CPI Project Management & Funding 3 — Questions and Answers
Question 1: A subrecipient on a federal grant fails to submit required financial reports. Who bears primary responsibility for monitoring subrecipient compliance?
- The federal program officer
- The PI as pass-through entity representative (Correct answer)
- The subrecipient's own IRB
- The Office of Research Integrity (ORI)
Correct answer: The PI as pass-through entity representative
Under 2 CFR 200.332, the pass-through entity (and the PI as its representative) is responsible for monitoring subrecipient performance and compliance.
Question 2: A PI discovers mid-project that a co-investigator must reduce effort from 20% to 5% due to a competing obligation. What must occur if the sponsor requires prior approval for significant changes?
- Notify only the department chair
- Submit a prior approval request to the sponsor before the change takes effect (Correct answer)
- Document the change in the final progress report only
- Immediately replace the co-investigator without notifying the sponsor
Correct answer: Submit a prior approval request to the sponsor before the change takes effect
Most federal sponsors require prior approval for significant reductions in key personnel effort, typically defined as a 25% or greater reduction from the committed level.
Question 3: Which financial management principle requires that expenditures on a grant be reasonable, allocable, and consistent with the project's scope?
- Cost sharing compliance
- Cost allowability standards under 2 CFR 200 (Correct answer)
- Uniform Guidance procurement rules
- Effort reporting regulations
Correct answer: Cost allowability standards under 2 CFR 200
2 CFR 200 establishes that allowable costs must be reasonable, allocable to the project, and consistent with applicable policies and award terms.
Question 4: A PI receives a clinical trial industry contract specifying a fixed price per-patient payment. How should unspent funds at study closeout typically be handled?
- Returned to the sponsor per contract terms (Correct answer)
- Transferred to an NIH grant automatically
- Retained by the PI as a discretionary fund
- Split equally between the PI and institution
Correct answer: Returned to the sponsor per contract terms
Industry-sponsored clinical trial contracts typically require any unspent funds at closeout to be returned to the sponsor unless the contract states otherwise.
Question 5: A PI is planning a grant-funded international conference trip. Which of the following must be complied with for federally funded travel?
- The Fly America Act, requiring use of U.S.-flag air carriers (Correct answer)
- Advance booking at least 90 days prior
- Use of the institution's preferred hotel chain only
- State Department approval for all international travel
Correct answer: The Fly America Act, requiring use of U.S.-flag air carriers
The Fly America Act (49 U.S.C. 40118) requires that federally funded international travel be conducted on U.S.-flag air carriers unless a specific exception applies.
Question 6: A PI receives an unfavorable peer review score but receives written encouragement from the program officer. What is the most appropriate next step?
- File a formal appeal with the agency's Office of Inspector General
- Contact the program officer to discuss resubmission strategy and address reviewer critiques (Correct answer)
- Submit the same application without changes to a different study section
- Withdraw from future grant competitions at that agency
Correct answer: Contact the program officer to discuss resubmission strategy and address reviewer critiques
Following reviewer critiques and consulting with the program officer is the standard strategy for improving and resubmitting an unfunded application.
Question 7: Cost sharing that is voluntary committed in a proposal becomes binding. What is the primary risk if the PI fails to meet that commitment?
- The PI must personally reimburse the institution
- The institution may be found in noncompliance, jeopardizing future funding (Correct answer)
- The IRB will suspend the study
- No risk — voluntary cost sharing is non-binding by definition
Correct answer: The institution may be found in noncompliance, jeopardizing future funding
Once voluntary committed cost sharing appears in an approved award, it becomes an obligation; failure to meet it constitutes noncompliance that can affect the institution's funding relationship with the sponsor.
CPI Project Management & Funding 3
A subrecipient on a federal grant fails to submit required financial reports.
Who bears primary responsibility for monitoring subrecipient compliance?