GIM 01 – Review and Submission Requirements for Proposals
Contents
Background
Policy
Purpose
GIM 1 sets out the UW’s review and submission requirements for proposals for sponsored programs.
Background
As an applicant organization, the University of Washington reviews a proposal for accuracy, validity, and conformity with institutional and sponsor policies and guidelines with respect to the administrative, fiscal, and technical information in the proposal. 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).
The Principal Investigator compiles required information on the UW internal proposal routing form (eGC1) and sponsor systems as applicable. OSP reviews the proposal, including information provided in the eGC1, to make the necessary representations, certifications, and assurances to an external Sponsor.
Policy
The University of Washington (UW) has an institutional responsibility to verify that the University can make the commitments set out in proposals submitted to sponsors. The Office of Sponsored Programs is the UW’s authorized signing official delegated by the Vice Provost for Research (UW Executive Order 34).
OSP provides institutional review and approval of proposals prior to submission to a sponsor. OSP has unilateral authority to determine if anything would prevent submission of the proposal or acceptance of an award. As the institutional official, OSP makes the final determination on which certifications are required and whether institutional certifications can be made as part of the proposal. The University is not required to honor any obligations, expressed or implied, which have not been properly authorized.
As the author and originator of a 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.
The PI must provide the proposal on an eGC1, consistent with the requirements of GIM 19, including making required PI assurances. All changes to the proposal or eGC1 made in response to reviewer comments are carried out by the PI or the PI’s delegate.
Deliberate withholding of information, falsification, misrepresentation, or carelessness in carrying out the processes, authorizations, notifications, or responsibilities required to make necessary assurances on the eGC1 may result in sponsor administrative actions. These actions may include:
- withdrawal or rejection of a proposal
- suspension and/or termination of an award
- debarment of the PI, project personnel, or the UW
- imposition of civil fines and/or criminal penalties
Proposals that fail to meet the GIM 19 deadline requirements, but are granted a deadline waiver, will receive less review, and as a result, the proposal is at higher risk of a missed sponsor deadline, submission errors, or return by sponsor without review.
Institutional Review
OSP provides an institutional review of proposals submitted in a timely manner, consistent with GIM 19. OSP review is based on the sponsor program announcements, sponsor policies, federal regulations, UW policies, OSP internal review guidance, and the information provided on the eGC1 and in the proposal.
OSP’s proposal review involves identifying issues that could create financial, audit, or compliance risks for the UW. The elements of institutional review are:
- University is eligible to apply.
- University business data are correct.
- Facilities and Administrative (F&A) costs are calculated in accordance with GIM 13, based on the information provided in the eGC1.
- 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 provided its approval, and the cost sharing is consistent with sponsor requirements.
- All proposed subrecipients satisfy the University’s documentation requirements in GIM 7.
- The PI, together with responsible units, addresses required compliance areas (such as ability to meet research data privacy and security requirements) applicable to the project, and/or including any approvals required by the University needed from compliance offices at time of proposal.
- Preliminary review of terms, conditions, or commitments at the proposal stage that may obligate the University (financially, programmatically, or otherwise) and therefore the University must decline to submit or require additional documentation.
Incidental to its proposal review, OSP may identify other areas needing clarification or changes outside the scope of the above criteria, such as carrying out review that sponsor’s technical instructions are met.
As needed, OSP may return an eGC1 for changes. Upon the eGC1’s return to OSP, OSP will only verify that these changes were addressed.
In all cases, OSP reserves the right to require changes based on the specific review, the sponsor requirements, and changes to institutional policy. OSP may also decline to submit a proposal based on institutional review.
At time of award, the University of Washington reserves the right to negotiate the terms and conditions of the award, per GIM 2.
Aspects of Proposals Review by PI and Campus Units, including Department, Schools & Colleges
OSP relies on campus units’ & PI approvals of an eGC1 to indicate PIs, Departments, and Schools/Colleges have provided substantive review of the following aspects contained within a proposal.
Accuracy and acceptability of the following information are the responsibility of the PI, the reviewing Department, and School/College, as reflected by the PI’s Assurance on the eGC1, as well as campus unit approvers:
Personnel
- Personnel Eligibility (includes Principal Investigator)
- No Conflict of Commitment
- Reasonableness of the commitment of faculty and staff effort, including possible impacts to teaching and other obligations
- Institutional Base Salary (IBS) and commensurate salary request are accurate
- Debarment, suspension, or ineligibility status of key personnel
- Qualifications and training of personnel to carry out the proposed research or other activity
- Qualifications of subrecipient personnel
- Correct application of and consistency with UW Academic HR rules to personnel and students proposed on project
- Appointment information is accurate
Proposed Programmatic Components
- Grantsmanship, including strategy, persuasiveness, and significance
- Scientific and technical merit
- Academic value of the research activity
- Scope of Work meets sponsor and proposal guidelines
- Any F&A waiver or GIM 19 waiver information is approved by the department official (e.g., Chair) before submission to OSP
Facilities, Resources, and IT Capabilities
- Accurate portrayal of subrecipients and vendors
- Facilities and resources listed are available for use
- Correct location information is listed, and commensurate F&A rate used
- All information, data, equipment, materials proposed for use are available
- Research data privacy and security requirements can be met, including technical, administrative, or organization measures required by sponsor
- Required documentation to support authorized official certification to the sponsor
- Proposed budget is sufficient, adequate, appropriate for the proposed research/activity see GIM 2, GIM 13, GIM 23
Formatting and Sponsor Technical Instructions
- Proposal available & accessible to OSP in sponsor system, if applicable
- Proposal attached to eGC1, including all related attachments in their complete form. This includes all requested documentation by a pass-through entity.
- Collaborator elements appropriately associated/linked in sponsor systems (for example NSF collaborative proposals)
- Current RFP used, if applicable, and sponsor application templates are completed and accurate
- Required sponsor forms or letters are accurately completed and ready for authorized official signature
- Technical Instructions are followed and consistent with sponsor requirements, such as: Appearance, titles, and headings, naming conventions, format, page limit, order, required attachments, and content of the proposal.
- Grammar, spelling, sentence structure, jargon, scientific and technical terminology, punctuation, and abbreviations
Compliance with University Limited Submission requirements.
eGC1 Requirements
All proposals to external sponsors for sponsored activities must be submitted on an eGC1.
Review GIM 19 for internal deadline details and requirements.
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 their knowledge. They are aware that any false, fictitious, or fraudulent statements or claims may subject them to criminal, civil, or administrative penalties.
- They agree 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 their responsibilities under University policies to administer and manage a resulting award. This includes, but is not limited to, the following:
- Fiscal Responsibility of the award, including documenting delegated fiscal authority to others in support of University policy 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 & GIM 8
- Pre-award spending is consistent with sponsor policy and federal regulations GIM 9
- 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
- Compliance and management with applicable intellectual property provisions per GIM 40
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 and Recommended Changes
The Office of Sponsored Programs (OSP) maintains oversight over institutional review.
If components of the proposal or eGC1 need revision, OSP will provide required changes and/or recommended changes as OSP Reviewer Comments on the eGC1 to the PI and eGC1 Administrative Contacts and return it 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. When the PI/department returns the eGC1 to OSP, OSP re-reviews that OSP Comments were addressed. This re-review is facilitated by the PI/department 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 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.
Roles and Responsibilities
Principal Investigator (PI)
The PI ensures that the proposal is complete, accurate, and meets all programmatic, administrative, and compliance requirements. This includes sponsor requirements for the funding opportunity and designation of the appropriate sponsored program activity type.
While the PI may delegate certain components of proposal preparation to their team and/or departmental staff, the PI retains personal responsibility and accountability for all portions of the proposal, including post-submission revisions and just-in-time information.
PIs are also required to make eGC1 assurances, any other sponsor required assurances, and to ensure Multiple PIs make the same certifications.
Identify all UW investigators for the project per GIM 10 and obtain requisite FIDS disclosures.
Campus eGC1 Reviewers and Approvers
Campus units are responsible for handling all Aspects of Proposals Review by PI, Department, Schools & Colleges as well as following their own specific unit and school policies and procedures. The eGC1 approvals reflect that all appropriate individuals have been informed or reviewed.
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.
Office of Sponsored Programs
OSP provides an institutional review of proposals submitted consistent with GIM 19.
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 activities to be undertaken if the proposal is approved and funded.
Change Notes
Details on changes to this GIM are available from the Office of Sponsored Programs, osp@uw.edu