THE ROLE OF THE PRINCIPAL INVESTIGATOR
THE ROLE OF THE OFFICE OF SPONSORED PROGRAMS
THE FORMAL PROPOSAL
Number of Copies
Classified Research and Publications
PROCESSING THE PROPOSAL
ACCEPTANCE OF AN AWARD
This guide contains information about how to work with the Office of Sponsored Programs (OSP) when writing a proposal to obtain grant, contract, or cooperative agreement funds. It will not guarantee success. It will save you time.
This guide contains most of the policies and procedures that relate to sponsored research, service, and training at the University of Maryland, Baltimore County (UMBC). It includes development, review, and submission of proposals soliciting external support and with the establishment and administration of sponsored project accounts. This guide does NOT deal with policies and procedures concerning “gifts”.
Sponsored projects or programs, differ from “gifts” provided by a donor. The differences are based on the purpose of the funds provided and are completely independent of the source of funding. The distinction is important because project directors, departments, and the campus are required to administer the agreements and account for the funds in different ways.
The term “Sponsored Project” relates only to a research, service, or instruction project that is conducted with support provided by some entity outside the campus (the sponsor). A sponsored project is based on a commitment from the University to carry out one of those programs in keeping with terms agreed upon by both parties. The sponsored project will always require some use of university resources and the sponsor will receive some benefit (which could range from a single technical and financial report through substantial material benefits).
Readers of this guide are reminded of relevant University policies. At various locations throughout this manual readers can directly link to the appropriate policy, procedure, or guideline to obtain more information.
While this guide was developed for applications to federal sponsors, the material is also pertinent when applying to State, City, or private sources. For information on corporate sponsors, click here.
As campus needs change these policies and procedures will be updated. This guide has been designed so that revisions to particular sections may be issued and inserted as required.
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Funding agencies make awards to organizations and not to individuals. UMBC requires any proposal prepared by a faculty, staff member, or student to be submitted in the name of UMBC. Thus, there is a need for institutional review, approval, and official authorization of proposals and awards by someone legally empowered to make commitments on behalf of the university. The PI does not have the authority to commit university resources, permit the use of the UMBC name or logo, or enter into contractual arrangements that commit UMBC, etc.
A proposal is a cooperative effort between you as Principal Investigator and the University, represented by the Office of Sponsored Programs. Each has a specific role and responsibilities.
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THE ROLE OF THE PRINCIPAL INVESTIGATOR
When you function as a funded researcher, you assume fiscal and legal responsibilities. A Principal Investigator is responsible for ensuring that the terms of the award are met and the policies of the university are followed. A PI is responsible to:
the sponsoring agency
The PI must:
· Conduct and manage the technical research
· Comply with all applicable state and university policies, procedures, and laws
· Comply with all terms and conditions of a sponsored award
· Manage project funds efficiently and effectively within approved budgets
· Ensure that the project is completed in a professional manner
· Accept fiscal responsibility on behalf of his/her department, administrative unit, and/or college in the case that the project is over extended or an unauthorized expenditure is disallowed by the auditors. In such cases the academic unit must cover the cost.
Many funding agencies recognize only one Principal Investigator. When more than one person is listed as PI, one will be designated as first among equals, appear first on any listing, and be identified on university forms as Principal Investigator/Project Director. Other persons may be Co-Principal Investigators if they are considered to be primarily responsible for the scientific, technical, and administrative conduct of a project. Each Co-Principal Investigator must meet the same eligibility requirements as those set forth for the Principal Investigator. The appointment of Co-Principal Investigators does not supplant the need for one individual to be listed first and designated as “corresponding” investigator.
Although the University is legally responsible to the sponsor as the actual recipient of a grant or contract, the PI is accountable for the proper fiscal management and conduct of the project. If a PI acts outside the rules of the university, the PI may be held liable.
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THE ROLE OF THE OFFICE OF SPONSORED PROGRAMS
The university provides supporting administrative services and procedures to help meet the requirements of both the sponsor and the university. Sponsored projects are in this sense joint efforts between the university and the PI.
The Office of Sponsored Programs exists to promote extramural funding of research and scholarly activity and to help all faculty members as a group and each faculty member as a researcher. OSP is responsible for ensuring that grant and contract agreements do not:
Challenge our institution’s integrity
Threaten a faculty member’s academic freedom
Overburden the faculty with management procedures
In terms of the individual faculty researcher, OSP can assist at every stage of preparing the proposal and faculty members should feel free to contact OSP for help at any time. For a list of OSP personnel click here.
· Protects the university from unnecessary risks and liabilities
· Ensures proper stewardship of sponsored funds
· Creates mechanisms for accountability
· Develops procedures for the proper use of sponsored funds
· Interprets sponsor’s rules and establishes compliance with public policies
· Files assurances and certifications regarding regulatory compliance
· Serves as the official liaison between the university and the funding agency
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PREPARING THE PROPOSAL
Principal Investigators (PIs) are urged to communicate by phone or email with agency technical or Program representatives at the very earliest stages of proposal preparation. The information gained via an early dialogue with potential sponsors may prove useful in structuring and routing the final proposal.
A well prepared short prospectus or abstract can present the important points of a proposed project and can serve as a discussion point for follow-up phone calls to the interested agency. A personal visit to the sponsor can also be useful, since it may result in some guidance by sponsor personnel in structuring the final proposal. When requested, an OSP staff member can accompany the PI on such a visit.
In most cases, informal proposals (letter of intent, preproposals) may contain basic, lump-sum cost estimates rather than detailed budgets. An informal proposal does not require campus endorsement; therefore, it does not need to proceed through the formal review and approval procedure. In those instances however, budgetary matters should be discussed with Business Managers and/or with the OSP to avoid confusion or misunderstanding at a later date. A lack of correlation between the technical proposal and the budget may lead to rejection of the proposal. For those informal proposals that require a detailed budget and/or university approval, the informal proposal must be routed through the OSP.
Informal proposals are not accepted by Federal agencies when the submission is in response to a "Request for Proposals" since this is a competitive contract award process with strict guidelines and deadlines.
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THE FORMAL PROPOSAL
The format and content of any proposal or application will vary with the requirements of the potential sponsor. A grant application will differ from a proposal submitted to a competitive contract-bidding situation. Additionally, proposals for new research will differ from those written for renewal of an ongoing research project. OSP is available for assistance in these matters.
Some sponsoring agencies provide instructions, some require the use of pre-printed forms, and some have few prescribed rules. Applications or proposals submitted to some sponsors must meet certain deadlines; other sponsors will accept proposals at any time. If allowed by the sponsor, grant proposals may be submitted concurrently to several agencies; a statement of concurrent submission should be included in such cases citing the other agencies to which the proposal was submitted.
READ THE SPONSOR’S INSTRUCTIONS CAREFULLY!
For a list of application forms that are available on the web click here.
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A proposal requesting support from any sponsor will most often consist of the following:
- Title Page For those sponsors who do not provide application forms or have other specific requirements, the principal investigator must construct some form of title page. Generally the title page will contain the title of the proposed project, the College and Department or Institute, name and title of the principal investigator(s), time period and inclusive dates of the proposed project, total support requested, and name and address of the sponsoring agency. It should also contain a signature block for both the PI and for the UMBC OSP business official. For a sample Title Page click here.
- Table of Contents Show page numbers.
- Abstract Brief description covering the purpose, specific aims, and significance of the project. In general, little or no experimental detail should be in the abstract. Some sponsors require the abstract be written in lay terminology.
- Description of the Project This is generally the largest part of the application and contains a detailed description that may contain many or all of the following:
o Project Rationale
o A Statement of the Needs and Problems
o Goals and Objectives of the Project
o Relation of the Project to the State of Knowledge in the Field
o Significance of the Project
o Statement of Approach
o The Means by Which Objectives Will be Met
o Problems that are Anticipated
o Organization of the Project
o Project Staff and Their Roles
o Project Schedule
- Facilities Available facilities and equipment that will be important to the project should be described. Any additional facilities and equipment to be acquired under the project funded either by the University or the sponsor should be described in detail. The importance of these facilities or equipment to the success of the project should be clear.
- Personnel Biographical sketches including pertinent publications of the principal investigator(s) and senior faculty and professional collaborators should be included. Only those individual people who are identified as essential to the project (i.e., PI, co-PI) should be considered as Key Personnel.
- Budget The budget should be reasonable and identify the cost of the project to the sponsor. The budget also serves as a further measure of the PI’s capabilities since there must be a reasonable correlation between the project as described and the principal investigator's assessment of the various cost elements. Budget preparation constitutes a large segment of the proposal and may be structured differently depending on the sponsor. For instance, on federal grants, the budget will always contain both direct costs and indirect or Facilities and Administrative (F&A) costs, whereas a budget developed for a corporate grant or contract may benefit from adding indirect costs to each line item and showing only the total. It is strongly recommended that the PI work with OSP during budget development (and before discussing costs with the sponsor). For a sample grant budget page click here.
OSP REQUIRES A DETAILED BUDGET AND BUDGET JUSTIFICATION ACCOMPANY THE PROPOSAL, EVEN IF THE SPONSOR DOES NOT REQUIRE IT. IN THE CASE OF NIH's MODULAR GRANTS, DIRECT AND INDIRECT COSTS SHOULD BE CALCULATED AS USUAL AND THEN THE AMOUNT SHOULD BE ROUNDED UP TO THE NEXT $25,000.
Direct costs are those that can be distinctly identified as benefiting the project such as salaries and fringe benefits of faculty, technical staff, and research assistants; equipment; supplies; travel; computer time; and others. All budget items must be justified.
Indirect or F&A costs (overhead) are expenses incurred by UMBC that support, in part, the expansion of sponsored research activity. UMBC has varied rates depending on activity; i.e., Research, Instruction, or Other. Items such as buildings and building maintenance, depreciation, instrumentation, compliance with biohazard safety, disposal of hazardous waste, startup funds for new faculty, veterinary services, library books, departmental supplies, administrative and clerical salaries, summer faculty fellowships, and special research initiative support are among the items covered by F&A. UMBC negotiates F&A costs with the U.S. Department of Health and Human Services Audit Agency acting on behalf of all federal agencies. For the current F&A rates and categories, click here.
The rate used and calculation should be shown on the budget page for ease of approval and sponsor review.
- Budget Justification - All budgets must contain a justification for the items listed. For a sample justification page, click here.
Direct costs include some or all of the following:
Salaries: Includes faculty, technicians, graduate research assistants, other professional research staff, and hourly personnel who are UMBC employees. Include for all; names, titles, the percentage of time each will devote to the project, the rate of pay, fringe benefits (see below) and amount requested from the sponsor to support each person per year (or for the budget period). Adjust for salary increases for budgets that are for more than one year or that cross UMBC fiscal years.
Faculty are on a 9.0- or 9.5-month academic year appointment or in some cases faculty may receive compensation based on a 12-month fiscal year appointment period. An appropriate percentage of the academic year or fiscal year salary is specified in the budget. A faculty member on a 9.0- or 9.5-month appointment may elect to devote time during the summer to a sponsored project beyond the academic year and may request and receive additional compensation beyond the base academic year salary. For faculty with 9-month appointments, a maximum of 3.0 months of summer effort and salary (calculated at 3/9 x base salary for the new fiscal year) is possible in those cases in which this is acceptable to the sponsor. For 9.5-month faculty a maximum of 2.5 months of summer effort and salary at 2.5/9.5 of the base salary for the new fiscal year is possible. Note that for NSF sponsored grants summer salary is limited to no more than 2/9 of the academic year salary. A faculty member on a 12-month appointment may not receive additional salary for summer research effort. For a copy of the UMBC policy, click here.
Other professional research staff and technicians should be compensated for periods during which their services will benefit the project.
Administrative Personnel may be charged only under special circumstances as explained by government Office of Management and Budget Circular, OMB A21. See below or contact OSP for assistance. For a copy of OMB A21, click here.
A graduate research assistant may be assigned to research duties with the student's time divided between formal study and research. Tuition remission for graduate research assistants on sponsored projects should be included as a fringe benefit calculation and requested from the sponsor. Adjust for tuition increases for budgets that are more than one year. The Office of the Dean of the Graduate School and Vice Provost for Research annually publishes a schedule of stipends for guidance. Click here for the current schedule.
In no case can funds be requested or used to augment salaries of any faculty or staff beyond University approved rates.
Fringe Benefits: Include the University's contributions to Social Security, retirement programs, health insurance, and unemployment compensation. Where applicable, tuition allowance should be added for permanent full-time employees and dependents, and graduate assistants. Graduate Research Assistants are entitled to full hospitalization benefits and tuition remission; other benefits do not apply. For undergraduate assistants (hourly workers), no employee benefits apply except during the summer. If the assistants are not attending Summer School classes, then Social Security and unemployment compensation are applicable. Permanent part-time employees are entitled to all benefits if employed one-half time or more. Part-time employees who work less than one-half time, temporary personnel, and hourly employees are entitled only to Social Security and unemployment compensation. For a table of applicable fringe benefit rates click here.
Permanent Equipment: These are identified as individual items of $5,000 or more in value with a useful life greater than one year and they must be itemized and justified. In addition, the PI must determine that the equipment requested is not already available within the University. The cost of equipment generally includes needed accessories, installation, and delivery costs. In some cases the sponsor may provide the equipment directly rather than provide acquisition funds, or short-term rental may be preferred. Individual Items with a value of less than $5,000 or useful life less than one year should be listed under “Supplies and Expendable Equipment”.
Consultant fees:These costs may be paid to experts outside UMBC who provide a unique contribution to the project. A consultant is defined as an individual or organization hired to provide advice and/or service to the project within normal business operations and whose status is governed by Internal Revenue Code of Common Law. Charges may include fees, travel, and supporting costs (per diem, etc.). Where the costs of consultants are borne in whole or in part as direct costs by PHS projects, the consultation must be documented by an invoice from the consultant and a copy of the consultant's written report. UMBC policy indicates that vendor/consultant services must be competed if the amount exceeds $25,000 unless strong justification for sole source is provided. The use of consultants is govern st be evidence that:
- the services provided are essential and cannot be provided by persons receiving salary support under the grant;
- a selection process has been employed to secure the most qualified person available; and
- the charge is appropriate considering the qualifications of the consultant, his/her normal charges, and the nature of the services rendered.
For a detailed description of how to distinguish between a consultant/vendor and a subrecipient, go to Subawards.
For most proposals, the PI should obtain at a minimum an hourly rate, Statement of Work, and list of deliverables from the consultant. The PI should be aware that most federal agencies cap the daily rate at which a consultant may be paid.
Consultants within UMBC and within the University System of Maryland may receive compensation only with the advance approval of the President or designee of the faculty member’s institution. State of Maryland employees are not eligible to receive compensation for consulting services on sponsored projects. Federal agencies specifically prohibit the payment of consultant fees from Federally supported projects to persons employed by the Federal government.
Supplies and Expendable Equipment: Items should be identified and justified. They include, for example, chemicals, glassware, small electronic components, animals and animal care, any equipment with a value of less than $5,000, unusually large quantities of paper supplies that can be easily identified as related to the project as in the preparation and distribution of questionnaires or other brochures and forms, audio and videotapes, film and film processing supplies, and minor fees for participants in anthropological or sociological studies. A complete description of this category can be found in government circular OMB A21 or call OSP for assistance.
Travel: All costs of both domestic and foreign travel, including subsistence and registration fees, if any. The need for PIs to consult with colleagues and disseminate new knowledge at scholarly meetings is an accepted cost in most projects. There must be a correlation between the project and the purpose of the meeting. Federal agencies require the use of U.S. flag carriers.
If the project requires travel to various locations to perform the work, these costs should also be identified. An itinerary may be required if travel is a significant portion of the total cost. Some examples would be travel to various localities to collect samples, to interview respondents, or to make special measurements.
Publication: This should include manuscript illustration, costs of reprints, and page charges to be incurred in publishing articles resulting from the project. The publication costs of a book or monograph are not generally allowed and special permission must be obtained from the sponsor.
Subawards: Includes other entities (labs, etc.) that provide a substantial programmatic contribution to the project. Specific approval by the sponsor is required and specific regulations flow down to the subawardee; thus the proposal must include documentation (i.e., work statement, budget, and endorsement by the Sponsored Programs Office of the proposed subawardee) of the involvement. It is the PI's responsibility to be familiar with sponsor requirements for subawards, but contact your Business Manager or OSP for assistance.
To distinguish between a vendor/consultant and a subawardee, ask the following:
- meets only the requirements of the procurement contract
- end-products or deliverables are specified in advance with regard to quantity, quality or other characteristics
- provides the goods or services within its normal business operations
- provides similar goods or services to many different purchasers
- operates in a competitive environment
- is likely to be paid by a fixed price method
- involved performance of repetitive tests or activities requiring little of no discretionary judgments on the part of the provider
- performs specified activities, but quantity, quality, and other characteristics or end products or deliverables are not specified in advance or no deliverable is required except for reports describing the supported activities
- performs "substantive project work" defined as a "significant portion of the activities for which support was awarded"
- provides unique services or products
- has responsibility for programmatic decision making
- usually cooperates with UMBC in developing the proposal for submission to the sponsor
- is usually responsible for design or development of the supported activities
- is likely to be paid by the cost-reimbursement method
To obtain a UMBC form and instructions for subcontracts click here.
· Copying, duplication and/or mailing costs: Must be an integral part of the research such as sending out questionnaires.
· Alterations or renovations of space necessary to carry out the project.
· Rental of space in those special cases where this is necessary. If more than 50% of the project will be performed in rental facilities, an off-campus indirect cost rate is appropriate*.
· Maintenance (service contracts) or rental of specialized equipment that is necessary to the project.
· Communication costs such as long distance telephone costs and postage charges where large volumes of mailing are required for the project.
· Special costs such as the purchase or lease of airplanes, boats, or other vehicle.
· Stipends for participants in special training programs (allowable only when specified by the sponsor).
* There is an off-campus and an on-campus F&A cost rate depending on where the project is performed. Since the off-campus rate covers only the "administrative" portion of the F&A, it is expected that the grant will include direct charges for rent of an off-campus facility. If no rent is involved, then the project is more accurately described as "on campus". To use an off-campus rate, in addition to rent being charged to the grant, the PI must indicate on the budget justification what resources are needed for the project that are not available on campus (space, equipment, etc.). The off-campus rate will apply only if more than 50% of the project will be performed in rented facilities. It is the position of UMBC that all proposals requesting support from any sponsor, either government or non-government, must include a request for full F&A cost recovery.
Indirect (Facilities and Administration or F&A) Costs For the current rate click here.
The following costs should normally be treated as indirect costs and should not appear directly in the project budget:
· Salaries of administrative and clerical staff (providing normal support activities in the department or unit) but see NOTE below.
· Office supplies (including postage, Xeroxing, faxing, etc.)
· Local telephone calls (including line charges)
· Individual memberships and subscriptions
NOTE: Direct charging of administrative staff costs may be appropriate where a major project or activity explicitly budgets for these items and they can be specifically identified with the project or activity with a high degree of accuracy. The key is whether they are integral to the research activity and necessary for the consummation of the research objectives. Some specific examples of situations are:
- Large, complex research programs, such as those conducted by Centers or programs that entail the management of teams from a number of departments/units or institutions.
- Projects involving extensive data collection and data entry, surveying, tabulation, cataloging, literature searches, analysis and reporting.
- Projects that require extensive travel and meeting arrangements for large numbers of participants, such as conferences and seminars.
- Projects involving the preparation and production of large reports, manuals, books, and monographs (excluding routing progress and technical reports).
- Projects that are geographically inaccessible to normal departmental administrative services, such as seagoing research vessels, radio astronomy projects, and their research field sites that are remote from campus.
- Individual projects requiring project-specific database management; individualized graphics or manuscript preparation; human and animal protocol, IRB preparations and/or other project-specific regulatory protocols; and project-related coordination and communications among multiple investigators.
When such charges are to be included as direct costs in a grant budget they must be both strongly justified and be approved by the sponsor. The primary responsibility for making a determination as to whether such charges are justified and appropriate rests with the PI and his/her Department Chair/Unit Head. Restricted cost categories and other inappropriate charges can be readily detected in audits, and any resulting disallowances must be reimbursed to the federal government. Once the sponsored agreement is awarded, the costs reflected can only be charged if they are specifically reflected in the approved budget and have not been deleted by the funding agency. Contact OSP for assistance.
UMBC is responsible for ensuring that all costs (direct and indirect) charged to a sponsored agreement are allowable, allocable, and reasonable under cost principles stated in OMB A-21.
For federal grants and contracts, F&A costs are generally expressed as a percentage of Modified Total Direct Costs (MTDC). MTDC consist of all direct costs such as salaries and wages, fringe benefits, materials, supplies and expendable equipment (less than $5,000), services, consultants, travel, and subawards up to the first $25,000 of each subaward (regardless of the period covered). MTDC excludes permanent equipment ($5,000 or more), capital expenditures, charges for patient care, tuition remission, rental costs of off-site facilities, scholarships, and fellowships as well as the portion of each subaward in excess of $25,000.
Some sponsors, particularly foundations, may have specific written policies that preclude the use of UMBC's full F&A rates. In those cases, the rate allowed by the sponsor should be applied to the Total Direct Cost Base (TDC) unless specifically prohibited by the sponsor. TDC includes ALL direct costs, including tuition, fellowships, equipment, etc.
Other exceptions to the rule of full recovery may be necessary in special circumstances. Such requests must accompany the application and be justified. For more information on Exceptions to Recovery of Full F&A Costs click here.
Cost sharing should be included only where absolutely required by the sponsor because auditors interpret this as effort related to sponsored research and the net impact of their interpretation is to increase the University’s share of F&A costs, thus making it difficult for UMBC to negotiate a fair indirect cost rate with HHS. All matching and cost-sharing resources must meet the following general criteria:
- They must be verifiable from the recipient's accounting records;
- They may not be included as contributions for any other federally assisted project or program in either the current or any prior period;
- They must be necessary and reasonable for proper and efficient accomplishment of project or program objectives;
- They must be allowable under the applicable cost principles (OMB Circular A-21). This is true even if the asset is derived from a third party contribution. Therefore, a matching contribution must be for something for which the organization or institution could have spent federal funds;
- They may not be paid by the federal government under another award except when authorized by federal statutes;
- They must be provided for in the approved project budget.
The amount of the required contribution may vary from less than 5% to greater than 50% of the total project cost, depending on the sponsor. Cost sharing may include effort of the PI or other personnel committed to the project at no cost to the sponsor. If cost sharing is other than the PI's effort explicitly stated in the proposal, the responsible university official must guarantee the cost sharing commitment in writing. Proposals may not be signed by the OSP on behalf of the university unless cost sharing documentation, with all guarantees completed, is on file. Once an award is made, all cost sharing commitments are considered mandatory and, as such, represent binding obligations of UMBC. Cost sharing may be met from several sources; however, sponsor guidelines and policy will be controlling:
Other support for the same project, i.e., if the project is Federally-funded, the other support must come from a non-federal source;
A portion of the faculty member's effort for which no support funds are being requested (requires Chair approval). Such effort must be necessary and reasonable for the performance of the project and must be included in the faculty member's Effort Report;
Unrecovered indirect costs may be included as part of the cost sharing and matching WITH PRIOR APPROVAL OF THE FEDERAL AWARDING AGENCY. (It should be noted that the Department of Education expressly prohibits the use of unrecovered indirect costs as matching funds.)
Donated computer time, with the written consent of the computer center involved;
Contributed resources from the Department, College, or Institute/Center (with appropriate approvals).
Once awarded, all cost sharing referenced in a proposal becomes mandatory and must be accounted for as a cost of the project. These costs must be separately identified and reported and, if in the form of effort, certified in the Faculty Effort Report. It is important to realize that once an award is made, all cost sharing commitments are considered to be mandatory and as such, represent binding obligations on the university.
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Number of Copies
Most sponsors require a specific number of copies of the formal proposal to be submitted along with one or more signature copies. The appropriate number of copies can be found in the sponsor's guideline. OSP requires the original and one copy of the complete application (or the documents required for expedited review) and any RFA or RFP at the time of routing. The original will be returned to the PI for submission to the sponsor. At the time of submission OSP requires a fully executed, complete copy of the application for the university files.
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Some sponsoring agencies have specific deadlines for proposal submission. This information is available directly from the sponsor. Note that all Requests for Proposals (RFP) have strict deadlines that cannot be modified; this information is always in the RFP application package obtainable from the issuing agency. OSP requires at least 3 business days to process all grant and contract applications; if this deadline cannot be met, the PI should contact OSP to make other arrangements. See below, Processing the Proposal.
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Classified Research and Restrictions of Publication
UMBC does not enter into agreements to carry out research if the grant, contract or other award instrument restrains the freedom of the University, its faculty, or students to disclose the existence of the grant or contract, the general nature of the inquiry to be conducted, and the identity of the sponsor. The University reserves for its faculty the right to publish the results of the research without the prior approval of the sponsor.
The Bayh-Dole Act enables institutions to elect title to inventions developed under federal funding. Any research project that is funded, in whole or in part, by a federal agency is subject to specific federal statutes and regulations. Additionally, it is UMBC policy that all intellectual property, including copyrights, developed by personnel or students under any sponsored research agreement shall belong to UMBC. For Intellectual Property information, click here.
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PROCESSING THE PROPOSAL
A formal proposal to conduct a research or training project with support from an external agency represents an offer by the University of Maryland, Baltimore County acting as an agency of the State of Maryland. It is necessary that any such proposal have the endorsement of those responsible for carrying out the project as well as those authorized to commit the University and the Campus resources to a legal offer. For proposals, the authority to officially commit the campus has been delegated by the President to the Office of Sponsored Programs. A review and routing procedure has been established to insure that each proposal or application for sponsored activity is reviewed and endorsed by the various responsible persons and that compliance exists between sponsor, University, and State policies. All proposals for external support of Research, Training, or Service projects must be submitted to the Office of Sponsored Programs.
NOTE: In order to properly review each application, OSP requires that required documents be received in the office at least 3 business days in advance of the sponsor deadline. Preferably, the PI will notify OSP as soon as he/she is aware of the intent to submit an application. OSP maintains a 3-month planning calendar for this purpose. An email or phone call to the appropriate grant administrator will reserve that person's time so that they are available to assist with the application. OSP will meet all sponsor deadlines; however, those applications that are received too late for appropriate review may be withdrawn by UMBC if errors are found later.
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The people or offices sequentially involved in the internal review and processing are as follows:
· Principal Investigator: responsible for the budget, technical content, quality, and preparation of the proposal. By signing the paper routing or approving the electronic routing the PI attests to the truth and accuracy of the contents of the proposal.
· Department Chair or Director: responsible for certifying to the academic soundness of the project, the compatibility of the project with the Principal Investigator’s other commitments, the availability of space and facilities, cost-sharing commitments, assuring that the project is in keeping with department objectives, and concurring that the proposal should be submitted to the agency named.
· Dean of the College or Reporting Line: responsible for determining the consistency with college mission, availability and commitment of college support services and resources, including time, space, and finances. Assures all department/school or college obligations, as defined in the proposal, can be met.
· The Office of Sponsored Programs: responsible for insuring that there is compliance with applicable laws and regulations and with University administrative rules. The OSP is also responsible for insuring that the content meets with acceptable rules and standards of the Campus, and for reviewing matters involving human subjects, DNA research, hazardous substances, and the experimental use of animals. Academic policy and cost sharing issues, problems of institutional financing, prior acceptance of contractual terms, and budget matters may be resolved here.
In some unusual instances, a proposal may be presented to the Board of Regents.
NOTE: Submission of an application without obtaining the appropriate approvals may result in UMBC refusing any ensuing award.
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A Routing Form must accompany each proposal. The Routing Form must have appropriate endorsement signatures before submission of the proposal to the Office of Sponsored Programs. THIS INCLUDES PROPOSALS TO BE SUBMITTED ELECTRONICALLY. Proposals proceed from the PI to the Department Chair, then to the Dean of the College, or Provost and then to OSP. OSP must receive one copy of the proposal plus the original, which will be returned to the PI for submission to the funding agency.
PeopleSoft Process. This electronic accounting system takes the place of the old Routing Form. All appropriate information is entered into the system and routing and approvals are done electronically. NOTE: Although documents can be attached in this system, sponsors still require their forms be used and OSP still must review the ACTUAL APPLICATION that is being submitted. Thus, although it is no longer necessary to prepare a Routing Form, all other proposal documents must be delivered to OSP for review.
Expedited Review. To assist faculty in the application process, the OSP implemented an expedited review. This expedited review requires only the RFA or RFP, cover page, abstract, detailed budget and budget justification, and any necessary documentation such as IACUC (for animal research) or IRB (for human subjects) approval/application letters as well as budgets and commitment letters for any subcontracts or cost sharing that is included in the project. Where appropriate, an Assurance on Hazardous Procedures form (for all proposals involving ionizing or non-ionizing radiation) must accompany the proposal. PIs submitting proposals involving previously approved recombinant DNA protocols should enter the approval number on the Internal Routing Form; if DNA experiments have not been approved, the Registration Document for Recombinant DNA Experiments must be filed. PIs submitting proposals through the expedited review process are still required to send OSP a copy of the ENTIRE completed application at the time of submission.
In regard to submitting the proposal to the agency, a distinction exists between those proposals submitted in paper (“hard copy”) format and those submitted electronically.
PAPER: When all approvals are in hand, the OSP will sign the proposal on behalf of the University, and return it to the PI who assumes the responsibility for delivery to the funding agency.
ELECTRONIC: Since agencies that offer or mandate electronic proposal submission have their own individual systems, specifics will vary. (For National Science Foundation applications, see their web page at www.fastlane.nsf.gov for specific instructions.) Typically, the PI electronically submits the proposal to the OSP and upon review and approval, an OSP Contract Administrator electronically submits the proposal to the agency with the PI receiving electronic confirmation of submission. Other federal agencies that use electronic submission are:
NOTE: Two paper copies of the final proposal form to be submitted electronically and the UMBC Routing Form or PeopleSoft forms must be completed before OSPA will consider electronic submission to the agency.
THE EASE OF SUBMITTING ELECTRONIC PROPOSALS IS DIRECTLY RELATED TO THE LENGTH OF TIME PRIOR TO THE DEADLINE; i.e., THE LATER A PROPOSAL IS SUBMITTED, THE GREATER CHANCE THAT SYSTEM FAILURE DUE TO OVERLOAD MAY INTERFERE WITH TIMELY SUBMISSION.
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ACCEPTANCE OF AN AWARD
An award to the University from a sponsoring agency is a legal document, which obligates the University. An award may be simply in the form of a letter issued by an authorized agent of the sponsor or it may consist of a lengthy contractual document. In some cases acceptance by the University (and then by the agency) is required before the award is in force, while in other cases no formal acceptance is required. The OSP is the office authorized to accept and execute awards on behalf of the UMBC. OSP will consult with the PI if the award differs from the submitted proposal, so that the award may be accepted, modified, or rejected. No charges may be incurred against a sponsored project until such time as OSP has received and processed an original award notification from the sponsor, and an account number has been issued by the Comptroller’s Office.
On some occasions receipt of the actual award documents authorizing expenditures for a project may be delayed. If a delay will seriously impede the course of the project, it is possible to obtain permission to initiate expenditures for a short time (maximum 90 days) in advance of actual receipt by the Campus of an award document. For this purpose, a Request for Pre-award should be submitted to the OSP. This form requests the issuance of an advance account number and commits the department to reimburse campus accounts in the event that the expected sponsor authorization is not forthcoming. The OSP will approve such a commitment only after the proper authority at the granting agency has assured us of their intent to provide such funding.
In some cases an award may be issued by the agency after a series of negotiations, which may involve revisions to the scope of the project and/or to the proposed budget. The OSP is the authorized agent for conducting and approving such revisions, but no changes to a project or a budget are authorized without the express consent of the PI. Faculty researchers are reminded that the acceptance of a revised scope of work or budget is a judgment that only they can make; it is not a judgment or condition that may be unilaterally imposed by the granting agency. If the agency requires the submission of a revised work plan or budget, this must be prepared by the PI and submitted to the OSP for institutional approval.
Upon receipt of an official award at the OSP, the PI, Department Chair, Business Manager, and Grant Accounting Department will receive notification of the award, the award document containing the terms and conditions of the award, and the account number established for the project.
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