Proposal Related

Document File: 

Topics: 

Roles and Responsibilities of Principal Investigators/Co-Investigators

Sen. Doc. No. 09-032

SPECIAL REPORT of the RESEARCH COUNCIL concerning

PRINCIPAL AND CO-PRINCIPAL INVESTIGATORS: ELIGIBILITY, ROLES, RIGHTS, RESPONSIBILITIES,  AND OBLIGATIONS

 Presented at the 683rd Regular Faculty Senate Meeting March 26, 2009

COUNCIL MEMBERSHIP:  Jenny Adams, Leslie Button, Lori Clarke, Paul Cormier, Kourosh Danai, David Evans - Chair, Andrea Foulkes , Cynthia Jacelon, Jane Kent-Braun, Paul Kostecki, Mason Lowance, Michael Malone, Michael Maroney,   Ernest May, Jane Miller, John Mullin, David Ostendorf, William Patterson, Stephen Rich, Jay Schafer, Linda Shea, Lynnette Leidy Seivert, Carol Sprague, Martha Taunton, Emily West, Hilary Woodcock

Principal and Co-Principal Investigators: 

Eligibility, Roles, Rights, Responsibilities, and Obligations

 Definition(s)

Principal Investigator (PI) – A Principal Investigator is the primary individual responsible for the preparation, conduct, and administration of a research grant, cooperative agreement, training or public service project, contract, or other sponsored project in compliance with applicable laws and regulations and institutional policy governing the conduct of sponsored research.

Co-Principal Investigator or Co-Investigator (Co-PI/Co-I) –Co-PIs/Co-Is are key personnel who have responsibilities similar to that of a PI on research projects.  While the PI has ultimate responsibility for the conduct of a research project, the Co-PI/Co-I is also obligated to ensure the project is conducted in compliance with applicable laws and regulations and institutional policy governing the conduct of sponsored research.

Faculty Participant – University of Massachusetts Amherst Faculty may be involved in projects key personnel without the same responsibilities of a PI or Co-PI/Co-I.  These faculty are not responsible for the conduct of the project, are not a signatory to an MOU, and normally do not share in the return of indirect cost, unless specified in the MOU.  Faculty participants may participate in the research, may collect salary, and may have a role in publications.  A Faculty Participant may also be referred to as a   Faculty Investigator or Senior Personnel.  The term “faculty Participant” is used below to refer to this category.

Eligibility

Being granted PI and Co-PI status is a privilege granted to eligible University personnel who meet the criteria identified below.  All persons granted PI and Co-PI authority must accept all of the responsibilities associated with the application for and administration of awarded sponsored projects.

Each PI and Co-PI certifies with every proposal submission that all information provided is true and complete and that the proposal conforms to the University policies and procedures applicable to sponsored activities.  In order to be certified as a PI or Co-PI, a researcher must confirm that he/she will comply with all regulatory compliance directives; that all information submitted within the proposal is true, complete, and accurate to the best of his/her knowledge; that any false, fictitious, or fraudulent statements or claims may subject the investigator(s) to criminal, civil, or administrative penalties; and that the investigators(s) agree to accept responsibility for the conduct of the project and to provide all required reports as applicable if a project is awarded as a result of the proposal.

Upon accepting the award, each PI , Co-PI and, if appropriate, each Faculty Participant must also confirm  that he/she will be responsible for project management of the award and agree to carry out the project with the highest professional standards and within the time period awarded.  The PI assumes responsibility to read, understand, and comply with all of the terms and conditions contained in the award.  Finally, the PI must confirm that he/she understands his/her responsibility to abide by University and sponsor policies, procedures and directives for the proper administration of sponsored projects.

Who can be a PI?

Persons holding the following positions may be designated as PIs in applications for externally sponsored funding:

  1. All tenured and tenure-track Assistant, Associate, and Full Professors and Librarians.
  2. All persons holding appointments as Research Assistant Professor, Research Associate Professor and Research Professor, Extension Specialists, and Clinical Professors.
  3. All persons holding Adjunct, Visiting, Emeritus or other faculty positions at the University of Massachusetts, Amherst not included under 1 or 2, and who have the approval of the appropriate governance bodies of a Department and, also, the approval of the Dean of the relevant School or College.  Such approval is indicated by the signature of the named governance bodies on the Internal Processing Form.  PI’sin one of these categories should also include a Co-Principal Investigator from appointment types included in 1 and 2 above.  In the event a Co-Principal Investigator is not named, the appropriate governance bodies of the Department and, also, the Dean of the relevant School or College shall accept full fiscal and administrative liability and responsibility for the actions of the Principal Investigator included in this category.
  4. All Post-Doctoral Fellows who have the approval of the appropriate governance bodies of a Department and, also, the approval of the Dean of the relevant School or College.  Such approval is indicated by the signature of named governance bodies on the Internal Processing Form. The Post-Doctoral Fellow’s mentor must be listed as a co-principal investigator.
  5. All Professional Staff who are not also students, provided they have the approval of the appropriate governance bodies of a Department and the approval of the Dean of the relevant School or College or the Vice Chancellor, if an administrative unit.  Such approval is indicated by the signature of the named governance body or bodies on the Internal Processing Form.

Note:  Neither undergraduate nor graduate students may be designated as PIs.  When a Sponsor’s program guidelines require the student to be listed as PI on the Proposal application, the student’s mentor/advisor shall be the PI of record on Internal Processing Form and responsible for the conduct and oversight of the project.

Who can be a Co-PI?

Persons eligible for designation as PI are also eligible to be designated as Co-PIs.  No undergraduate or graduate students may be designated as Co-PIs.  Persons who are located at other universities and who do not hold appointments in eligible categories at the University of Massachusetts Amherst may not be designated as Co-PIs.  Relations with collaborators at other universities, research institutes or corporations should be handled through subcontracts to the institutions involved.

PI Responsibilities:

PROPOSAL PREPARATION AND SUBMISSION

General

The Principal Investigator confirms that the entire proposal meets requirements outlined in the Program Announcement, Request for Application (RFA), Request for Proposal (RFP), or other application instructions. Examples of such requirements include, but are not limited to, award minimums/maximums, page limitations, font/margins, electronic file type/size, deadlines, and mailing addresses. The Principal Investigator may delegate this responsibility to Departmental Administrative Staff. If the Principal Investigator’s unit lacks Departmental Administrative Staff for proposal preparation or other sponsored programs administration requirements, he/she assumes these responsibilities or seeks support from the respective Department/Unit Head or Dean.

Technical Proposal

The Principal Investigator:

  • Prepares the technical proposal and may collaborate with others in its preparation.
  • Identifies the need for subrecipient agreements.
  • Determines whether on- or off-campus space in addition to that already assigned to the Principal Investigator is needed.  (The Principal Investigator identifies the need, and requests it from his/her supervisor, or other appropriate University manager.)
  • Takes responsibility for keeping his/her CV or biosketch updated.
  • Ensures that procedures used are consistent with sound research design and do not unnecessarily expose subjects to risk/harm.
  • Assures that the design is appropriate to the proposed question.
  • Determines that the project will contribute original scholarship.

Proposal Budget

The Principal Investigator:

  • Prepares or directly supervises the preparation of the budget and its justification.
  • Selects the appropriate facilities and administrative or indirect cost rate from the negotiated rates, under guidance from OGCA and/or the Dean’s Office.
  • If appropriate, makes a Facilities & Administrative cost (i.e. Indirect Cost) waiver request to the Department Head and Dean and then forwards this request to the Vice Chancellor for Research and Engagement for final approval;
  • Requests matching funds from University officials or identifies in-kind contributions from appropriate sources, when necessary.
  • Proposes cost sharing through contributed effort or other approved mechanisms and seeks approval from appropriate University officials.
  • Identifies all available financial resources in direct support of this or other research endeavors (other support) either at proposal submission or “Just In Time” in accordance with sponsor requirements.
  • Identifies anticipated program income.

Regulatory Requirements

The Principal Investigator:

  • Prepares the appropriate forms (either at proposal submission time or “Just In Time” in accordance with sponsor requirements) for the University Human Subjects IRB, or the Animal Care IACUC, the Radiation Safety Office and/or the Office of Environmental Health and Safety (EH&S), if the proposal involves:
    • human subjects;
    • live animals as subjects;
    • recombinant DNA, infectious agents, narcotics or biological toxins;
    • human blood or body fluids;
    • radioactive materials and/or ionizing or non-ionizing radiation-producing equipment;
    • hazardous materials; or
    • Protected Health Information (PHI).
  • Completes a Participation Agreement (PAG) prior to conducting sponsored research.
  • Discloses all potentially significant conflict of interest situations, and prepares a Conflict Disclosure Form and submits it to his/her supervisor, Department Head and Dean.
  • Affirms that he/she is not excluded or debarred from receiving Federal funds, and is not delinquent in student loans.
  • Ensures that other personnel involved in the project sign the University Internal Processing Form (IPF) as required.

Internal Processing Form (IPF)

The Principal Investigator:

  • Prepares or directly supervises the preparation of the Internal Processing Form. (The Principal Investigator must be the person who checks the boxes on the in section V of the IPF; this responsibility may not be delegated.)
  • Discloses the involvement of other departments or schools/colleges and ensures the appropriate signatures are included in the Internal Processing Form (IPF) approval.
  • Signs the Internal Processing Form. This responsibility cannot be delegated and the signature certifies that each item on the form is filled-out completely and accurately.

PRE-AWARD REQUIREMENTS

Pre-Establishment/ Pre-Award of Expenditure Account

The Principal Investigator requests pre-established accounts, if necessary. The Department/Unit Head will authorize and approve the pre-established account. (Department Administrative Staff should be cognizant of the need for (and use of) pre-established accounts, which minimizes cost transfers and/or reallocations.)

Small Business Subcontracting Plan

When applicable and required by the Sponsor’s requirements, the PI works with the Procurement Office and Departmental Administrative Staff to develop a Small Business contracting plan.

Negotiations with Sponsor

Formal negotiations with the sponsor are conducted only by OGCA staff.  All submissions of revised budgets and revised work scopes, as well as other information requested by the sponsor, must be coordinated with and submitted by OGCA to the sponsor.

The Principal Investigator role in negotiations:

  • Negotiates informally and forwards the approved revised project work scope to OGCA for submission to the sponsor.
  • In collaboration with Department Administrative Staff and the Office of Grant & Contract Administration (OGCA), the Principal Investigator modifies the project budget in line with the sponsor’s instructions for modification. (Department Administrative Staff should be involved in any budget modification, as this can impact other budgeting and effort issues on other projects or departmental accounts.)
  • The Principal Investigator communicates with the Co-PIs and other Faculty Participants concerning any changes in scope of work or budget that would substantially impact their participation in the project.  When Co-PIs or other Faculty Participants have their participation impacted substantially, the PI should provide to them verbatim copies of the relevant sections from peer reviews when those are available.
  • Completes a revised IPF and forwards the complete package through the signature process.
  • Notifies the appropriate regulatory office if changes to project scope will affect approved protocols.
  • Obtains approvals if cost sharing becomes necessary.

Acceptance of Award

When the Principal Investigator receives from OGCA the Principal Investigator Award Agreement (PIAA), he/she reviews the Notice of Award (NOA) that stipulates the approved budget and the terms and conditions of the award, and further delegates to Departmental Administrative Staff the review of the NOA for their part in helping the PI administer the project.  The PI then must sign and return the PIAA to OGCA indicating his/her acceptance of the terms and agreement to carry out the project in compliance with the terms in the NOA, University policy, and other applicable regulations and guidelines.  OGCA shall furnish a copy of the PIAA to the Co-PI’s and other Faculty Participants if they are named in the MOU.

Memorandum of Understanding (MOU):

A Memorandum of Understanding (MOU) is required for every funded grant or contract proposal that includes one or more Co-PIs.  The MOU must be signed by each PI and Co-PI, as well as their associated department head and dean thereby signifying each individual’s agreement to the responsibilities and terms as stated in the MOU.  The MOU may accompany the IPF.  However OGCA will not authorize the establishment of any accounts for a funded grant or contract until the MOU has been filed. OGCA will provide a standard MOU for PI’s and Co-PIs.  If the PI and Co-PIs want to file their own MOU, these MOUs must make clear the mutual understandings among the signatories concerning the following issues:

1. Who may authorize expenditures from grant or contract funds.

2. Responsibilities for carrying out major tasks specified in the proposal and granting instruments, including the preparation of reports required by grants or contracts (with the exception of invoices and financial reports to be prepared by Accounting).

3.  Percent of Credit to be attributed to each PI, as reflected by a pro-rated share of the awarded dollars in annual sponsored activity and expenditure reports. (This should not be confused with the percentage of effort committed to the project by the investigators.)

4. Division of RTF returned to investigators, department heads and deans.

5. Rules of succession in the event of the resignation or incapacity of a signatory.

6. Authorship and IP rights. These rights should be consistent with existing policies and procedures.

7.  The Dept ID numbers for all investigators, their department heads and deans.

The terms of any MOU cannot contravene or replace existing statutory or University regulations.

POST-AWARD CONDUCT AND MANAGEMENT OF THE PROJECT

General

Principal Investigators should reference the Office of Research web site: (http://www.umass.edu/research) or contact appropriate university offices to obtain information about rules and requirements governing sponsored funding. Principal Investigators are responsible for knowing what actions require sponsor approval and for obtaining that approval with involvement/assistance from OGCA.

Individual faculty - as principal investigators, research directors, and mentors - encourage their students and other research personnel to participate in educational programs on the responsible conduct of research or research ethics.

Conduct of the Research

The Principal Investigator:

  • Is responsible for all actions required to manage and complete the scientific and programmatic aspects of the sponsored project.
  • Initiates programmatic changes to the project and seeks approval from the sponsor via request to OGCA when required.
  • Initiates the hiring or assignment process and approves the selection or appointment of individuals to the project, and is responsible for communicating staff changes to Departmental Administrative Staff.
  • Ensures the integrity and safeguarding of notebooks and scientific data.
  • Ensures the completion, accuracy and timeliness of programmatic (technical) reports.
  • Initiates requests for and monitors subrecipient agreements prepared by OGCA.
  • Ensures the quality, timeliness, and programmatic (technical) performance of subrecipients.
  • Initiates a materials transfer agreement with the office of Commercial Ventures and Intellectual Property (CVIP) when using or providing materials to or from another source.

Budget Management

While the Principal Investigator retains primary responsibility for financial accountability, the Principal Investigator or the Department/Unit Head can delegate an authorized representative to act on his or her behalf for departmental account/project management.  Accounts should be managed by persons trained in these responsibilities. The University Controllers Office is responsible for account management at the University level and responsible for all payments, invoices, financial reporting, etc. to the sponsoring agency.

The Principal Investigator:

  • Initiates purchases.
  • At the time expenditures are initiated, determines that expenditures are allowable, allocable, and reasonable; approves them; and provides scientific justification for the transaction, if necessary. In both budgeting and charging of expenses, the Principal Investigator adheres to Cost Accounting Standards, such as consistency in allocating costs.
  • Initiates the process of documenting cost sharing and/or matching and for ensuring that cost sharing obligations are met from allowable and verifiable sources, including those by third party collaborators, if included in approved budget.
  • Initiates requests for rebudgeting as the sponsor requires.
  • Initiates cost transfer requests. When salary transfer requests are made, ensures these are based on actual effort expended and not merely as budgeted (per OMB Circular A-21).
  • Identifies and proposes a resolution of any account deficit.
  • Reviews subrecipient invoices for appropriateness and, to monitor progress of the work, approves payment of subrecipient invoices.
  • Uses PeopleSoft for financial monitoring, identifies and resolves errors in the account in a timely manner; certifies or documents a monthly review of ledgers. If appropriate and required at budget period end, the Principal Investigator requests that remaining balances are carried forward.

Program Income

The Principal Investigator:

  • When applicable, is required to understand the definition of program income.
  • Identifies all program income and notifies the Controller’s Office when program is anticipated/received.
  • Initiates the processes and proposes the allocation of program income.
  • Monitors receipt of program income.
  • Reviews program income reported to the sponsor by the University Controller’s Office.

Effort Reporting

To ensure compliance with the effort reporting (Plan Confirmation) policy, Principal Investigators sign and certify effort for themselves and employees on the grants in accordance with the University’s Time and Effort Reporting Guidelines, designed in compliance with OMB Circular A-21.

Project Transfer

All awards are made to the University and not to the individual investigator.  In the event a PI leaves the University, he/she must notify Co-PIs, Faculty Participants, the department head and dean of such departure in advance and seek appropriate next step instructions from the department head, dean, and OGCA.

Should the PI wish to take the grant/contract with him/her to the new institution, the PI must request and document written approval from his/her department head and dean to have the project officially relinquished.  Should the department head and dean approve of the transfer, the PI must provide OGCA with a memo confirming agreement to the transfer and other materials necessary to obtain appropriate sponsor permission.

Should the PI choose to leave the award with the University, the PI must notify OGCA of their departure as soon as possible and assist with the proper sponsor notification.  Such notification will either be a replacement investigator, or termination of the award.

Inventions and Intellectual Property

The Principal Investigator:

  • Adheres to the principles and policies outlined in the University’s Intellectual Property Policy and the Conflict of Interest Policy.
  • Ensures that all employees working on the project also comply with the policy.
  • Initiates the disclosure process and completes the Invention Disclosure Form in order to notify the Office of CVIP.
  • Assists in preparing patent applications.
  • Assists in the processing of copyright registration or other intellectual property protection.

Implementing a Small Business Plan (if required)

The Principal Investigator:

  • Directs purchases that are consistent with the project budget and the approved Small Business Plan (if required).
  • The PI or his/her delegate interacts with Procurement staff regarding progress toward achievement of Small Business Plan goals and reviews periodic reports about goals.
  • Provides an explanation when Small Business Plan goals are not achieved.

Project Closure

The Principal Investigator:

  • Prepares the final programmatic (technical) narrative report, which may include contributions by subrecipients or collaborators.
  • Submits any close out documentation needed in order for the Controller’s Office to submit financial status reports on a timely basis.
  • Provides information on other close out reports, such as for patents (to OGCA) and on equipment (to Property and Inventory Control).
  • Retains the scientific data in accordance with the University’s Policy on Access and Retention of Data.

Regulatory Compliance

The Principal Investigator:

  • Prepares a Conflict Disclosure Form in order to notify her or his Department Head and Dean if a potential conflict of interest exists and makes additional disclosures in a timely manner if a conflict of interest arises.
  • Is responsible for adhering to all educational and training requirements as the University requires.
  • Adheres to protocols and policies for research subjects, and notifies the IRB or IACUC if changes are made to protocols.
  • Meets continuing IRB/IACUC protocol review requirements and assists with inspections.
  • Adheres to chemical, biological, physical and radiation safety requirements, and notifies the appropriate office if accidents occur.
  • Adheres to the policies and procedures for using investigational new drugs and/or devices for clinical research.
  • Participates in the annual cost sharing certification (if applicable), as well as the periodic space and equipment survey.
  • Takes responsibility for adherence to record retention policy for all financial and scientific documentation.
  • Takes responsibility for cooperating in the audit process, whether internal or external audit staff is involved.
  • Takes responsibility for accounting of PHI disclosures, as required by HIPAA.
  • Takes responsibility for understanding and compliance with all institutional and sponsor policies, practices, and procedures.

 

MOVED:        That the Faculty Senate approved the Principal and Co-Principal Investigators:

33-09               Eligibility, Roles, Rights, Responsibilities, and Obligations, as presented in Sen. Doc. No. 09-032.

 

Topics: 

Five-Day Proposal Submission Procedure

Version 1, February 2, 2010

Issued by the Vice Chancellor for Research & Engagement (VCRE).

Late proposals are at high risk for submission failure, while faculty and staff highly value the maximum time for refining the proposal content. Timely and successful proposal submissions have been complicated by the advent of more widespread mandatory use of Grants.gov as a vehicle for Federal funding agencies. For this reason the VCRE is refining the mandatory five day proposal submission procedure (effective February 2, 2010) that is managed by the Office of Pre-Award Services (OPAS).

To ensure that these mandatory procedures meet the needs of the UMass academic community, the VCRE has approved the following enhancements:

  1. Proposals submitted to OPAS with a draft technical section on or before the five business day deadline will be considered “on time” if the proposal is complete in all other respects (including all sponsor forms and electronic form sets). This enhancement is designed to give PIs additional time to refine the technical component and thereby improve the proposal’s chances for success.
  2. If a proposal cannot be submitted “on time,” even with the use of a draft technical section, the PI must obtain the VCRE’s approval to submit a late proposal.

 

Submitting an “On-Time” Proposal

To be considered “on time” and in compliance with the mandatory lead time the complete proposal must be submitted to OPAS five working days before the proposal deadline.

An “on-time” proposal must include:

  • Completed and fully approved electronically-routed Kuali proposal.
  • Statement of work or technical section (in either final or draft form)
  • Budget with complete justification (Note: if the budget format required by the sponsor is not sufficiently detailed or explanatory, then a detailed budget should be included for OPAS review). Indirect costs must be calculated with either the federal negotiated rate or the rate specified by the sponsor in a published written policy or in program guideline documents that are applicable to all institutions. Any indirect cost (IC) variance must be approved by your department Chair/Head/Director, relevant Dean and the VCRE two weeks in advance. Documentation of that approval must be shared with OPAS when submitting the proposal.  See the Procedure for requesting an Indirect Cost Waiver/Reduction.
  • For subawards, documentation of the approval of the authorized representative of the subcontractor along with the statement of work, budget and budget justification for all proposed subawardees
  • Letters of support from named consultants and/or collaborators
  • Properly documented cost sharing/matching

Submitting a Draft Technical Section

A draft of the technical section of a proposal should not be a “placeholder” and should be clearly marked “Draft.”  It should address all required elements specified in the sponsor’s application guidelines and should be written in sufficient detail to allow the proposal to be reviewed even if only the draft statement of work or technical section were to be submitted. The PI should keep in mind that any changes made to the statement of work or to the technical section should not affect any of the following administrative elements:

  • Budget or budget justification
  • Cost-sharing, matching
  • F&A (indirect) costs requested
  • Effort of key project personnel
  • Named consultants and/or subcontractors

If a draft statement of work or technical section is submitted, the final version of the technical must be complete and submitted to OPAS via email to pre-award@umass.edu two full business days prior to the deadline. No other sections of the proposal are to be revised unless requested by OPAS’s review.  (See OPAS Proposal Staff.)

Submission of proposals that must be submitted electronically requires that the completed electronic form set/file be received by OPAS by the mandatory five-day deadline. Grants.gov and other proposals in electronic format should be submitted to OPAS by the mandatory deadline via Kuali.  For NSF proposals that use Fastlane, OPAS must be allowed access to the full complete proposal on FastLane by the five-day deadline.  

Late Proposal Exceptions

If a proposal cannot be submitted on time, even with a draft technical section, the PI must request an exception to the VCRE’s mandatory proposal submission procedures. These are the steps for requesting VCRE approval for the submission of a late proposal to OPAS at pre-award@umass.edu:

  1. Complete the VCRE Late Proposal Approval Request Form.
  2. Submit the completed “VCRE Late Proposal Approval Request Form” to the relevant Department Chair/Head/Director for review/approval.
  3. Ask the Chair/Head/Director to forward the completed “VCRE Late Proposal Approval Request” to lateproposal@research.umass.edu and to send an informational copy to the relevant Dean. Please note that the VCRE must receive request forms from the Chair/Head’s or designee’s email address. Incomplete request forms will be returned without review.

VCRE-approved requests will be returned to the PI and the Chair/Head with a revised date and time for submission to OPAS. Submission of late proposals that must be submitted electronically requires the completed electronic forms and files for the proposal be received by OPAS by the revised internal deadline.

Please note: Late proposals that are not submitted to OPAS by the VCRE’s approved revised deadline will be processed by OPAS only after all other “on time” proposals have been submitted. Depending on the volume of proposals at peak times, PIs submitting late proposals may be required to underwrite the cost of additional staff help in an effort to improve the chances for successful submission.

Frequently Asked Questions

Kuali Proposal Approval

What happens if my Department Chair/Head or Dean is not available to approve my proposal?

Each approver should have officially identified an alternate approver and had them profiled in Kuali by OPAS staff. Kuali is a web based product and can be accessed anywhere an internet connection is available.  Each profiled approver will receive an email that the proposal has been sent to them for approval.  Each department shall set their own policies as to how and when their authority shall go to the alternate approver.

Draft Technical Sections

What happens if the final version of the technical section is not submitted by the “two full business days” deadline?
The PI will be offered the option of having OPAS submit the draft technical section if the new “two full business days” deadline is not met. If the PI does not choose this option and also is unable to submit by the “two full business days” deadline, OPAS will accept the late proposal when it arrives but will process the proposal in the normal queue only after other “on-time” proposals are submitted. Such late proposals are at high risk of not being submitted by the agency deadline.

What happens if the revisions to the technical section alter the administrative component of the proposal?
At the time of the submission of the final statement of work or technical section, the PI should either highlight the changes that have been made or inform OPAS that only editorial changes were made. If the changes made in the final statement of work or technical section are inconsistent with what the PI submitted in the administrative section, OPAS will return the proposal to the PI so that the PI can make sure that the administrative and technical sections are consistent. This will result in the proposal being processed by OPAS only after all other “on-time” proposals have been submitted. Such late proposals are at high risk of not being submitted by the agency deadline.

Late Proposals

What happens if I receive approval from the VCRE to submit a late proposal but fail to meet the VCRE’s revised deadline?
OPAS will accept the late proposal when it arrives but will process the proposal in the normal queue only after other on-time proposals are submitted. Such late proposals are at high risk of not being submitted by the agency deadline.

Can the PI submit the late proposal exemption request form directly to the VCRE?
No. Only the Department Chair/Head/Director or relevant Dean can submit the late proposal exemption request to the VCRE because submission is considered administrative approval.

If I have approval for a late submission does that guarantee my proposal will be submitted on time?
Every effort will be made to meet the sponsor deadline; however, proposals are still reviewed in the order in which they are received. A proposal submitted “on time” will take precedence. It is unfair to expect that a proposal submitted “on time” should be delayed or not get the review it deserves because another PI’s proposal was late.

Where should we send the late proposal, to OPAS or VCRE’s Office?
The late proposal in final form can only be submitted once approval is received from the VCRE for late submission.  The proposal shall then be routed electronically with the complete proposal attached using Kuali.

What if OPAS has questions about a late proposal and the PI is not available?
The PI should make arrangements for someone to be available to answer questions and make any necessary changes to the proposal.

Are pre-proposals covered by the mandatory procedures?
Any pre-proposal, white paper, letter of intent, etc., which requires OPAS endorsement is subject to the five day requirement.

Acknowledgements

This procedure is adapted from a similar process used by the University of California, Berkeley.

Topics: 

Proposal Receipt Time

OPAS receipt of the proposal does not occur until after all required signatories approve the proposal electronically.  The proposal is due at OPAS by 9 a.m. five business days prior to the deadline. Please Note: If the proposal deadline is indicated by the sponsor as Receipt and it is not electronic (sponsor portal or email), the day that the proposal is due cannot be counted in the 5 day minimum because it must in fact be mailed the day before. In these cases, please count back 6 business days from the deadline. E.g. proposal deadline is Tuesday Receipt. The 5 day deadline to OPAS would be 9AM the previous Tuesday assuming no holidays or other closures (T, W, Th, F, M).

Proposal Criteria

The criteria of a complete proposal that can be logged in (9 a.m. five days prior to deadline):

  • All required proposal information, including the Kuali questionnaire (fully and accurately completed) listing the sponsors deadline, how the proposal is to be submitted, where the proposal is to be submitted, accurately identifies the sponsor and also list the prime sponsor if a subcontract situation, all cost share commitments,  answers compliance section, includes dept. id’s and RTF distribution, etc., and contains all non-OPAS requisite signatures.
  • A copy of the RFP or link to the RFP for the project you are applying
  • Proposal is uploaded into the sponsors official on-line system with full submit access granted (If this system represents a single input submission system [one log in only] list the website address, login name and password.)
  • Proposal Abstract (clearly marked draft is acceptable)
  • Technical section of the proposal (a reasonably complete and clearly marked draft of this section is acceptable)
  • CV’s, bio-sketches
  • Budget and Budget justification
  • Current & pending support documents
  • Other forms or documents as required by the sponsor
  • Subcontractor documents
    • Scope of work
    • Budget
    • Budget justification
    • CVs, bio-sketches
    • Current and pending support forms
    • Facilities statement if required
    • Certifications
    • Letter of endorsement from the Sponsored Programs Office
    • F&A agreement
    • Other forms or documents as required by the sponsor
  • References cited (a reasonably complete and clearly marked draft is acceptable)
  • Facilities statement
  • Letters of collaboration and support

 

Final Technical Sections

The final versions of the abstract, technical, and references cited must be received by OPAS two full business days (9 a.m.) prior to the deadline.

No further changes to the final version can be made once submitted to OPAS.

Topics: 

Development and Administration of Grants, Contracts and Cooperative Agreements for Sponsored Programs

Purpose

This policy establishes principles essential for the sound management and administration of grants, contracts and cooperative agreements for sponsored University programs in instruction, research, and public service.  They provide appropriate controls for the development of proposals and applications; procedures and criteria for the acceptance of grants and contracts for sponsored programs; and prudent and effective administrative and accounting controls for grant, contract and cooperative agreement administration.  This policy assigns responsibility to organizationally separated offices and individuals for each step in the administrative process, addressing both pre- and post-award administration.

The University engages in a wide variety of programs, projects, and other activities which are supported by funds from external agencies and organizations.  Funds received for such programs are held in trust by the University and are separately budgeted and accounted for.  The mechanisms used by external organizations to provide support are categorized into three types: Grants, Contracts and Cooperative Agreements.

The University's management procedures for the three general mechanisms are essentially the same.  Each is treated by the University as a specification of obligations which may require separate accountability for expenditures and evidence of performance consistent with the intentions of the sponsor.

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T94-034

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7/24/2015

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Cost Share Sources

Types of cost share in order of priority for use:

  1. Tuition Credits. Whenever possible, tuition credits should be used to cover mandatory cost share. 
  2. Academic Year Salary. Academic year salary plus the associated fringe and Facilities & Administration (F&A) may be used to meet mandatory cost share with approval of the dean.  The approval form must be uploaded in Kuali with the proposal.
  3. Unrecovered F&A. When the sponsor requires a lower rate than our federally approved rates, the amount of the F&A reduction from the full rate may be used towards cost share requirements unless disallowed by sponsor. No pre- approval is necessary.
  4. Graduate Student and other non-faculty salary.  Graduate Student research assistant salary, other non-faculty salary and associated benefits can be used as cost share if a University source is available to fund it.
  5. Other cost share. All other requests for cost share of $10,000 or less shall be the responsibility of the department and college and must be comprised of  allowable categories as defined in the University cost sharing policy.    Deans may request contributions from the VCRE towards mandatory cost share when amounts over $10,000 are required to meet mandatory cost share requirements in a proposal.
  6. Equipment.  When purchased as cost sharing, please list the Speedtype on the Institutional Commitment section of Kuali and ensure that the authorized approver is included on the Kuali routing map. The equipment must be purchased within the proposed grant period in time to benefit the project and must be dedicated exclusively to the proposed project or pro-rated based on use for the project.
  7. Third Party Cost Share. If from a source not under subcontract to UMass Amherst, third party cost-sharing must be approved by the VCRE. Submit requests to vcre@umass.edu with department and school/college recommendations two weeks in advance of the internal deadline. Approval must be uploaded in Kuali with the proposal, see University cost sharing policy for details on how to file a third party cost-sharing request.
  8. F&A Waiver or Reduction. Requests for indirect cost reductions to meet mandatory cost share requirements are based on recommendations from the department and school/college to the VCRE two weeks in advance of the internal deadline.

 

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