14.1 Preparation, Review, and Submission of Sponsored Project Proposals
This policy has been affected by the new federal Uniform Guidance regulations.
Summarizes University policy and procedures with respect to the preparation, review, and submission of proposals for external sponsorship.
Stanford depends to a large extent on external sources to support programs of research, instruction, and scholarship. Due to the growing complexity of conditions attached to sponsored projects, plus a trend toward greater diversity in sources of support, this policy will apply to the preparation, review, and submission of proposals for external sponsorship.
This policy applies to all proposals for work to be carried out in Stanford academic departments, laboratories, administrative units, and at Stanford Health Care. In addition, the terms of this policy also apply to proposals which commit Stanford resources for projects to be performed off-campus, including affiliated institutions, such as the Stanford Children's Health, the Palo Alto Veterans Administration Hospital, Santa Clara Valley Medical Center, etc.
See RPH, Definitions and Categories of Sponsored Projects, for further discussion of factors which determine whether a project is a sponsored project, and for which proposals must be handled in accordance with this policy.
The Vice Provost and Dean of Research retains the authority to approve exceptions to this policy.
2. Submitting Proposals
The Office of Sponsored Research (OSR) and the Research Management Group (RMG) in the School of Medicine are the central administrative offices responsible for submitting proposals and accepting awards on behalf of Stanford University. The Associate Vice President of OSR and the Director of RMG can grant various levels of signature authority to others both inside and outside of OSR and RMG to submit proposals and/or accept awards, as appropriate. Sponsored Project proposals must be submitted and awards accepted only by individuals authorized to sign the necessary documents. Questions in this regard may be directed to OSR or RMG staff or to the Office of the Dean of Research.
Adequate lead time is needed to review the proposal against sponsor guidelines, University policy, and federal regulations. In addition, many proposals are submitted via electronic sponsor systems where electronic validation errors and technical difficulties can occur. Proposals with missing or non-compliant components are frequently rejected by sponsors.
A complete proposal package must be submitted to OSR or RMG via the Stanford Electronic Research Administration (SeRA) system 5 full business days in advance of the sponsor’s deadline. This includes the complete proposal application, budget and justification, relevant approved waivers, and subaward documentation (see RPH 16.2). All administrative portions of the proposal must be complete and final. The technical components of the proposal can be a draft at this stage, but must be finalized at least 3 full business days in advance of the sponsor’s due date.
More information on the implementation of the policy can be found in the links below.
A. Proposals Involving Policy Exceptions
Proposals which involve any exception to University policy, e.g., requests for PI exceptions or Facilities and Administrative (F&A), i.e., indirect cost waivers, are subject to the approval of the appropriate School Dean, and, in some cases, the approval of the Office of the Vice Provost and Dean of Research. Such approvals should be sought as soon as practical, and must be received prior to submission of the proposal to OSR or RMG.
B. Budget Justifications
The primary purpose of a justification is to provide support for the funds requested to ensure adequate funding. Experience has shown that including budget justifications in the proposal increases the likelihood that the sponsor will award the cost.
Budget justifications will be included in sponsored project proposal budgets for costs normally treated as F&A costs that are proposed as direct costs, except when not required by the sponsor (e.g., NIH Modular Grants). This requirement includes proposed direct costs for equipment, operations and maintenance, and administrative salaries (see RPH: Charging for Administrative and Technical Expenses). Particular care must be given to the federal requirement that costs incurred for the same purpose in like circumstances shall be treated consistently as either a direct cost or an F&A cost. The following are key elements that are to be included in budget justifications:
- a description of the expense or service
- how it relates to and benefits the project
- the anticipated cost
- the time-period in which it will be utilized
- any other information that will aid the sponsor in evaluating and funding the proposed item of cost
For administrative charging to federal sponsors only: describe how the administrative role is integral, i.e., essential, vital or fundamental, to the project.
Some sponsors provide rebudgeting authority that would allow a PI, after an award is received and the project is in progress, to rebudget awarded dollars within the project scope.
If, during the course of the project the PI becomes aware of other expenditure needs that were not included in the proposed budget, rebudgeting within the sponsor's provisions is permitted. This includes equipment, operations and maintenance, or administrative costs that are normally treated as F&A costs. Of course, all other provisions of Stanford and sponsor policy for acceptability of the costs as a direct charge must be met.
When costs are explicitly listed and justified in the sponsor accepted budget, grant/contract administrators, auditors, and sponsoring agencies can easily understand the nature of the costs and their allowability under the regulations.
C. Student-Initiated Research
In the circumstances where a student has initiated a research project, a proposal will normally need to be submitted with a faculty member as PI. The provisions for rare exceptions to the policy on PI eligibility are applicable (see RPH: Principal Investigator Eligibility and Criteria for Exceptions).