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Compliance Grant & Contract Glossary

Signature Authority, Delegation of

The Principal Investigator is the individual responsible for meeting the objectives of a project. To facilitate efficient progress, the Principal Investigator may, at his or her discretion, delegate authority for initiating and approving the acquisition of goods and services necessary to complete project objectives. The initiation/approval process is the first step in a series of events to acquire goods and/or services for use on a sponsored project. Individual PIs or their units may, at their discretion, implement more stringent controls, such as authorization limits.

The following minimum criteria is essential when delegating this authority:

  1. The individual to whom the signature authority is delegated should have direct knowledge of the needs of the project.

  2. The delegation of signature authority must be made in writing, prior to any individual other than the PI initiating/approving acquisition of goods and services. The written documentation must be maintained at the appropriate organizational level, i.e., college, department, division, etc., where administrative/budget records are maintained for the budget number assigned to the sponsored project. One authorizing memo should be used for each budget number, unless the same delegation criteria and individuals are used among more than one budget number. For example, if a lab is supported by 5 sponsored projects, with essentially the same personnel working on all 5 projects, and the PI wishes to delegate the signature authority to the same individual(s) for each project, then one written delegation document is sufficient. The delegation document must be revised and updated as individuals and budget numbers change.

Note: As a reminder, the Principal Investigator may not delegate signature authority for the following:

  1. Approval of the quarterly Faculty Effort Certification (FEC) Reports. The FEC form is the university document that functions as a "time card" for faculty paid on research projects. Therefore, it is appropriate that only the faculty identified on the report document and certify the effort reported on the form. The Dean, Director, or Chairperson may sign in the absence of the PI.

  2. Approval for a federal budget receiving an expenditure transferred from another budget (Request to Transfer Expenditures, or RTE, or Retroactive Salary Transfer, or RST). These documents detail expenditures that were charged to incorrect, or inappropriate funding sources. It is critical, particularly for federally funded projects, that the PI take an active role in documenting the reasons why this occurs and in the correction of the charge. The Dean, Director, or Chairperson may sign in the absence of the PI.

  3. Approving a request to establish a departmental revolving fund or field advance. Since these actions result in cash being distributed on behalf of the sponsored project, it is critical that the PI approve this distribution, accepting overall responsibility for the safeguarding of the cash. The Dean, Director, or Chair may sign in the absence of the PI. The PI may delegate signature authority for initiating purchases for activities funded by revolving funds or field advances.

As an added control it is suggested that PIs, particularly if they have delegated authority to others, review the monthly Budget Activity Report (BAR), or other reports that serve the same purpose, for reasonableness and to detect errors and/or irregularities (fraud). PIs are further encouraged to sign or initial and date the reports as evidence of their review.

Examples which identify appropriate format for signature authority documentation are available in Grants Information Memorandum (GIM 14). Units may develop their own alternative formats or may develop thresholds for delegation providing the essential elements (grant name, budget number, Principal Investigator name, date, signature of delegees, signature of Principal Investigator) are included.

Compliance Grant & Contract Glossary