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  • 1.  Designating AOR who has no signing rights for the organization

    Posted 3 hours ago

    Hello all,

    I work in a Finnish university (Aalto University) where decision-making and authority to legally bind the university is vested with the academic leaderships (department heads, deans etc.). This works well with our national and EU funding systems but we are running into issues when working with US federal funding. The AOR role is also vested with these academic leaders and since each department doesn't have very many proposals, these busy leaders need often guidance on how to use the systems (e.g. grants.gov, ERa Commons) and there is also the matter of their schedule to worry.

    We have noticed that US universities often have research office personnel as AOR submitting the proposal or reports, and we would like to move to this direction. However, in our discussion with our legal counsels, the issue about signing authority of the AOR was raised. So, I thought I'd few questions about this from the best experts.

    1) Does the AOR submitting proposals and reports in federal funding systems need to be able to legally bind the organisation and sign on its behalf?

    2) Can the right to submit proposals and reports be delegated to a research office member (but not the right to sign / bind legally / make decisions), so that they can submit after the person with the authority has given confirmation in our management system that the submission is ok?

    3) If delegation is possible, what sort of documentation is required? Is an internal decision signed by the university leadership ok?

    If anyone has advice, I'm very grateful. If we can do this, it will simplify ours and our leadership's life.

    Best regards,

    Petri



    ------------------------------
    Petri Kanninen
    Research Liaison Officer
    Aalto University
    Espoo
    +358503556869
    ------------------------------


  • 2.  RE: Designating AOR who has no signing rights for the organization

    Posted 2 hours ago

    Hello Petri,

     

    With respect to your specific questions:

     

    1. Does the AOR submitting proposals and reports in federal funding systems need to be able to legally bind the organization and sign on its behalf?

    At our institution, yes. Individuals registered as AORs are designated because they possess authority to act on behalf of the institution and legally bind the organization when required. Institutional leadership formally delegates this authority and documents it through policy.

    1. Can the right to submit proposals and reports be delegated to a research office member (but not the right to sign, legally bind the organization, or make institutional decisions)?

    Potentially, depending on the sponsor's requirements and the institution's internal controls. In practice, many institutions allow research administration staff to prepare submissions and route them through internal approval systems. However, the actual submission in federal systems is often limited to individuals designated as AORs. If a research office staff member were granted submission access without independent signature authority, the institution would need a clear process documenting that all required approvals were obtained before submission.

             3.   If delegation is possible, what documentation is required? Is an internal decision signed by university leadership sufficient?

     

    Generally, delegation should be documented through a formal institutional policy, delegation-of-authority memorandum, or other written authorization approved by university leadership. The documentation should clearly define:

    • Who is authorized to submit proposals and reports.
    • The scope and limitations of that authority.
    • Required institutional approvals prior to submission.
    • Any responsibilities retained exclusively by Authorized Officials.

     

    An internal delegation document approved by university leadership may be sufficient from an institutional perspective, but requirements can vary by sponsor and funding system. Therefore, it is important to confirm sponsor-specific requirements before implementing such a delegation model.

    We have found that maintaining clear written delegations, internal routing and approval processes, and limiting legal signature authority to designated Authorized Officials provides strong oversight while allowing research administration staff to efficiently support the submission process.

     

    Best regards,


    Renee Raines

    Renee Raines, MHA, CRA, CCRP
    Assistant Dean, College of Medicine

    University of Arkansas for Medical Sciences
    4301 W. Markham St., #550

    Little Rock, AR 72205-7199
    Main: 501-526-6940; Mitel: 48013
    Email: renee@...

     



    UAMS.edu | UAMSHealth.com

     

     






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