account always reflects the most current transactions.
If there are any budget changes that require sponsor approval, the PI should contact their assigned ORS Pre-Award Specialist.
All project accounts with end dates require a continuation account. All expenditures charged to a project account beyond 30 days after the end date will be automatically booked to the continuation account.
Continuation accounts should be set up as clearing accounts. FAs are responsible to monitor them regularly and transfer expenditures to the appropriate project or other operating account in a timely manner. Use the General Error Correction (GEC) document to transfer non-labor transactions, and the Salary Transfer (ST) document to transfer labor transactions.
If an award requires cost sharing, a cost sharing subaccount will be set up in the university financial system and cost sharing reporting done through a Distribution of Income and Expense (DI) eDoc. PIs should work with their FA to ensure cost sharing is properly recorded.
Treatment of Costs
- Cost sharing for direct costs should be recorded when the direct expenses are recorded in the source account.
Salary and Fringe
- Cost sharing for UH personnel salaries and fringe should be based on the pay period or service date, and must be recorded in the proper fiscal year in order for the year-end cost sharing certification report to generate properly.
Unrecovered Indirect Costs, External Support and Tuition Waivers
- Unrecovered indirect costs, external support and tuition waivers will be recorded to the cost sharing subaccount via DI, regardless of the period. Best efforts should be made to record the applicable cost sharing in the period when the expense is occurred.
See Cost Sharing for more information.
PIs should familiarize themselves with UH and RCUH procurement policies and procedures, and any applicable federal regulations governing their award, including the Uniform Guidance (2 CFR 200). PIs should also work with their FAs to ensure that proper campus procedures are followed, and that all procurement expenditures are allowable, reasonable and allocable.
Types of Procurement
- Competitive procurement: For federal awards, unless otherwise authorized, procurement is to be done on a competitive basis. Depending on the dollar amount, verbal or written quotations are required to support Cost or Price Reasonableness, and should be recorded and retained as support for the procurement action. (See AP 8.285, and applicable RCUH policies, including 2.103, 2.104 and 2.110.)
- Sole source procurement: When there is only one source available from which particular goods or services may be obtained, purchases from qualified vendors may be made without soliciting competitive quotations if certain criteria are met and proper justification provided. (See AP 8.255 and applicable RCUH policies, including 2.106 and 2.110.)
- Professional services: Professional services generally include services within the practices of architecture, professional engineering, land surveying, real property appraisal, law, medicine, accounting, and other areas defined as “professional” by Hawaiʻi law, or included in the “professional and scientific” occupation series in the United States Office of Personnel Management’s Qualification Standards Handbook. Professional services must be procured as set forth in AP 8.245, and applicable RCUH policies, including 2.105, 2.110, 2.209, and 2.210.
- Emergency procurement: Normal procurement procedures may be suspended for the purchase of goods or services in emergency situations as defined in and subject to the provisions of AP 8.260 and applicable RCUH policies, including 2.108 and 2.110.
- Exempt procurement: Certain procurements are exempt from source selection. Cost or price reasonableness analysis still applies to exempt procurements. (See AP 8.220, Item 9 and RCUH policies 2.107 and 2.110.)
UH Office of Human Resources (OHR) positions
Staff who will work directly on the project may be hired through OHR using project funds provided they were included in the project budget. Hiring must be conducted in accordance with all applicable employment laws, policies and procedures. PIs should contact their unit’s personnel officer for applicable hiring policies and procedures.
Types of Appointments
Researchers and program administrators who work directly on the project may be classified as Faculty; Graduate Assistants; or Administrative, Professional and Technical (APT). These individuals may already be working on campus in some capacity. As a general rule, staff who provide general administrative services to an entire department may not be hired using project funds as they are considered indirect costs.
- Existing employees: To place an existing employee on a project as part of their regular workload, PIs should have their personnel officer generate a Payroll Notification Form (PNF). The existing employee may also be placed on an overload appointment if work is being performed in addition to their regular duties. Make sure to obtain prior approval from the employee’s supervisor and convert the time to be spent on the project to full-time equivalent (FTE) format. PIs should consult with their personnel officer for further information.
- New employees: To hire new staff through the UH Office of Human Resources, PIs may have to establish a new position and include information such as duties, educational requirements, and skills. PIs should work with their personnel officer to determine the appropriate career group, pay and level. Once the new position is established and approved, it must be advertised for at least ten (10) business days. It could take more than a month from establishing the position to getting someone on board, so it is best to start early.
- Graduate assistants: PIs should consult with their personnel officer regarding the recruitment and hiring of graduate assistants (GAs). After a candidate has been selected, a PNF must be processed through the appropriate college and forwarded to the Graduate Division for approval.
- Casual hire: If project staff is needed on an intermittent or short-term basis, a person who is not currently employed by UH may be hired into a limited term, casual appointment. In general, a casual hire will work 20-40 hours per week for 89 calendar days, or less than 20 hours per week for up to 12 months. A casual hire is not entitled to any fringe benefits, e.g., sick or vacation leave, holidays or health coverage.
Research Corporation of the University of Hawaiʻi (RCUH) positions
RCUH has recruited and non-recruited hires. Most regular status positions, including visiting appointments, must be openly recruited. Non-recruited hires are generally short-term hires. They do not require a recruitment process, so a contingent job offer may be made without RCUH approval. All hiring must be conducted in accordance with all applicable employment laws, policies and procedures. PIs should contact their unit’s personnel officer for applicable hiring policies and procedures.
Types of Non-Recruited Hires
- Intermittent hire: An hourly-paid employee hired to work on an on-call, as needed basis.
- Student assistant: An employee who is enrolled as a student in a school, college or university in a degree program, and generally works 20 hours or less per week [50% full-time equivalent (FTE)] while school is in session.
- Temporary hire: An employee hired at an FTE for a period not to exceed 20 weeks within a one-year period, irrespective of the number of temporary positions hired.
PIs should review their award terms and conditions to ensure that all sponsor reporting requirements are complied with. In general, PIs are responsible to submit progress, performance, scientific and technical reports to the sponsor, and for retaining documentation of timely report submission (e.g., print screen from the sponsor’s system or email from the sponsor confirming submission). For other types of reports, the PI should coordinate with the following offices:
|Type of report||Office / Section|
||Capital Asset Accounting Office|
PIs are responsible for fulfilling all research compliance requirements relating to their extramurally-funded project, including requirements related to research involving human participants, human subjects, or biomaterials. PIs must also ensure that all required approvals and related documentation have been obtained from the subrecipient prior to commencement of any these activities, and such documentation provided with the applicable program committees for human subjects, animal subjects and biosafety.
- The PI should review, complete and obtain all items listed in the UH-Issued Subaward Checklist.
- The complete packet should be emailed to firstname.lastname@example.org, one email per subaward requested.
- ORS will perform the risk assessment of the subrecipient (required by 2 CFR 200.331), then prepare the subaward once all required documents are received, and send it to the PI for approval, with a copy to the FA.
- Any desired changes must be identified to ORS within five (5) business days of receipt by the PI and FA.
- Once agreement is reached with the subrecipient and all compliance issues are resolved (e.g., subrecipient tax clearance), ORS will sign the subaward and email the fully-executed copy to the PI, FA and subrecipient.
- The PI should review, complete and obtain any required items listed in the Subaward Amendment Request form.
- The complete packet should be emailed to email@example.com, one email per amendment requested.
- ORS will prepare the amendment once all required documents are received, and send it to the PI for approval, with a copy to the FA.
- Any desired changes must be identified to ORS within five (5) business days of receipt by the PI and FA.
- Once agreement is reached with the subrecipient and any compliance issues are resolved (e.g., subrecipient tax clearance), ORS will sign the amendment and email the fully-executed copy to the PI, FA and subrecipient.
An infographic of the subaward process flow is posted here, and more details are posted here.
The status of subawards and amendments may be checked at any time using the Subaward Status Log.
As a pass-through entity, UH must monitor the activities of its subrecipients to ensure that subawards are being used for authorized purposes (see 2 CFR 200.331). ORS is responsible for general oversight of UH’s subrecipient monitoring program and performing additional monitoring activities as deemed necessary. ORS is also responsible for issuing a management decision for audit findings provided to the subrecipient from UH and verifying that every subrecipient is audited as required by federal law (see 2 CFR Subpart F).
The PI, with their FA’s assistance, has the primary responsibility for performing subrecipient monitoring, including:
- Reviewing subrecipient invoices and validating or denying questionable expenditures;
- Reviewing financial reports from the subrecipient to ensure that funds are being used for their authorized purposes;
- Reviewing performance reports from the subrecipient to ensure that performance goals are being achieved;
- Following up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies identified through audits, on-site reviews or other means;.
Any deficiencies or instances of noncompliance should be reported to ORS immediately at firstname.lastname@example.org.
Based upon the level of risk posted by the subrecipient, to ensure proper accountability and proper compliance with program requirements, UH may also use monitoring tools such as:
- Providing subrecipients with training and technical assistance on program-related matters;
- Performing on-site reviews of the subrecipient’s program operations or “during the award monitoring” reviews; and/or
- Arranging for agreed-upon procedures engagements under 2 CFR 200.425(c).
For new awards or increments meeting specific criteria* issued on or after December 26, 2014:
- “Uniform Guidance” (2 CFR 200) – Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards
For all other awards and increments – Office of Management and Budget Circulars:
- A-21 (2 CFR Part 220) – Cost Principles for Educational Institutions
- A-110 (2 CFR Part 215) – Uniform Administrative Requirements for Grants and Other Agreements with Institutions of Higher Education, Hospitals and Other Non-Profit Organizations
- Single Audit – Audits of States, Local Governments and Non-Profit Organizations
* The Uniform Guidance applies to increments to existing awards issued on or after December 26, 2014 if the federal sponsor modified the terms and conditions of the incremental award, or did not specifically reference the above OMB Circulars in the existing award.
Fiscal Accounting / Procurement
- Procurement Overview (Office of Procurement)
- Procurement Information (Office of Export Controls)
- Foreign Influence in University Research
- International Travel Information
- University of Hawai‘i Global Sponsored Activities Guide
- Initial Subaward – complete UH-issued Subaward Checklist
- Subaward Amendment Request
- Subaward Status Search (log in with UH username)
- Assigned ORS Contract Specialist
Process & Procedure
All other forms may be found in the “Subrecipient Forms” section on the ORS web page here.
RCUH (Research Corporation of the University of Hawaiʻi)
Policies & Procedures
|RP 12.205||Patent and Copyright Policy|
|RP 12.211||Ethical Guidelines in the Conduct of Technology Transfer Activities|
|EP 5.223||Graduate Assistants|
|EP 12.205||Administration of the Patent and Copyright Policy|
|EP 12.214||Conflicts of Interest and Commitment|
|AP 5.500||Procedures for Invention Identification, Disclosure and Reports Under State Funding|
|AP 5.501||Procedures for Copyrights of Work Produced For Hire|
|AP 5.502||Procedures for Invention Identification, Disclosure and Reports Under Extramural Contract Patent Clauses|
|AP 5.504||Procedures for Disclosing and Addressing Conflicts of Interest and Commitment|
|AP Ch. 8||UH Business and Finance Administrative Procedures|
|AP 8.926||Administrative and Financial Management Requirements for Extramurally Financed Research and Training Programs/Activities of the University of Hawai‘i|
|AP 12.304||Procedures for Disclosing and Addressing Conflicts of Interest Related with Extramurally-Funded Activities|
|AP 12.410||Accounting for Cost Sharing|
|AP 12.411||Subrecipient Monitoring|