Stewardship and Compliance
for Stanford PIs



See related discussion of reporting requirements in Section 3 of Stanford policy, Fiscal Responsibilities of Principal Investigators.
Ongoing communication between the PI and the sponsor is a critical component of sound fiscal management. Such conditions as rebudgeting requests, no-cost extensions, or considerations related to the scope of the project warrant communication in writing, with a copy retained in the project file.

In additions, regulations applicable to different types of projects REQUIRE written notification or prior approvals in the following situations.

FOR FEDERAL GRANTS: Changes in PI Status
OMB Circular A-110 requires prior written approval from the sponsor for either of the following circumstances involving the Principal Investigator or approved Project Director:
  1. A reduction in time devoted to the project of 25% or more from the proposed and awarded level

  2. An absence from the project for more than three months.
For example, if your project is awarded with a commitment of 50% of your effort, and you decide to reduce that to 30%, that reduction is more than 25% from the awarded level and would require advance notification and approval.

If, in the original award, Stanford had committed to fund some of this effort as cost sharing, the Office of Sponsored Research (OSR) will also negotiate reductions in levels of the cost-shared component of effort, as appropriate.

In addition, when a PI's faculty appointment will terminate prior to or during a project's period of performance, the sponsor is so informed by OSR.

Circular A-110 also requires prior approvals from the sponsor in the following circumstances:
  • change in the scope or the objective of the project or program (even if there is no associated budget revision)

  • change in a key person specified in the application or award document

  • need for additional Federal funding

  • transfer of funds allotted for training allowances (direct payment to trainees) to other categories of expense.

FOR FEDERAL CONTRACTS: Limitation of Funds/Limitation of Cost clauses

In the case of federal cost-type contracts (as opposed to grants), PIs must comply with the Limitation of Funds and/or Limitation of Cost clauses which include the requirements that:
  1. the Contractor notify the sponsoring agency in writing at any time that there is reason to believe the total cost to the Government for the performance of the project will be greater or substantially less than the estimated cost, and further,

  2. the Contractor notify the sponsoring agency if, at any time, there is reason to believe that the costs which are expected to be incurred in the next succeeding 60 days, when added to all costs previously incurred, will exceed 75% of the specified estimated cost.
Failure to provide such notice may preclude Stanford from receiving additional funding on that contract. (See sample notification letter.)

These notifications are intended to allow sufficient time to arrange for and process additional funds, or for the reduction in spending and effort in order to phase out the program in an orderly fashion if additional funds are not available. The Principal Investigator's Department Chair and School Dean should also be informed, in advance, of potential funding problems.

In the case of grants, similar restrictions often apply and appear in the grant award itself or in the accompanying agency policy manual or administrative guide. Check the terms of your particular award.

In all cases, notifications of contract or grant status, including those described above, must be made in writing to the administrative official in the sponsoring agency. Such notifications must be coordinated through the Office of Sponsored Research.
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