Roles and Responsibilities in Accountability and Compliance
Managing research funds is a significant responsibility which is shared by the University, the department and faculty where the award is administered, and you as the Principal Investigator and ultimate authority for approving expenditures.
As a Principal Investigator who is successful in securing funding for your research, you have primary responsibility for undertaking and directing activities to achieve your research objectives.
PI’s are not alone, however, in ensuring accountability and compliance in conducting research and spending research funds following sponsor and University guidelines. There are a number of policies, processes, and specific roles in place at the University to facilitate ethical, accountable, and transparent research.
Those involved in conducting research or facilitating research, including award establishment and day-to-day management and administration, fall into a fairly specific hierarchy of accountability with roles and responsibilities as outlined below:
Principal Investigator (PI)
Leads a research team to conduct research and research-related activities ethically and in compliance with policies, terms and conditions. The PI authorizes activity and expenses on a funded research project. Any delegation of authority in this regard can only be done by the PI.
The principal investigator is the signing authority on all approved expenditures for the research award and, accordingly, is ultimately responsible for ensuring that expenditures against the research fund:
- are in support of the research project named in the award
- occur within the award period
- comply with all terms and conditions of the award, including eligibility requirements set by the Sponsor
- comply with all applicable University policies including:
- represent the most effective use of the award funds
- do not exceed the available funds
Principal, Dean and Chair
Ensures that controls are in place and that they are operating effectively. They also provide assurance that University policies and procedures and terms and conditions set by the sponsors and donors are being followed.
As the person to whom the principal investigator directly reports, he/she:
- authorizes all travel planned by the principal investigator
- establishes effective review procedures in those cases where Chair approval is specifically required including:
- staff appointment forms
- expense reimbursements
- sets internal reporting procedures to ensure problems are identified and appropriate action taken with respect to:
- potential or actual funding deficits
- potential conflicts with award terms and conditions or University policy
Business Officer and Chief Administrative Officer (CAO)
Implements effective reporting system(s) and manages funds towards specific project goals. Also, reports problems and potential problems.
The Business Officer’s role in the management of award funds is defined by organizational decisions within the department but generally includes some or all of the following:
- organizing all relevant reference materials:
- Funded Research Digests (FReDs) or standard sponsor award notices
- sponsor guideline publications
- University policy and procedure manuals
- with reference to these materials, ensuring that relevant considerations are applied to decisions on hiring and purchasing
- consulting with University support offices as required
- processing purchases of goods and services authorized by the principal investigator
- alerting the principal investigator and/or chair to potential conflicts with award terms and conditions or University policy, which includes review for expense eligibility
- alerting the principal investigator and/or chair to potential or actual funding deficits
- ensuring all award expenditures are processed in the correct sponsor reporting period and, most critically, before the expiry date for the research funding. The Award End date can be found within the FReD.
- reviewing the monthly statement of account for completeness and accuracy.
It is important to note that the authorizing signature on an expenditure charged to a Restricted Research Fund indicates that all applicable University policies and regulations, and sponsor terms and conditions have been followed.
In addition, the originating department is responsible for reviewing to detect non-compliance such as:
- transaction documents generally provide very limited evidence in this regard
- central reviews could only take place after completing an already established legal commitment to an employee or University supplier — that is, it is past the point of effective financial control.
Vice-President, Research and Innovation
Staff in the VPRI division serve in an advisory role utilizing expertise to facilitate and reduce the administrative burden to permit research funded projects to be conducted. Staff also assist in ensuring that risk is mitigated to the highest possible extent.
As the research activity progresses, VPRI staff:
- assist fund managers with problem solving
- liaise with the sponsor where changes in budgets or clarification of terms is required (RSO / IPO)
- provide advice on the application of University policies, regulations and sponsor terms and conditions, when required (RSO / IPO)
- prepare funding invoices, financial statements, and coordinate audits (ROCO)
The hierarchy of accountability at the University of Toronto shows the detailed description of the roles and levels involved in the research administration.
Principal Investigators and Business Officers are required to complete an Annual Accountability Report, part of which includes certification that they have managed and administered research funds in compliance with formal University policies and procedures. It is one of the key accountability mechanisms the University relies on to ensure compliance with its policies. It is also one of the measures that the University can use to demonstrate to sponsors specific ways in which compliance and accountability are monitored. The University does not, however, provide copies of individual accountability reports to sponsors.
More detailed information on your responsibilities and the Annual Accountability Report can be found in the Guide to Financial Management.
The Financial services and Other Central Departments’ support are outlined in the Guide To Financial Management.
As you conduct research and collaborate with others outside of the University of Toronto, there may be occasion when there is an exchange of information or resources required. It is important to contemplate the terms and conditions under which that exchange or shared access to resources occurs. VPRI staff can answer questions or direct you to the right resource within the University when it comes to matters such as exchanging confidential information. While some of these matters are often covered in agreements for research between the sponsor and the University, and potentially the University and other institutions where your collaborators are located, there are a range of specific agreements available when such needs arise:
- Material Transfer Agreements
- Confidentiality Agreements
- Software Agreements
- Visiting Scientists Agreements
Agreements that fall outside of these areas (e.g. service or consulting agreements) are administered at the divisional level.
If you require guidance on which of the above agreements to use, or which may apply to you or your situation, please contact the VPRI’s Innovations & Partnerships Office for assistance.