Research Proposal & Internal Processing Form (IPF) Policy Clarification
A strong program of research with extramural funding is a top priority for the College for a variety of reasons that include: carrying out exciting work, enhancing our academic reputation, attracting top-notch faculty and students. Extramural grants also generate overhead return that can be used to fund future research efforts and new College initiatives. In the present financial climate this last item is particularly important as overhead from funded research programs is a primary source of start-up funds.
At present, overhead rates are negotiated with major funding agencies by the University and are thus set by prior agreements or past practice ranging from nearly 60% of direct costs to zero. At present, 10% of the overhead (indirect costs) are returned to each of the Dean(s), Organizational Unit(s), and Principal Investigator(s). Where more than one party is involved at any of these three levels, the internal processing form (IPF) required for all proposals must include a memorandum of understanding specifying how the overhead return and credit for the proposal will be apportioned among the parties unless a specific exemption is agreed to by parties for post-award negotiation of these matters. In such cases, the exemption agreement should accompany the IPF.
Not all grants and contracts carry the full overhead rate of 57% but even that does not cover the actual costs of research. Grants and contracts from the Commonwealth of Massachusetts are typically at 26% and “unrestricted grants” or “gifts” at 10% return. Some foundations and non-profit organizations have different indirect cost rates or a policy of no indirect costs. In those cases, the University will generally abide by any longstanding written policy of the foundation if a copy of the policy or letter attesting to past practice is provided with the IPF. Funded research portfolios within an organizational unit should include a reasonable balance of any such grants/contracts.
The general policy of the University and the College is, other than these standard variations, to not grant a waiver or exception to overhead rates. However, in some rare cases a reduction in the standard overhead rate may be warranted. Requests for such reduction must be endorsed by the appropriate department head(s) and then by the Associate Dean for Research. Final approval rests with the Vice Provost for Research. Such endorsements will indeed be rare and not routine. Faculty often have the mistaken notion that lower indirect costs will benefit their proposal review. Federal funding agencies, however, do not generally allow consideration of indirect costs in the review process and will negotiate any concerns in the award phase of the process after review.
Another, related concern, is the need to insure that all appropriate direct costs are included in budgets. This is, of course, especially important in proposals where coverage of indirect costs is also less. A common example is the failure of fellowship funding to cover benefits for faculty. When faculty informally discuss any arrangements beforehand and then submit a formal proposal for approval, they should be warned that any direct costs which are not covered by the award will not be absorbed by the College or organizational units from indirect costs. To minimize such difficulties, we encourage faculty who are informally exploring funding opportunities to discuss their provisional budgets and proposals with the Associate Dean for Research early in the process. Faculty are also advised that they can seek advice beforehand from the Office of Sponsored Research or from the Office of Foundation Relations.
All research activities which involve proposals for research, instruction, or other support from sources outside the University (i.e., externally sponsored projects) that in turn require the use of University facilities or employees working in the capacity of their UMass appointments must submit their proposal through OGCA and be accompanied by an internal processing form (IPF). Faculty who directly negotiate outside these confines should be aware of the fact that the University has no responsibilities in such an arrangement. Again, a common example would be direct fellowship support during sabbatical that is not directed through the University and hence has no provision for benefits.
It is important that we have a clear and simple process for handling the paperwork associated with externally sponsored proposal submissions. This is particularly true in expediting the signing of the IPF form. The College is adopting procedures common elsewhere on campus in setting procedural standards. Listed below are guidelines to be used in the preparation of the IPF paperwork:
- In SBS the signing authority for proposals and IPFs in the Dean's Office is the Associate Dean for Research. All proposal submissions for external funding, regardless of the amount or sponsor, must be accompanied by an IPF. To meet the responsibilities of the College the IPF should be presented for approval well before signatures are required.
- The process for proposal approval through an IPF can be initiated, given sufficient budget detail, even if the text of the proposal is still in the form of a working draft.
- The approval of the IPF should ordinarily be sought first from the relevant department chair(s). However, if the chair wishes clarification from the ADR, chairs may communicate their concerns to the ADR and the investigator may be instructed to first seek approval from the College.
- It is the responsibility of the PI and Co-investigators to obtain signatures of approval on the IPF from the relevant department chair(s) and dean(s). It is also their responsibility to insure that all direct costs required and any matching costs are correctly identified on the IPF.
- It is the responsibility of the PI and Co-investigators to seek endorsement of any IC variance from the relevant department head(s) and dean(s). The PI then seeks approval from the VPR. Normally this can be done electronically, but some time is necessary for consideration; last-minute requests for variances are difficult to accommodate.
- In the case of an IC variance, the endorsements (e.g., copy of emails and VPR approval) must accompany the IPF when it is brought to the Dean’s Office for final signature. The VPR approval will be forwarded to OGCA along with the IPF.
- When submitting a proposal where the granting agency requires a specific overhead rate, this requirement must be clearly documented in the IPF by inclusion or reference to published guidelines of the funding source.
- When submitting a proposal for an “unrestricted grant” or “gift” (i.e., 10% overhead rate) a document from the sponsor stating the nature of the funding must be included with the IPF form, clearly displayed.
Janet Rifkin, Dean
Douglas Anderton, Associate Dean of Research
January 15, 2008
Research ACCESS recently ran a three-part series on indirect costs that faculty might find relevant.
