Guidelines for Grant and Contract Management
310. Proposal Submission Policy
The following memo was sent to Deans, Directors and Chairs on September 9, 2005. The new policy sent out from the Provost's Office established firm deadlines for receipt of proposals for review and comment at URA. It also established firm deadlines for receipt of final proposals to URA which require electronic submission.
A clarification of the policy was sent out by University Research Administration on August 30, 2006: “In order for proposals to receive a full review prior to the above submission deadline, the hard copy of the proposal is due to URA at least 3 full business days in advance of the URA electronic submission deadline day. This clarification applies to all agency/sponsor applications which have to be submitted electronically from URA”. [See full clarification announcement]
Because the proposal process varies depending upon your particular location in a division, school, or unit of the University, it is important to consider how these requirements will affect the routing of your proposals prior to their arrival at URA, and what internal timetables you may need to establish to accommodate the new requirements.
Should you have any questions about the new policy or the clarification, please contact Susan Boone.
Revised 9/07
MEMO
To: Deans, Directors, Chairs
From: Keith Moffat
Louis Block Professor, Department of
Biochemistry and Molecular Biology
Deputy Provost for Research
Mary Ellen Sheridan
Associate Vice-President for Research
and Director, University Research Administration
Subject: New University Research Administration (URA) Deadlines Policy
Background
Almost 15 years ago the Provost’s office and URA issued a policy stating that proposals were required to be submitted to URA five days in advance of the sponsor’s deadline. This lead time was intended to permit URA staff sufficient time to evaluate proposals to certify that commitments offered can be honored, that information provided is accurate and to assure compliance with University and sponsor policies, prior to providing institutional endorsement on the application. A summary of the items covered in the typical URA review is attached.
Unfortunately this policy has seldom been honored. Too many proposals now arrive at URA two days and sometimes two hours before the deadline. Adequate time to review proposals, make revisions and still meet the deadline for submission is often lacking. Late submissions have become stressful for everyone involved: local administrators, URA staff and the PI. There is a serious danger that deadlines will be missed, or that inaccurate information will be supplied to the sponsor.
The most urgent reason to re-examine the timing of the proposal submission process is the imminent requirement for submission of all federal grant proposals electronically through grants.gov. In time this system will become the single portal for all grant applications to federal agencies, including NSF, NIH, NASA, and DOE. NSF has required direct submission of electronic proposals from URA through NSF Fastlane for almost 10 years. PIs and local administrators develop the proposal and budget for URA review but the electronic proposal submission to NSF is done by URA staff. For many recent NSF deadlines, certain PIs have not been able to submit "final" proposals to URA until hours or even minutes before the NSF deadline. The same difficulties arise with the Army Medical Command electronic submissions. NIH is about to phase in electronic proposal submission through grants.gov, and all other federal agencies are experimenting with its use. Currently this system is in the testing phase. From our experience, grants.gov still has severe deficiencies that impact the research community: it is cantankerous, slow to access and upload files, and subject to service provider failures. We anticipate an inevitable "train wreck" when late proposal submissions to URA and unpredictable electronic proposal submission processes collide.
We have therefore re-evaluated the proposal review and submission process, and redefined the deadlines for submission of proposals for review and endorsement by URA. We also have considered what the consequences will be when PIs do not meet these deadlines and do not allow sufficient time for appropriate URA review. Our intention is to make URA’s deadlines more realistic, following a "Just in Time" model. - September 9, 2005
DEADLINES POLICY – EFFECTIVE OCTOBER 2, 2005
For purposes of this policy, a "business day" is the standard University administrative work day ( 8:30 a.m. – 5:00 p.m.). The sponsor deadline is the day the application must be submitted by the University, whether that is an electronic submission by URA or mail postmark, or shipping by FedEX, UPS or other commercial carrier.
URA "Regular" Submissions
Proposals submitted to URA 3 FULL BUSINESS DAYS in advance of the sponsor deadline day will receive normal, full review and comments by URA Grant & Contract Managers
Proposals submitted to URA LESS THAN 3 FULL BUSINESS DAYS before the deadline day are not reviewed for compliance with institutional and sponsor policies. The proposal will be entered in TRACS and "Contingent Endorsement" will be provided.
URA Electronic Submissions
Final proposals are due in URA NO LATER THAN NOON THE BUSINESS DAY BEFORE THE SPONSOR DEADLINE.
Proposals which are submitted to URA after noon the business day before the deadline WILL NOT be reviewed prior to submission. URA will make a reasonable effort to submit the proposal electronically, however for internal purposes the application will be considered as bearing a "Contingent Endorsement." [The application as submitted to the sponsor will not include any "contingent" disclaimer or special language.]
Electronic proposals will be submitted in the order in which they are received. Proposals which were submitted in a timely manner for URA review and comment will all receive higher priority than late proposals.
URA is not responsible for electronic submissions which arrive at URA too late to meet the sponsor’s deadline.
Consequences of Absence of URA Review prior to Submission
Proposals that have not been reviewed may encounter problems with submission (especially with electronic submissions), or with noncompliance with University or sponsor policies. Potential awards from submissions which did not receive prior review may not be accepted by the University unless satisfactory terms and conditions can be negotiated and compliance with these policies assured.
Contingent Endorsement
When a proposal arrives at URA with too little time to carry the normal institutional review, it will be given only a cursory examination sufficient to enter accurate application data into TRACS and routed by Grant & Contract Manager for "contingent" institutional endorsement. If terms and conditions contrary to University policy are found upon review after submission, the proposal may be withdrawn; or acceptance of an award will require removal or modification of any troublesome clause(s), or satisfactory resolution of deviations from University or sponsor policies.
BSD "Blue Folder" Deadline
By agreement between URA and BSD ORS, proposals which are considered "minimal risk" are submitted directly to the URA endorsing official for review and signature. Proposals processed through the "Blue Folder" process are due in URA NO LATER THAN NOON THE DAY BEFORE THE SPONSOR DEADLINE.
Unfortunately, these must all be hard deadlines. There can be no exceptions.
URA PROPOSAL REVIEW FUNCTIONS
- Financial/budget review:
- Cross check data on Proposal Transmittal Form (PTF) with application
- Check for allowable budget items when detailed direct cost budgets are required by sponsor
- Assure correct, fair and consistent application of F&A rates
- Confirm correct MDTC base
- Confirm correct application of nonprofit, private sector and clinical trial overhead rates
- Confirm budget justification matches budget and personnel commitments
- Confirm cost sharing/matching funds
- Confirm correct application of fringe benefit rates
- Subaward/subcontract documentation and budgets
- Nonfinancial reviews:
- Publication rights are assured
- Data ownership/access is consistent with University policy
- Treatment of confidential or sensitive information is consistent with University policy
- Research compliance - human and animal subjects, biosafety, financial conflict of interest, export controls
- Completion of Representations & Certifications
- Intellectual property/patents, inventions rights, copyrights – consistent with University policy
- Indemnification requirements
- Confirm insurance requirements are met
- Confirm Agency-specific formatting and submission requirements
- Confirm accurate subaward and consulting documentation
- Assistance with Small Business Plans, when required
- Confirm accuracy of Sponsor Checklist, if required
- Confirm accuracy of "Other Support" and Pending Applications, if required
- Assure agency prior approvals are provided when required by sponsor
- Confirm documentation required by sponsor is included in application (e.g. supporting letters, annual reports, audit reports, list of trustees, etc.)
- Take exception to sponsor policies (Terms and Conditions of award) which conflict with University of Chicago policies
- TRACS data
- Accurate financial and nonfinancial information for all applications must be recorded in TRACS
