Policies, Procedures and Guidance

GIM 01 – Review and Submission Requirements for Proposals

Contents

A Guide for the Preparation of Grant and Contract Proposals

Effective: May 12, 2014

Purpose

GIM 1 sets out the UW’s review and submission requirements for Proposals.

Background

As an applicant organization, the University of Washington (UW) has an institutional responsibility to verify the eligibility of all sponsored program Proposals submitted to a Sponsor on behalf of the UW. The institution is also responsible for reviewing the Proposal for accuracy, validity, and conformity with institutional and Sponsor policies and guidelines with respect to the administrative, fiscal, and scientific information in the Proposal, including the correct application of the appropriate Facilities and Administrative rate. This responsibility is shared within the institution by the Principal Investigator (PI), the PI’s Chair or Director and Dean, and the Office of Sponsored Programs (OSP).

In accordance with UW Executive Order 34, as the authorized signing official and as delegated by the Vice Provost for Research, OSP approves, signs, and transmits Proposals to external Sponsors.

OSP gathers needed information on the UW internal proposal routing form (eGC1). OSP reviews the Proposal, including information provided in the eGC1, in order to make the necessary representations, certifications and assurances to an external Sponsor.

Roles and Responsibilities

Principal Investigator

The PI ensures that the Proposal is complete, accurate, and meets all programmatic, administrative, and compliance requirements. The PI may delegate certain components of Proposal preparation to the PI’s research team, department fiscal specialist, department administrator, or others within the department, but the PI retains personal responsibility and accountability for the content of all portions of the Proposal, including post-submission revisions. Multiple PIs on a single project or the inclusion of a Co-PI requires the assignment of responsibilities between the PI’s in accordance with a written Multiple PI Plan or other documentation.

Department eGC1 Reviewer and Approver

The department reviews the Proposal for consistency with specific departmental policies and procedures as well as various institutional requirements. Departmental review typically includes an assessment and approval of the following: An accurate budget; costs are allowable, reasonable and allocable to the project; personnel listed are available and qualified to participate; facilities are available; any proposed cost-share is adequately documented and accurate; appointment information is accurate; Institutional Base Salary (IBS) is accurate; and any F&A waiver or GIM 19 waiver information is approved by the department official (e.g. Chair) before submission to OSP.

eGC1 Administrative Contact

This contact compiles and assembles the components of the Proposal and completes eGC1 data fields, as delegated by the PI. This individual receives OSP Reviewer Comments as well as other eGC1 reviewer comments and assists in responding to these comments and making necessary corrections and additions as delegated by the PI.

Dean’s eGC1 Reviewer and Approver

The Dean’s Office reviews and approves the Proposal for consistency with specific School/College policies and procedures and institutional deadlines. Examples of review areas: Any proposed cost-sharing on behalf of the School/College and departments within the School/College are adequately documented, authorized and approved; matching funds committed by another School or College are confirmed; facilities and other space identified in the Proposal and any new, rental or renovation of space is confirmed; School/College internal deadlines and GIM 19 deadlines are met; F&A is accurate for location and activity; F&A waivers or GIM 19 waivers, if applicable, are approved by department and School/College prior to submission to OSP.

Office of Sponsored Programs

OSP reviews Proposals submitted in a timely manner for consistency with GIM 1 using sponsor program announcements, sponsor policies, federal regulations, UW policies, OSP internal review guidance and the information provided by the PI to OSP. OSP certifies to the Sponsor that the UW will be accountable both for the appropriate use of any funds awarded and for the performance of the grant-supported project or other activities to be undertaken if the Proposal is approved and funded.

Policy

As the author and originator of the Proposal and the programmatic director of the project, the PI is responsible for ensuring each component of the Proposal is complete, accurate, and meets all programmatic, administrative, and compliance requirements prior to its submission to OSP. The PI must provide the Proposal on an eGC1 and indicate it is Ready To Submit to a Sponsor, consistent with the requirements of GIM 19. All changes to the Proposal or eGC1 made in response to reviewer comments are carried out by the PI or the PI’s delegate.

As the authorized signing official for the University, OSP will approve and submit a Proposal only after OSP determines and confirms the Proposal meets the requirements of the UW, Sponsor, and any applicable rules and regulations, is designated as “Ready To Submit” by the PI on the eGC1, and the PI has made all required assurances on the eGC1 prior to OSP approval.

If Proposal submission is carried out using a Sponsor electronic system, OSP must have access to review and submit the Proposal using the Sponsor’s system. Failure of the PI to grant OSP access to the final Proposal in accordance with GIM 19 requirements may result in either no Proposal submission or a failure to submit the Proposal before the Sponsor’s deadline.

Deliberate withholding of information, falsification, misrepresentation or carelessness in carrying out the processes, authorizations, notifications, or responsibilities required to making necessary assurances on the eGC1 may result in administrative actions, such as withdrawal or rejection of a Proposal, suspension and/or termination of an award, debarment of the PI, project personnel or the UW, as well as the imposition of civil fines and criminal penalties.

Aspects of Proposal Reviewed by OSP

OSP carries out a Proposal review using a number of tools, sources of information, and guidance, including Sponsor program announcements, Sponsor policies, federal regulations, UW policies, OSP internal review guidance, and the information provided and approved by the PI and other eGC1 approvers. In addition, OSP assesses whether information in the eGC1 is consistent with the Proposal.

The following criteria are used by OSP when reviewing competing Proposals that reach IN OSP status in SAGE/SPAERC in accordance with GIM 19 deadlines. OSP will assess whether the Proposal is complete and satisfies the following:

• Sponsor and University eligibility requirements.
• Sponsor formatting, page limit, and technical requirements are followed and University business data are correct.
• Sponsor’s specific budgetary requirements.
• Facilities and Administrative (F&A) costs are calculated in accordance with GIM 13.
• Mandatory cost-share requirements are met, or, if prohibited by sponsor, cost-share is not presented in proposal. If cost-sharing is included, it is not done so inadvertently, the UW cost-sharing unit or party has reflected its approval and the cost-sharing is consistent with federal requirements.
• All proposed subrecipients satisfy the University’s documentation requirements in GIM 7.
• The requisite compliance approvals are met.

Incidental to its Proposal review, OSP may, but is not required, to identify other areas needing clarification or changes outside the scope of the above criteria.

Components of the Proposal or eGC1 that need revision are brought to the attention of the PI and eGC1 Administrative Contacts by OSP in the OSP Reviewer Comments as either “Required Changes” or “Recommended Changes”. Upon the Proposal’s return to OSP, OSP will verify only that these changes were addressed and that any new programmatic components not previously available upon first review are consistent with Sponsor formatting requirements.

Proposals that fail to meet the GIM 19 deadline requirements, but are granted a deadline waiver, may receive less than a full review. Due to limited time by the PI to respond to OSP Reviewer Comments, the Proposal is at higher risk of a missed Sponsor deadline, submission errors, or return by Sponsor without review. OSP will use reasonable efforts to review and submit Proposals when there has been a GIM 19 deadline waiver approval, consistent with OSP and reviewer workload and available resources.

Research Performance Progress Reports (RPPRs), “After-the-Fact” awards, industry-sponsored clinical trials, master agreements, and other items routed on an eGC1 that are not considered Proposals are reviewed using review criteria applicable to the item and are not subject to this policy.

Aspects of Proposals NOT Reviewed by OSP

Accuracy and acceptability of information that are the exclusive responsibility of the PI, the reviewing Department and School/College will not be reviewed by OSP and include the following:

• Grammar, spelling, sentence structure, jargon, scientific and technical terminology, punctuation, and abbreviations
• Grantsmanship, including strategy, persuasiveness, and significance
• Scientific and technical merit
• Correct application of non-research related UW policies, such as academic human resource rules
• Academic value of the research activity
• Reasonableness of the commitment of faculty and staff effort, and possible impacts to teaching and other obligations
• Facilities and resources listed as available for use
• Accuracy of salaries listed for individuals, including faculty and staff
• Sufficiency, adequacy, appropriateness, and accuracy of the budget for the proposed research/activity (see GIM 2)
• Department or School/College PI eligibility rules
• Debarment, suspension or ineligibility status of key personnel
• Qualifications and training of personnel to carry out the proposed research or other activity
• Qualifications of subrecipients proposed to participate in the project
• Correct linking by proposed collaborators in sponsor systems

Procedures and Guidance

eGC1 Requirements

All Proposals to external sponsors for support of research and research facilities, University-administered traineeships and fellowships, institutes and special teaching programs, and other University activities which are to be supported wholly or partially with non-University funds, shall be submitted on an eGC1.

Incomplete eGC1s, eGC1s containing significant inconsistent information with the attached Proposal, or eGC1s that do not contain a Proposal (when eGC1 is routed for application to an external Sponsor) will be returned without review by OSP. The “IN OSP” date on an eGC1 will not be considered timely per GIM 19 deadlines if any of these circumstances apply.

An eGC1 is also required for other items; review When is an eGC1 required?

All eGC1s must be “IN OSP” status and complete prior to Office of Sponsored Programs (OSP) review.

PI Assurances made on eGC1

Upon approval of an eGC1, a PI makes assurances and certifications to the University. These include the following:

• The application is Ready To Submit to the Sponsor (when “Ready To Submit” is answered “yes”).
• All Investigators on the project have read the UW Investigator Financial Conflict of Interest Policy for Sponsored Projects (GIM 10).
• The PI and other Key Personnel (anyone involved in the design, conduct or reporting of the research) have not been debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from covered transactions by any federal department or agency.
• All statements in the eGC1 and related Sponsor application (Proposal) are true, complete and accurate to the best of his/her knowledge. He/she is aware that any false, fictitious, or fraudulent statements or claims may subject him/her to criminal, civil, or administrative penalties.
• He/she agrees to accept responsibility for the scientific conduct of the project and to provide the required progress reports if a grant (award) is made as a result of the application.
• PI accepts his/her responsibilities under University policies to administer and conduct a resulting award. This includes, but is not limited to, the following:
  • Fiscal Responsibility of the award (GIM 2)
  • Ensuring subrecipients are making reasonable progress, monitoring compliance with regulations and the terms of the subaward, and invoiced costs are appropriate for the technical/scientific work performed (GIM 7)
  • Pre-award spending is consistent with sponsor policy and federal regulation (GIM 9)
  • Delegated authority from the PI to others in support of University policy is documented appropriately (GIM 2)
  • Internal and sponsor deadlines, including those for progress reports and final reports, are met (GIM 19 and GIM 39)
  • Regulatory compliance, such as IRB approval, IACUC approval, biosafety procedures, and other requirements per federal regulation and University policy, are met (GIM 20, GIM 27)
  • Effort reporting is completed and reflect a reasonable estimation of effort (GIM 35)
  • Management, retention and protection of Research Data (GIM 37)

Other related University policies, such as Administrative Policy Statements and Executive Orders, may impact the sponsored program and the PI’s assurance on the eGC1 is a reflection of intent to adhere to those policies as they apply.

OSP Required Changes and Recommended Changes

As the Authorized Signing Official, the Office of Sponsored Programs (OSP) maintains oversight over institutional Proposal Review Criteria. This Criteria is set out in GIM 1.

During Proposal review, OSP will use the Proposal Review Criteria, the Sponsor program announcement, Sponsor policies, Federal regulations, UW policies and OSP internal review guidance. In addition, OSP refers to the information provided on the eGC1 by the PI and other eGC1 approvers.

If components of the Proposal or eGC1 need revision, OSP will provide OSP Reviewer Comments to the PI and eGC1 Administrative Contacts. OSP supplies this information as either Required Changes or Recommended Changes and returns the eGC1 to the PI.

• Required Changes are changes that must take place prior to submission to a Sponsor.
• Recommended Changes are changes that are suggested by OSP based on its review.

The PI is responsible for all changes to a Proposal. The PI or his/her delegate is encouraged to contact OSP about OSP Reviewer Comments if clarification is needed. When the eGC1 is returned to OSP, OSP re-reviews that OSP Comments were addressed. This re-review is facilitated by the PI/dept responding to each Comment in turn. If it is not clear that changes were made, this can cause delay and potentially lead to the need for the PI to request a GIM 19 waiver.

In addition to Required Changes, OSP may make Recommended Changes based on the review under each Criterion, that, if not addressed, may impact the success of submission, the chance of Sponsor review, the funding success of the proposal, or may seriously delay the processing of funding. We highly recommend these changes be made, along with any Required Changes.

In all cases, OSP reserves the right to require changes not currently listed above based on the specific review, the sponsor requirements, and changes to institutional policy.

Required Changes

Below is the current list of areas that Require Change by the PI or Department representative, based on the OSP Review, prior to submission to a Sponsor. Note this is not a complete list of all areas of review by OSP under each Criterion:

Criterion 1: Sponsor and University eligibility requirements are met.

Area of Review	Issue	Solution (Dept or PI action)
Sponsor limits the number of proposal submissions coming from one institution.	No Limited Submission Committee approval to move forward.	Achieve Limited Submission Committee Approval and provide on eGC1.
PI is delinquent with final report submission on another project.	PI is on Closeout Delinquency List maintained by OSP per GIM 39.	PI submits delinquent final reports to Sponsor, provides copy of final report to closeout@uw.edu with receipt of submission.

Criterion 2: The proposal meets sponsor formatting, page limit, and technical requirements and the business data is correct.

Area of Review	Issue	Solution (Dept or PI action)
Sponsor required format, fields, sections, character requirements, and attachments.	Submission without the changes will lead to an “ERROR” message upon submission via Grants.gov or other Sponsor system, or is known to cause “Return without Review” by the agency.	Change text, characters, page limit, attachment format, or other component of proposal that is not meeting sponsor technical requirement.
Institutional data is accurately listed.	Business data is incorrect.	Modify business data listed consistent with UW requirements. Review Institutional Facts and Rates.

Criterion 3: The proposal meets sponsor’s specific budgetary requirements.

Area of Review	Issue	Solution (Dept or PI action)
Administrative costs are presented as a direct cost.	There is no justification.	A justification consistent with OMB Cir. A-21 is required. See GIM 23, Administrative and Clerical Salaries, for more information. In all cases, OSP approval of Proposal does not indicate acceptability of the cost as a direct cost. A justification consistent with Federal Uniform Guidance is required. See GIM 23, for more information. In all cases, OSP approval of Proposal does not indicate acceptability of the cost as a direct cost

Criterion 4: Facilities and Administrative (F&A) costs are calculated in accordance with GIM 13

Area of Review	Issue	Solution (Dept or PI action)
Facilities and Administrative (F&A) cost calculation.	Miscalculation results in higher F&A recovery than should be requested.	Review GIM 13 and make recalculation to be consistent with location, activity, period of performance and other factors that impact correct rate selection.

Criterion 5: The proposal meets mandatory cost-share requirement or, if prohibited by sponsor, cost-share is not presented in proposal. If cost-share included, it is intended to be cost-share, and the commitment is documented and cost-sharing unit/party has reflected its approval via SAGE approval graph, via e-mail, or by third party letter commitment.

Area of Review	Issue	Solution (Dept or PI action)
Cost-share presented in Proposal.	Commitment from cost-sharing entity/party not apparent on eGC1 or within attached documents.	Add UW Cost-sharing unit to approval graph and route eGC1 for approval , or obtain e-mail from that unit for inclusion on eGC1. If third party, include third party commitment letter.

Criterion 6: All proposed subrecipients meet the University’s documentation requirements in GIM 7

Area of Review	Issue	Solution (Dept or PI action)
Subrecipient Documentation is provided.	Required subrecipient documentation is not provided on eGC1 or as part of Proposal.	Obtain all necessary subrecipient documentation before GIM 19 deadline, or if not achievable, seek GIM 19 waiver.

Criterion 7: The requisite compliance approvals are met.

Area of Review	Issue	Solution (Dept or PI action)
University is CERTIFYING to the fact we have a compliance approval at time of Proposal submission.	Compliance approval (e.g. protocol approval, signed assurance from responsible office is not obtained).	Provide compliance approval information within answers to Compliance questions on eGC1 or as attachment to eGC1.
Investigators have made SFI disclosures.	An Investigator listed on eGC1 has not made an SFI disclosure, as reflected on the PI&Personnel page of the eGC1.	Notify Investigator of need to enter the Financial Interest Disclosure System (FIDS) and disclose.

In all cases, OSP reserves the right to require changes not currently listed above based on the specific review, the sponsor requirements, and changes to institutional policy.

After-the-Fact (ATF) eGC1s

The University is not required to honor any obligations, expressed or implied, which have not been properly authorized.

Any commitment of University resources must be approved by the Department, School and OSP via the eGC1 process, per Executive Order 34.

On occasion, sponsors begin negotiations by providing a draft agreement, award letter, or a check directly to an Investigator. In order to obtain University approval “after the fact”, an eGC1 is required

Review & Submission guidance for ATF eGC1s for Agreements & Awards.

More information about award review and requirements is found in Award Review and Set Up.

University sponsored program policies and procedures apply to all sponsored funding. This includes the correct application of Facilities & Administrative (F&A) rates to the budget used by the Sponsor to make an award.

The PI and their department are responsible for the lack of full sponsored program cost recovery.

Definitions

Authorized Signing Official 
The individual with authority to legally bind the UW as a party with respect to grants, contracts and related agreements, assurances, certifications, and representations. Sponsors may refer to the Authorized Signing Official as in a number of ways including “Authorized Organizational Representative”, ”Grant Official”, or “Institutional Official”. The Authorized Signing Official may also delegate authority to staff within OSP to act on behalf of the UW.

eGC1
The UW electronic grant and contract internal routing form and auditable source of record for UW Proposals and related approvals.

Facilities & Administrative Rate or F&A Rate
The various rates established by the UW through negotiation with the cognizant federal and other agencies for costs incurred for a common or joint objective that cannot be identified readily and specifically with a particular sponsored project.

Proposal
An application submitted by the UW on the recommendation of a PI to a Sponsor seeking funding or other support for a project. Generally, a Proposal will contain a scope of work, budget, budget justification, along with collaborator letters of intent, and other sponsor-required documentation, as applicable. Typically, Proposals are submitted in competition with other applicants and usually in response to a broadly-distributed Sponsor-issued solicitation for funding, request for proposal, or other funding opportunity announcement. Categories of competing Proposals include, but are not limited to: New, Resubmissions, Competing Renewal, Competing Revisions, Competing Supplements and Transfers to the UW that require application documentation. GIM 1 Proposal Review Criteria do not apply to other items that may route on an eGC1, such as Research Performance Progress Reports (RPPRs), “After-the-Fact” awards, and industry-sponsored clinical trials as well as various types of non-award agreements, including master agreements, affiliation agreements, confidentiality agreements, data use agreements, and material transfer agreements.

Ready To Submit
A Proposal status in which the Proposal is deemed to be full and complete and in final format that is ready for submission to the Sponsor. A Ready to Submit Proposal includes all completed required Sponsor forms, components, sections, and attachments, consistent with Sponsor program announcements and policies. A Proposal is not Ready To Submit if it does not conform to all applicable policies and requirements of both the Sponsor and the UW.

Sponsor
A federal agency, private entity, non-profit organization, institution or other entity external to the UW that provides funding, equipment, support, or other tangible items, such as goods or services, for research, instruction, training, or other sponsored activity.