VII.
Pre-Award Activities: Proposal Preparation
& Submission
A. Overview
Faculty planning to apply for external funding
have much to consider. Some of the most
commonly asked questions are: What funding
sources are available? With what University
policies must proposals comply? How is a
budget developed? By what process do potential
grantees receive University approval of
their proposals? How long is the proposal
approval process?
To assist faculty in preparing and submitting
proposals, the Office of the Vice President for Research (OVPR) divides the
proposal process into stages: development,
preparation, approvals, processing, and
negotiations. During each of these stages,
the principal investigator (PI) must take
into account certain University policies
and procedures. This section describes the
policies, which governs each stage of the
process, along with procedural guidelines.
In addition, OVPR has included policies
and procedures governing two special cases:
industry-sponsored clinical trials and sub-contracts.
B. University
Policy on Submitting Proposals
OVPR is responsible for submitting
all proposals for grants and contracts for
research and other scholarly activities
to public agencies (federal, state or local
government), private non-profit research
organizations and industries. The Sponsored
Projects Administration (SPA) in OVPR
assists investigators in preparation and
submission of all proposals. Except for
certain fellowships awarded directly to
individuals, PI's or program directors may
not apply for, or receive, funding directly
from sponsoring organization's without receiving
University approval. ALL PROPOSALS MUST
BE PROCESSED THROUGH OVPR AT EITHER
THE MAIN CAMPUS OR THE HEALTH SCIENCES CENTER
(HSC).
OVPR also works closely with the
Office of Development and Alumni/ae Affairs
(ODAA) to help secure funding for the University.
OVPR is responsible for assisting
faculty in locating corporate and foundation
support for sponsored activities. ODAA is
responsible for the solicitation of private
sector development funds from corporations,
foundations, associations, and individuals.
Therefore all proposals for sponsored projects
to private foundations and corporations
must receive approval from both OVPR
and ODAA.
C. Proposal Development
One of OVPR's primary functions
is to assist faculty in identifying potential
external funding sources, although faculty
and researchers may also discover potential
funding sources by other means. As faculty
identify such sources and begin to formulate
proposals, they may want to take advantage
of certain OVPR services.
The investigator is fully responsible for
the preparation of all applications for
support of research or scholarly activity,
always keeping in mind adherence to the
specific instructions provided by the particular
funding agency. SPA can provide interested
faculty with agency guidelines and application
forms. OVPR may be able to assist
the investigator in identifying a key contact
person at the funding agency. Please note,
because ODAA is charged with negotiating
with private foundations and corporations,
that office must be notified if a foundation
or corporation is to be approached as a
potential funding source.
While investigators must first ensure that
the proposals satisfy funding source requirements,
they must also fit proposals to certain
criteria established by OVPR. To
help investigators meet these criteria,
SPA offers assistance in preparation of
all necessary forms, representations, certifications,
assurances, and other non-technical data.
Investigators are invited to contact SPA
directly to discuss proposals under development.
Because the criteria for contracts are often
more complex than for grants, investigators
considering these types of proposals are
particularly urged to contact SPA.
On certain projects, investigators may
want to consider working with collaborators
to enhance the scope and quality of the
proposal. OVPR can assist investigators
in identifying potential collaborators with
expertise in their area.
D. Proposal Preparation General Information
SPA must approve all proposals before it
submits them to the appropriate external
funding agencies. SPA approval hinges on
its receipt of both a completed proposal
and a completed Sponsored Projects Approval
Form (SPAF) from the investigators (Appendix
A). In order for the full proposal to be
reviewed, approved and submitted by the
deadline, the SPAF must:
-
contain
all required signatures, including
those of the appropriate Department
Chair and Dean. Therefore, investigators
are encouraged to contact the Department
Chair and/or Dean as early as possible
in the proposal preparation process,
particularly when proposals include
matching resources, release time,
additional space, renovations, or
other requirements needing department,
college of school or University approval;
-
arrive at SPA
no later than ten working days prior
to the deadline date of the proposal.
Additional time should be allowed
for proposals involving special clearances,
such as for human subjects or animal
care. Also, allow extra time for contracts,
because they may require additional
review by SPA. Due to the high volume
of proposals submitted by the University,
SPA cannot guarantee that a proposal
received less than ten working days
before the deadline will be submitted
to the funding agency on time.
When preparing the proposal, the PI should
also note the following general guidelines:
-
because
most agencies want one individual
to serve as contact point for day-to-day
administration of an award, when co-investigators
are involved, one party should be
named PI;
-
agency funding
decisions may take more than nine
months. Investigators and project
directors should anticipate such waiting
periods and plan their efforts accordingly.
Budget Preparation
Upon identification of a potential funding
source and formulation of a proposal, SPA
determines that the investigator should
develop a budget. Based on the criteria
that SPA uses to prepare and evaluate proposal
budgets, it established some general guidelines
for investigators. Proposal budgets should
include at a minimun:
- all appropriate direct costs items;
- correctly applied fringe benefit
and indirect cost rates; and
- funding source requirements.
Furthermore, the budget should conform
with one of the budget category patterns
currently available in the University's
Financial Management System (FMS). A summary
of FMS Budget Categories is listed in Appendix
E. SPA recognizes that agency requirements
do not always permit an exact correlation
between FMS account numbers and their budget
categories. However, investigators are encouraged
to discuss individual issues with their
department administrator or SPA staff.
The budget should contain separate figures
for University contributions and funds being
requested from the agency. Should an award
be forthcoming, investigators must inform
all appropriate administrative offices of
the University's obligations.
Budgets may not be presented to a funding
agency without appropriate review by SPA.
Therefore, PIs or and/or financial officers
should consult SPA early in the proposal
development process to ensure preparation
of an accurate budget. Upon receipt of the
SPAF, the completed proposal and properly
signed budget, SPA commences with internal
approval of the project.
Budget Specifics
Investigators preparing proposal budgets
should consider the following specific policies
and procedures:
–
Personnel
The University encourages the use of external
support for academic year (nine or ten months)
faculty salaries. Salary support received
for sponsored activities conducted during
the academic year may result in release
time from teaching or service activities.
Faculty members are asked to contact their
departmental chair and Dean early in the
planning stages of their proposal to discuss
release time.
Depending on the sponsoring agency's regulations
and approval of the Dean, University faculty
on academic year appointments may earn additional
compensation above base salary during the
academic year (see Faculty Guide for details).
During the summer months, faculty on academic
year appointments may receive additional
salary from a sponsored project. The monthly
rate cannot exceed the applicable base salary
(1/9 of the academic year salary for each
of the summer months: June, July, and August).
The salary from the prior academic year
determines summer compensation. Faculty
must obtain permission from the appropriate
Dean and Department Chair to teach during
the summer sessions in addition to fulfilling
a commitment to the sponsored activity.
Faculty who choose to use their external
support for summer salary only are not entitled
to release time during the academic year.
The Personnel category should include all
individuals necessary to conduct the proposed
sponsored activity. The category should
list the names of all personnel involved
directly in the project; proposed, but unfilled,
position titles; individual percentage of
time devoted to the proposal; and applicable
salary and fringe benefit rates.
–
Compensation
Compensation includes salary/wages and fringe
benefits that an employee receives for their
efforts on behalf of the University. University
employees are eligible for compensation,
which is an allowable direct charge to the
project, for all time and effort devoted
to a sponsored project.
–
Salary
Salary charges should be based on the same
rate of pay as the individual's other University
work. Salaries paid to persons hired exclusively
for work on sponsored projects may not be
materially different from those paid to
other persons in the University with similar
qualifications for similar work. Salaries
proposed in project budgets for each position
are not guaranteed amounts. Actual salaries
are subject to approval by the Office of
Personnel Services (OPS).
–
Percentage of Effort
The percentage of effort that a faculty
member commits must be equal to or greater
than the percentage of total salary drawn
from project funds. The work schedule must
be adjusted so that total effort does not
exceed 100% of available time.
Individual colleges/schools may require
faculty to devote a specific amount of time
and effort to scholarly activities with
appropriate salary recovery to be included
in the proposal. The maximum level of support
on sponsored activities should not exceed
90%. Funding agencies assume that all investigators
have at least some administrative or teaching
responsibilities at their institution.
Many external agencies require effort reporting.
Effort reporting does not correspond to
a specific number of hours worked. Any additional
pay for a faculty member must be approved
by the appropriate Dean, or in the case
of certain Center Directors, by OVPR.
–
Graduate Assistant Compensation
Compensation to graduate assistants involved
in sponsored projects should be assessed
at the same rate as compensation to graduate
assistants assigned to academic departments
within the same discipline. During the academic
year, graduate assistants are considered
full-time if they work fifteen weeks per
semester and twenty hours per week. During
the summer months, graduate assistants may
work more than twenty hours, but should
not exceed forty, if course work and research
permits.
The Graduate School, or the student's college/school,
may contribute graduate tuition support
on sponsored activities. The student's particular
department may also contribute funds when
full overhead is received, the overhead
received exceeds tuition, or when the college/school
has recovered costs available to the departments.
SPA must approve these cases. Please contact
OPS for the minimum amounts for graduate
assistantship stipends.
–
Part-time Staff
Part-time staff is defined as staff working
less than thirty-five hours per week. Some
part-time employees may be eligible for
benefits depending upon the bargaining unit.
Rates for part-time employees should be
consistent with University rates. Please
check with SPA for current rates.
–
Fringe Benefits
Budgets must include fringe benefits as
direct costs to all sponsored projects.
If they are full-time, employees on sponsored
projects are eligible for University benefits.
A full-time appointment for faculty is defined
as 80% effort for at least one academic
year; for most part-time staff and faculty,
the fringe benefit rate is 8%. Post-doctoral
employees do not receive full fringe benefits.
–
Hiring Staff
The PI should submit a HRS Employee Requisition
and HRS Position Questionnaire Form (Appendix
D) for classification of each proposed position
at the time of the grant or contract submission.
Some standard position descriptions are
available through OPS. OPS classifies and
recruits for positions when an award is
made. The hiring of full-and part-time staff
on a sponsored activity follows the procedures
and receives the approvals of OPS just like
regular university hires excepting positions
such as graduate (6301), teaching (6302),
research (6303), assistants (6303), and
post-doctoral employees (6580) which do
not require a competitive search or affirmative
action procedures. Post-doctoral fellow
appointments do require the approval of
the Dean (Appendix E).
–
Consultants
Consultants on sponsored activities may
be either external consultants/independent
contractors or internal consultants.
–
External Consultants/Independent Contractor
All external consultants must meet the requirements
set forth in the University Consultant/Independent
Contractor Policy and Procedures (Appendix
F). Direct questions about whether to classify
an individual as an employee or a consultant
to OPS.
–
Internal Consultants
If internal faculty consultants are used
on a project, the budget must include a
footnote stating that University faculty
members are being compensated in addition
to base salary. The consultant's time will
be limited to the equivalent of one day
per week. The rate of compensation should
be consistent with the employee's base salary.
–
Equipment
Equipment costing more than $500 must be
itemized along with estimated costs. The
proposal should provide adequate justification
for all equipment purchases for the sponsored
activity. Equipment purchases from awards
ultimately become University properly, unless
otherwise specified in the award.
–
Travel
The University Travel and Business Related
Expense Policy and Procedures governs all
travel and requires strict adherence (Appendix
G). The proposal should identify the type
and extent of travel and its relationship
to the sponsored activity. The authorized
university travel agency, World Travel,
must handle all University business travel
arrangements including transportation, hotel
reservations, and other travel related activities.
When preparing a precise travel budget,
PIs should consult World Travel. If the
PI considers foreign travel, the proposal
should contain relevant information and
budget justification.
–
Indirect Costs
All proposals submitted for external support
must include the current and appropriate
University indirect cost rates (Appendix
H). There are varying rates for on-campus,
off-campus, sponsored activities and instructional
projects. In some cases a faculty member
may request approval from OVPR for
an indirect cost rate that is different
from current rates. Requests for exceptions
must be in writing and approved by OVPR
prior to submission of the proposal.
For industry sponsored, fixed-price contracts
(other than clinical trials), the University
applies an indirect cost rate of 25% on
the total direct cost of the project budget.
If the direct cost budget developed by the
PI does not include this indirect charge,
SPA will add the 25% rate to the contract
budget. When an investigator negotiates
the budget with a company sponsor, the total
budget for any fixed-price contract must
include this 25% indirect cost. All fixed-price
contracts must recover 25% overhead.
OVPR is the ONLY University office
with the authority to approve the appropriate
amount of indirect costs. Failure to secure
OVPR approval may result in reduction
of direct cost support.
–
Cost Sharing
Some funding agencies require the University
to share certain cost expenses. These expenses
should be discussed with the Department
Chair, Dean, and OVPR early in the
proposal development process. The Department
Chair, Dean, and University, must approve
all requests for the University to provide
matching funds. In certain instances, the
investigator may be required to raise the
matching funds. The SPAF must identify the
project's source of all matching funds.
–
Space and Renovation
During development of a proposal, a faculty
member must consider the amount of space
and any renovations that may be necessary
to accomplish the specific aims of the proposed
sponsored activity. Any requirements for
additional space or renovations must be
made known to the Department Chair and Dean
and must be indicated on the SPAF prior
to proposal submission. Any special configurations
of the space as well as the amount and location
should be specified on the Administrative
Space Allocation Committee (ASpAC) Priority
Projects form. It is the responsibility
of the Department Chair and Dean to review
the space needs with the PI. If the PI's
department or Dean cannot provide space,
they may make a request to OVP/Research
and ASpAC. Predicated on a reasonable request,
OVP/Research and ASpAC identifies additional
space. If unable to accommodate the project
on campus, the University may rent space
off campus. Academic relevancy, rental cost,
overhead returned to the University, and
length of project all factor into the decision.
E. Proposal Approvals
All members of the University responsible
for the particular sponsored project must
sign the SPAF. By signing the proposal,
the units listed below accept accountability
as assigned to them by the University. All
principals should thus take the following
criteria into account when evaluating the
proposal for signature.
Principal Investigator (PI) or Project
Director
The PI, in signing the SPAF, agrees to:
-
accept
responsibility for the intellectual
content of the research or scholarly
activity that is proposed;
-
accept responsibility
to discuss quality and completeness
of both the fiscal and technical portions
of the proposal;
-
ensure that all
necessary approvals are received prior
to submission of the proposal to an
outside funding source;
-
consult, early
in the development process, with the
Department Chair and Dean to inform
them of plans for preparing a proposal,
and to discuss any special requirements
that may be necessary, such as additional
space, renovation of space, graduate
student tuition support, or matching
funds;
-
avoid conflict
of interest;
-
adhere to the
principles of responsible conduct
in research or other creative work;
-
assure that the
sponsored project is conducted safely
and in accordance with University,
federal, state, and local regulations;
-
meet deadlines
for the submission of the proposal
and for the completion of reports
to the sponsoring agency;
-
accept primary
responsibility for administration
of the awarded activity;
-
use funds for
the awarded project appropriately,
and to ensure that all expenditures
are consistent with the terms and
conditions of the award;
-
report potentially
patentable or other commercial results
in accordance with the University
Invention and Patent Policy;
-
complete the
work on schedule and within the project's
agreed upon budget; and
-
assure compatibility
with the total academic assignment.
Department
Chair and/or Center/Institute Director
The Department Chair or Center/Institute
Director must approve all sponsored activities
seeking external funding prior to proposal
submission to the Dean and SPA. In certain
cases, Center/ Institute Directors are delegated
oversight responsibilities. The signature
of the Department Chair or Center/Institute
Director or designee on SPAF indicates the
acknowledgement of the:
-
research
or creative activities that are being
conducted in the department;
-
research or
creative activity conforming to the
short or long-range objectives of
the department;
-
needs of the
proposal in terms of space requirements,
materials, staffing, or health and
safety hazards associated with the
conduct of the activities (the Department
Chair may need to discuss the special
requirements with the Dean before
signing the SPAF form);
-
commitment to
provide any necessary requirements
if the proposal is funded;
-
approval of advance
release time for designated faculty;
-
coverage of any
over expenditure or disallowed expenditures
from departmental funds;
-
adherence to all applicable college/school
and University procedures; and
-
competency of the PI to conduct and
manage the proposed project.
Dean
The Dean or designee, in signing the SPAF,
assures that he or she:
-
acknowledges
the proposed project;
-
recognizes the
project as compatible with the institutional
goals and objectives of the college
or school;
-
makes available
staff and space necessary for conducting
the project;
-
recognizes personnel
descriptions as appropriate and consistent
in the college/school;
-
notes all aspects of the proposal
which may have an effect on budgets
as well as procedures specified
to meet these obligations;
-
identifies post-doctoral
appointments which satisfy college/school
requirements; and
-
identifies any over expenditure
or disallowed expenditures that may
require coverage from college/school
funds.
Office of the
Vice President for Research
OVPR is the only University office authorized
to sign a proposal which seeks external
funding. The PI must obtain all appropriate
signatures before submitting the proposal
to SPA. In signing on behalf of the University,
SPA assures that the proceeding entities:
-
execute
their responsibilities;
-
meet the special
requirements of sponsoring agencies;
-
complete the
proper internal clearances;
-
advise the appropriate
officials of regular policy or any
parts of the proposal that call for
major fiscal or academic arrangements;
-
accept the projects
terms as outlined in the proposal.
Vice President
for Development and Alumni/ae Affairs
In some cases, the Vice President for Development
and Alumni/ae Affairs may be required to
sign the proposal. Upon signing the proposal,
ODAA assures that the project adheres to
the guidelines promulgated by the specific
corporation or foundation. OVPR
coordinates all required signatures with
ODAA.
F. Special Approvals Graduate Assistantships
In most cases, the University will not provide
support for graduate assistantships on sponsored
projects unless full overhead is provided
on the grant or contract. Exceptions to
this policy must be approved by the Graduate
School and OVPR.
Use of Human
Subjects
The Institutional Review Board (IRB) must
review and approve use of human subjects
in research. Research Review Committees
are on the Main Campus and HSC. Each committee
has slightly different formats and requirements.
For proper forms and guidelines specific
to the appropriate committee, please refer
to Section X in the manual and Appendices
I & J.
Use of Animals
in Research
The Animal Use and Care Committee (IACUC)
must approve the use of animals in research.
Please refer to Section X and Appendix L
for further information.
Use of Recombinant
DNA or Biohazards Research
The use of recombinant DNA, infectious agents,
or other biohazards in research must be
registered with, and approved by, the Institutional
Biosafety Committee (IBC). There is one
university-wide IBC that includes all University
affiliates. Section X and Appendix K contain
additional information.
Environmental
Health and Safety
For projects involving hazardous procedures,
including Biologicals and Chemical Hazards,
Radioactive Materials, Toxic Chemicals,
Controlled Substances, Ionizing and Non-Ionizing
radiation, and use of recombinant DNA or
RNA, the PI must complete an Assurance on
Hazardous Procedures (Appendix M).
–
Recombinant DNA
Prior to the initiation of research that
includes the use of non-exempt recombinant
DNA molecules, those projects containing
DNA from any pathogenic organism, more than
50% of the genome of any eukaryotic virus,
or the formation of recombinant DNA's containing
genes for the biosynthesis of toxic molecules,
must include a protocol to the Office of
Environmental Health and Safety Services
for consideration by IBC.
–
Radioisotopes and Radiation
The Radiation Safety Office must approve
the use of radioisotopes, radiation producing
machines, lasers and non-ionizing radiation
in sponsored projects.
–
Biological and Chemical Hazards
All investigators submitting applications
that involve biological or chemicals hazards
are required to complete and submit a notification
of the proposed activity to the Office of
Environmental Health and Safety.
G. Processing
Of Proposals
The full proposal and accompanying completed
SPAF, including necessary signatures, must
be at SPA ten working days before the funding
agency's due date. Failure to have appropriate
signatures on the SPAF may result in the
proposal being returned to the PI without
University approval. Due to the high volume
of applications submitted by the University,
SPA cannot guarantee that a proposal will
be submitted to the funding agency on time
if it is received less than ten working
days prior to the due date. If the PI anticipates
delays in meeting this schedule, he or she
should communicate in advance with OVPR.
The requirements for completing a proposal
for a contract are typically much more complicated
than those for an application for a grant.
The investigator should allow SPA additional
time to process the administrative component
of the proposal.
The completed SPAF, bearing the signatures
of the Department Chair or designee, Dean
or designee, and all other appropriate endorsements,
assures that all University officials involved
in the conduct of the proposed sponsored
activity have reviewed and approved the
proposal, and agree to fulfill any and all
commitments set forth in the proposal.
H. External Review
& Negotiations
Upon receipt of a submitted proposal, the
funding agency reviews it for approval.
The PI should be prepared to respond to
requests from the funding source for modifications,
additional information, or revisions. For
large programs, many federal and state agencies
send a site visit team to confer with faculty
and administrative personnel involved directly,
or indirectly, with the proposed project.
Appendix KK contains suggestions on how
to prepare for site visits.
Funding sources may negotiate reductions
in the project's direct cost. Any final
negotiations of the budget are handled by
SPA in consultation with the PI. If the
investigator is notified of a reduced award,
he or she must consult with SPA to determine
the budget categories to adjust. As opposed
to across-the-board reductions, some agencies
may accommodate investigators who justify
reductions to specific line items. If the
funding source deletes charges in certain
areas, the University may compensate with
available specific funds. For example, the
University may have funds to purchase a
piece of equipment for the project instead
of the investigator accepting a reduction
in salary support. If there is a significant
reduction in funds, the investigator should
attempt to negotiate a reduction in the
scope of the activity to be performed, such
as omitting a particular "aim"
in the application.
I. Special Cases
- Industry Sponsored Clinical Trials
The University is committed to, and supportive
of, industry-sponsored clinical trials.
In order to evaluate new drugs/medical devices
or new uses for approved products for support
of applications to the Food and Drug Administration
(FDA), the University conducts clinical
trials. The University is responsible for
negotiation, approval, oversight, and compliance
with appropriate regulations and guidelines
governing clinical trials.
Authorized representatives of the University
and the corporate sponsor must sign formal
contracts/agreements prior to the initiation
of the project. Both parties must either
sign or mutually agree upon the agreement
prior to release of IRB approval. Suitable
research agreements include the following
components:
-
designation
of PI;
-
inclusion of
beginning and ending dates of the
project;
-
authorization
of budgets and schedules for payments/patients
completing the protocol;
-
inclusion of
the number of patients expected in
the protocol;
-
ownership of
completed forms and data collected;
-
ownership of inventions;
-
publication rights;
-
confidentiality of proprietary information;
-
indemnification clause for clinical
studies (Appendix II);
-
company coverage of patient adverse
reactions to the protocol;
-
independence of the parties;
-
assignability of the agreement;
-
conditions governing termination;
-
certification as to sovereignty of
the agreement; and
-
designation of responsible representatives.
IRB requires that only a physician who
is a University employee with an academic
appointment may serve as a PI for clinical
trials or when human subjects are exposed
to more than minimal risk as outlined by
the federal Office for Protection from Research
Risks. The PI is responsible for obtaining
appropriate departmental approval prior
to requesting University approval. The PI
should present the University's requirement
for a clinical research agreement to the
corporate sponsor. A representative from
the company should contact OVPR
to develop a mutually agreeable clinical
research agreement to govern the conduct
of the project.
To qualify for a complete institutional
review of the proposed clinical research,
PIs must submit all necessary documents
along with a complete copy of the proposed
request for funding and/or the full company
protocol. Because the President or the Vice
President, Chief Financial Officer and Treasurer
are the only two officers who can execute
contract agreements on behalf of the University,
the PI should submit all required information
at least one month prior to the expected
date for patient entry to the project. University
reviews include, where applicable:
-
project
budget review and proposed approval;
-
IRB Review of
Human Subjects Protocols (Appendices
I & J);
-
Institutional
Animal Care and Use Committee Review
for use of Non-Human Animals (Appendix
L);
-
Institutional
Biosafety Committee Review of Recombinant
DNA (Appendix K);
J. Special Cases
- Sub-Contracts
If the University receives an award and
a portion of the activity is to be sub-contracted
to another entity, SPA assists the PI in
development of a sub-contract which outlines
the sub-contractor's role in meeting the
requirements of the award (Appendix N).
SPA forwards the sub-contract to the sub-contractor
for review and signature. Upon return of
the executed document, the PI should complete
a Financial Impact Statement (Appendix JJ).
OVPR forwards the sub-contract and
Financial Impact Statement to University
Counsel, where review and appropriate signature(s)
and seal (if necessary) are obtained.
When the University is the recipient of
a sub-contract similar procedures are followed.
Please direct any questions on sub-contracts
to OVPR.