SUPERSEDES: GIM 14 (November 2010)
The purpose of this memorandum is to communicate the minimum standards whereby a named Principal Investigator (PI), or named Principle Investigators (PIs) for projects with multiple PIs, may appropriately delegate the authority to acquire goods and/or services with sponsored project funds.
NOTE: This policy does not apply to delegation of authority for approving personnel and payroll related items other than salary cost transfers (RST or OSET). Please contact the Payroll Department for further information.
Practices used in the past to delegate signature authority did not meet current audit standards. Practices used in prior years consisted of signature cards which were completed by PIs and returned and maintained centrally by the Accounting Operations Department. This written delegation of authority is now maintained at the unit level where sponsored project administrative/budget records are maintained. Signature cards are no longer maintained centrally.
The Principal Investigator is the individual responsible for meeting the objectives of the project. To facilitate efficient progress towards meeting project objective, the Principal Investigator may, at his or her discretion, delegate authority for initiating, approving the acquisition of goods and services, and the transfer of expenditures to sponsored projects under their direction. PIs may delegate signature authority to named individual and/or to specific position titles. 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.
Effective budgeting, appropriate expenditure procedures, and oversight should minimize the need to transfer expenditures. However, if expenditures do require transfer, the PIs may delegate the approval for the transfer of expenditures (see GIM 15, Transfer of Expenditure Between Budgets). Individual PIs or their units may, at their discretion, implement more stringent controls, such as authorization limits (See Attachment A).
The following minimum criteria are essential when delegating this authority:
The individual and/or position to which the signature authority is delegated should have direct knowledge of the needs of the project, i.e., how a specific purchase benefits or is needed by the project.
The delegation of signature authority must be made in writing or email prior to any individual or position other than the PI initiating/approving acquisition of goods and services. The written document or a copy of the email 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 or email should be used for each budget number unless the same delegation criteria and individual 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 signature authority to the same individual(s) and/or positions for each project, then one written delegation document or one email is sufficient. The delegation document must be revised and updated as individuals and budget numbers change.
Faculty may not delegate signature/certification authority for approval of their Faculty Effort Certification (FEC) Reports. Principal Investigators may not delegate signature authority for Grant and Contract Certification Reports (GCCR). The FEC and GCCR forms represent the University's method for complying with the federal requirements for certifying that payroll distributions represent a reasonable reflection of actual effort directed towards sponsored projects.
Where permitted, the Principal Investigator may delegate authority in writing or email to an individual to sign for expenditure transfers to or from another budget.
As an added control it is suggested that the PIs, particularly if they have delegated authority to others, review the monthly Budget Activity Reports (BARS), 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.
Please refer to the attached examples (A, B, C, D) which identify appropriate formats, although units may develop their own formats using alternative formats or thresholds providing the essential elements are included.
Questions concerning delegation of signature authority for sponsored programs should be directed to the Grant & Contract Accounting (GCA).