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 Services. 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 Children's Hospital at Stanford, 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) is the central administrative office responsible for submitting proposals and accepting awards on behalf of Stanford University. The Associate Vice President of OSR can grant various levels of signature authority to others both inside and outside of OSR 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 staff or to the Office of the Dean of Research.
Adequate lead time is needed for review because sponsors increasingly are enforcing proposal submission dates stringently. OSR requires five working days to review proposals, and reviews in the order in which completed proposals are received.
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.
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.
As a result of negotiating the FY99 F&A (indirect cost) rates, Stanford has committed to the Office of Naval Research that written 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 and other administrative expenses (see RPH: Charging for Administrative and Technical Expenses). Particular care must be given to the A-21 and Cost Accounting Standard (CAS) 502 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: an explanation of the activities that make the project "major" as defined by A-21 and Stanford Policy. A "major" project is one that requires an extensive amount of administrative or clerical support, which is significantly greater than the routine level of such services provided by academic departments.
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).