UAF Uniform Proposal Review Policy

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UAF Policy Number: 004-001

When UAF faculty, staff, or administrators submit proposals for external funding, they are acting on the behalf of the University. For that reason, UAF policy requires that all proposals for external funding be reviewed by the Office of Sponsored Programs. The OSP will conduct a proposal review and obtain the AOR's signature indicating UAF's overall endorsement of the proposal before the unit or PI submits the proposal to the prospective funding agency.

TABLE OF CONTENTS

Section A. Policy Statement, Description of Process, and Mandatory Requirements

Policy Statement

1. Definitions
2. Certifications When Signing a Proposal
3. The Proposal Review Process
     a. Proposal Routing Form Review
     b. Proposal Abstract and Body Review
     c. Budget Review
     d. Proposal Problems
     e. AOR Approval
4. UAF Rights Regarding Proposals and Awards
5. Unauthorized Proposal Submissions
6. Archival of Proposals and Record Keeping

Section B. Policy Approval

Section A. Policy Statement, Description of Process, and Mandatory Requirements

Policy Statement

The purpose of this policy is to ensure a uniform and consistent review of all Proposals submitted by the University of Alaska Fairbanks to sponsors for funding, and ensures compliance with sponsor/agency, state, federal, and university regulations and policies.

1. Definitions

Sponsored Program

A sponsored program is a research or educational project that is funded by a source outside the institution. Activities funded through grants, contracts, and cooperative agreements are sponsored programs. A sponsored program is initiated with a Proposal to the sponsor and followed by an award with specific terms, objectives, rights, and reporting requirements. The sponsor, whether it is federal, state, or private holds the University accountable to meet designated terms in exchange for project funding.

Sponsors include federal agencies, state and local governments, private foundations, businesses and corporations, and foreign organizations. Federal agencies and many private foundations have detailed information on funding opportunities on their web sites.

Proposals

A proposal is a request made of a sponsor to fund a project. Proposals may be submitted in response to a solicitation (e.g., a Request for Proposals, an Announcement of Opportunity, a Request for Applications, etc.) or unsolicited. Proposals for external funding are submitted on behalf of UAF, but composed and executed by the Principal Investigator (PI). The resulting awards are made to UAF’s post-award authority (The Office of Grants and Contracts Administration). For the purpose of this policy, grant proposals, cooperative agreements*, memorandums of understanding/agreement*, reimbursable services agreements, and revisions to non-awarded Proposals are referred to as “Proposals.” All Proposals must receive Authorized Organizational Representative approval before submission.

Authorized Organizational Representative (AOR)

The AOR is the individual within UAF that has been delegated signature authority by the Chancellor to approve Proposal submissions to external sponsors.

The AOR at UAF is the Director of the Office of Sponsored Programs. The AOR holds the sole responsibility of granting institutional approval to proposal submissions.

*Cooperative agreements and MOUs/MOAs executed within the scope of facilitating a sponsored program only.

2. Certifications When Signing a Proposal

Each person who signs a Proposal certifies different responsibilities:

• An agreement to do all work as proposed;
• That there are no significant conflicts of interest (financial or other);
• An agreement to be the overall project manager;
• An agreement to abide by all applicable regulations, policies and procedures related to the project; and
• An agreement to accept responsibility for the scientific and ethical conduct of the project.

• An agreement to do all work as proposed;
• That there are no significant conflicts of interest (financial or other);
• An agreement to abide by all applicable regulations, policies and procedures related to the project; and
• An agreement to accept responsibility for the scientific and ethical conduct of his or her portion of the project.

The Dean’s/Director’s/Department Head’s signature certifies:

• That PI and Co-I/Co-PI work loads are within 100% of effort;
• That unit resources are available and allocated;
• That matching/cost share commitments are authorized and committed; and
• That all space considerations in the project have been accounted for.

The Unit Fiscal Officer’s signature certifies:

• That the Proposal budget is in compliance with sponsor/agency, state, federal, and university policies, regulations, and standards.

The Office of Sponsored Programs’ signature certifies:

• That the Proposal review was conducted in accordance with this policy; and
• That the Proposal passes that review sufficiently to receive institutional approval.

The Authorized Organizational Representative’s (AOR) signature certifies that:

• UAF has the appropriate facilities, resources, and systems in place to administer and monitor the award in compliance with sponsor/agency, state, federal, and university policies, regulations, and standards;
• UAF is committed to the project and agrees to complete the project as proposed if an award is made; and
• That all certifications and assurances in the Proposal are understood, are true statements, are agreed to, and will be abided by.

3. The Proposal Review Process

The following review process is mandatory for all Proposals originating from UAF departments/institutes/schools (units) before AOR approval will be granted. UAF’s Office of Sponsored Programs conducts these reviews. The units will allow five business days (at minimum) for Proposal review and any necessary revisions before AOR approval.

a. Proposal Routing Form Review

Each Proposal will include a Proposal Routing Form. This form ensures that uniform information about the Proposal will be tracked and readily identifiable as the Proposal moves through the pre-award and post-award phases. The Proposal Routing Form will be reviewed for accuracy, consistency, and special considerations as outlined:

• Ensure the PI is a faculty member, has an approved exemption, or has included a memo to the AOR to request exemption from any the UAF PI Policy.
• Ensure that the Conflict of Interest statement is signed by all PIs and Co-Is and Senior Researchers;
• Identify any Research Compliance issues (e.g. IACUC, IRB, Biohazards, or Chemical Hazards) and check with the Office of Research Integrity (ORI) to verify application/approval;
• Identify any Research Restrictions (e.g. Classified Research, ITAR/EAR, Restriction on Publications, or Restrictions on Non-Resident Employment);
• Identify any Intellectual Property/Technology Transfer (IP/TT) issues (e.g. Potential for Intellectual Property Disclosure or Potential for Program Income);
• Identify any matching/cost share (M/CS), and ensure it is mandatory, that a memo to the AOR from the unit dean/director is included, and the agency’s published terms showing that it is mandatory M/CS are included. All instances of M/CS must be allowable per OMB Circular A-21 and conform to all provisions of OMB Circular A-110. UAF as a policy does not allow voluntary cost share;
• Identify any subawards, and ensure a budget, a statement of work, and a statement of institutional endorsement from each subrecipient’s AOR is included;
• Identify any reductions from full allowable F&A recovery, and ensure that the sponsor’s published terms showing that is a mandatory reduction are included. Any fees for reduced F&A will be assessed to the unit, unless they complete a waiver request in memo form which is approved by the Vice Provost for Research and Vice Chancellor for Administrative Services;
• Check the unit cover page, if applicable, for consistency with the Proposal Routing Form

b. Proposal Abstract and Body Review

The Proposal abstract and body will be reviewed as outlined:

• Ensure completeness of the Proposal package per the sponsor’s guidelines (if applicable);
• Ensure the format of the Proposal package follows the sponsor’s program announcement (if applicable);
• Read the abstract/text and identify/address any potential Research Compliance, Research Restriction, or IP/TT issues as outlined in Section 3.a. above

c. Budget Review

The Proposal budget will be reviewed as outlined:

• Ensure correct addition of the budget totals;
• Ensure dollar amounts are consistent throughout the Proposal text, Routing Form, cover page, budget, and current and pending support (if applicable);
• Ensure items are in the correct budget categories and are direct or indirect costs;
• Ensure that only allowable costs are listed as per OMB Circular A-21 and consistent with the UAF Cost Accounting Standards Board Disclosure Statement for Educational Institutions (UAF CASB DS-2);
• Ensure that salaries have been calculated correctly for faculty, staff, and students;
• Ensure that appropriate leave and benefit rates have been used per UAF’s current negotiated agreement, or that the use of projected rates has been disclosed in the budget narrative/justification;
• Ensure that tuition remission has been included for graduate student research assistants employed during the academic school year, if allowed by the sponsor;
• Ensure that travel categories have been identified (domestic/international), that trips are listed separately, and that the correct per diem rates are applied;
• Ensure that a budget narrative/justification based on the UAF OSP model has been included with the Proposal package, regardless of sponsor requirements;
• Ensure that the budget narrative/justification corresponds to the budget and supports the scope of work;
• Ensure that any applicable UAF Recharge Center rates are correct;
• Ensure that MTDC has been calculated per UAF’s negotiated agreement;
• Ensure that F&A recovery is calculated properly;
• Ensure that the correct F&A rate is being used per UAF’s negotiated agreement and/or the sponsor’s guidelines;
• Ensure any instances of M/CS, subawards, or reduced F&A are identified/addressed as outlined in Section 3.a. above.

d. Proposal Problems

     Problems that arise with a Proposal during review will be addressed with the unit’s representative and/or PI in order to resolve them in a timely manner.

     If the problems are not solved sufficiently to pass review, the Proposal will be returned to the unit representative and/or PI with an explanation, a timeframe, and potential solution(s) to remedy the problems. Proposals that are not corrected within the deadline for submission will not be authorized or submitted.

     Problems will be documented on a review worksheet and kept with the copy of the Proposal to be archived as a record that all problems have been resolved before AOR approval, Proposal submission, or setup of award.

e. AOR Approval

Once the Proposal review has been completed and the Proposal has passed the above review, it can be submitted to the AOR for institutional approval, provided the AOR finds no problems with the Proposal. The Proposal is then authorized for submission to the sponsor.

4. UAF Rights Regarding Proposals and Awards    

Proposals that are submitted that do not allow sufficient review time may be authorized and submitted solely at the AOR’s discretion, with the stipulation that a full review will take place after submission. The UAF administration reserves the right to withdraw the Proposal at any time and/or reject any award made on the Proposal if any issues of non-compliance or other serious problems are discovered that place the University of Alaska Fairbanks at unnecessary financial or legal risk.

5. Unauthorized Proposal Submissions

The University of Alaska Fairbanks only authorizes Proposal submissions with AOR approval. If a Proposal is submitted to the sponsor without AOR approval, the full Proposal package must still be reviewed. The PI will attest to their understanding of the process of authorized Proposal review and submission, and will agree to not submit an unauthorized Proposal again. If this agreement is violated, disciplinary action may be taken. The PI, their dean/director, the AOR, the Vice Provost for Research and the Vice Chancellor for Administrative Services will sign this agreement and each be given a copy. AOR signature will be granted if the Proposal passes review as outlined in this policy. If the Proposal does not pass review, it will be withdrawn. Any award granted as a result of an unauthorized Proposal submission may be rejected at UAF’s discretion as stated in Section 4. above. The PI will also be required to submit an explanation as to the nature of the unauthorized submission.

6. Archival of Proposals and Record Keeping

 A hard copy of every Proposal will reside in the UAF Office of Sponsored Programs, where it will be archived for minimum of two (2) years. In addition, an electronic database will be kept that shows details about each Proposal for statistical analysis and reporting.

Proposals will be checked by the UAF Office of Sponsored Programs in the Banner Proposal Module (FRAPROP) to ensure that their status has been marked as submitted (S).

 A quarterly report will be furnished by the OSP to the AOR and Vice Chancellor for Administrative Services for the purpose of tracking fees assessed to units for reductions in F&A recovery.

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