Policy for Sponsored Projects Submission and F&A Rates

Announcement from Vivian S. Lee

The Office of Science & Research would like to announce the adoption of two new policies covering the administration of sponsored projects at the School of Medicine. 

Policy on Sponsored Project Submissions

The first attached policy, the Policy on Sponsored Project Submissions, sets forth the responsibilities of the Office of Sponsored Programs Administration (SPA) in reviewing, approving and submitting applications and other sponsored project submissions on behalf of the School of Medicine and identifies institutional submission deadlines to ensure that these responsibilities can be met. 

To ensure that SPA has sufficient lead time to review completely and approve submissions, Principal Investigators must submit all sponsored projects proposals in paper format no later than seven (7) business days prior to the sponsor’s deadline. This includes all components of the proposal listed below.  Of these, all except for the Research Proposal, i.e. the scientific content, must be in final format at the time of this submission.

Internal Components (i.e. School of Medicine Components):

1. SPA Transmittal Form
2. Financial Interest Disclosure Form(s) for the Principal Investigator and all key personnel
3. Base Salary Form
4. Internal detailed budget if required

External Components (i.e., Sponsor Components):

1. Sponsor Guidelines
2. Required Sponsor forms
3. Budget
4. Research Proposal
5. Consortium statement (if applicable)
6. Consortium budget (if applicable)
7. Any other information as required by the Sponsor guidelines
8. Final Electronic copy on CD or Flash Drive (if applicable)

This requirement applies to all applications, whether they are to be submitted on paper or electronically.  Upon receipt, SPA will review the components of the submission and inform the investigator as soon as possible of any issues or concerns that might prevent its successful submission.

For paper submissions, the final version of the research proposal (which may have been submitted in draft form at the earlier deadline) must be submitted to SPA three (3) business days ahead of the sponsor deadline.  For electronic submissions, final electronic versions – including the final research proposal – must also be delivered three (3) business days ahead of the sponsor deadline. The requirement applies not only to grant applications, but also to all contracts, subcontracts, progress reports, and just-in-time reports, i.e. all projects and submissions provided to SPA, regardless of the sponsor.  Under the new submissions policy, proposals will not be considered received by SPA unless all internal and external components of the submission are received as outlined in the policy. 

Proposal submissions submitted after the deadlines outlined in this Policy or submitted by the deadlines in incomplete or non-final form are not assured submission by SPA.  Except under the most extenuating circumstances described in the Policy, exceptions to this Policy will not be made.

This Policy will be effective July 1, 2008 and will apply for all sponsor deadlines beginning with the NIH July 16, 2008 submission deadline.  Accordingly, for applications being submitted for the July 16 NIH deadline, a submission to SPA will be timely under the policy only if the final and complete paper submission (only the scientific content may be in draft form) is delivered to SPA by 5:00 p.m. on Monday, July 7, 2008 and the final electronic version of the submission (including the final version of scientific content) is submitted to SPA by 5:00 p.m. on Friday, July 11, 2008.

Policy on Facilities and Administrative Rate

The second attached policy, the Policy on Facilities and Administrative Rate, confirms the School of Medicine’s longstanding policy on indirect costs and is effective immediately.  Indirect costs are real costs and their recovery is critical to the financial health of the Medical Center and its ability to grow. This policy reiterates the School of Medicine’s commitment to obtain the full federally-negotiated F&A rate for all sponsored projects at the School of Medicine.  This F&A rate or indirect cost rate is negotiated by the federal government for federal grants and contracts and is based on the ratio of direct costs on funded projects, to total allowable expenses at the School of Medicine, with the assumption that it applies to all grants at the School of Medicine.  Each sponsored project the School accepts with less than the standard indirect cost rate results in a reduction in future federally-negotiated F&A rates, which can result in a real loss of funding to the School.

 The School of Medicine uses the federally-negotiated F&A rates for all federally sponsored projects at the School of Medicine as well as for industry sponsored research that does not meet the definition of clinical trial (see below).  The only standard exception is for industry-sponsored or funded clinical trials, where a 30.0% F&A rate will continue to be applied by the Office of Clinical Trials (OCT).  (Clinical trials are defined as controlled, clinical testing in human subjects of investigational new drugs, devices, treatments, or diagnostics under an industry-developed or an investigator-developed protocol.)  For state or local government sponsors or foundation sponsors, the School of Medicine will accepts a rate lower than the federally-negotiated F&A rate if that rate is published and available from the sponsor. .

This Policy also sets forth formal procedures for requesting a reduction or waiver from the standard F&A rate for a specific project.  Very few F&A rate waiver requests will be approved and none will that do not follow these formal procedures.

Questions

If you have questions regarding how the new policies might affect your sponsored project proposal, please ask Farooq Niazi (x3-3546) for SPA matters, Jean Gatewood (x3-4211) for OCT matters, and Abram Goldfinger (x3-8178) at the Office of Industrial Liaison (OIL) for matters involving industry-sponsored research that does not fall under the definition of a clinical trial.