Research Policy Handbook

Preparation, Review and Submission of Sponsored Project Proposals
(RPH 10.1)

Current Version: May 2, 2011

Summary:

Summarizes University policy and procedures with respect to the preparation, review and submission of proposals for external sponsorship. Requirements related to budget justification incorporated in December 1999. Requirement related to commitment of PI effort for research projects was established in March 2001 and revised in May 2011.   Clarification related to student-initiated proposals added in 2009 upon recommendation of the Committee on Research.

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 Research Policy Handbook document 3.2, 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.

1. SUBMITTING PROPOSALS FOR SPONSORED PROJECTS
   

   The Office of Sponsored Research (OSR) is the central administrative office responsible for submitting proposals and accepting awards on behalf of Stanford University. The Director 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 (see memo).

   1. 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.

   2. BUDGET JUSTIFICATIONS
      

      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 Research Policy Handbook 3.6, 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 (see Research Policy Handbook 3.6). 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. 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.

   3. 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 Principal Investigator. The provisions for rare exceptions to the policy on Principal Investigator eligibility are applicable (see RPH 2.4, Principal Investigator Eligibility and Criteria for Exceptions).

2. ACADEMIC POLICIES PERTAINING TO RESEARCH
   
   1. PRINCIPAL INVESTIGATOR ELIGIBILITY
      

      Only members of the Academic Council are eligible to submit proposals to outside agencies. Academic Council members include the ranks of Assistant Professor, Associate Professor and Professor, and in the non-tenure line, Professor and Associate Professor of [Subject], (Teaching), (Performance), (Clinical), (Research), or (Applied Research), as well as certain senior University staff.

      Any exceptions to this policy must be approved by the appropriate School Dean, and by the Vice Provost and Dean of Research, as outlined in Research Policy Handbook 2.4, Principal Investigatorship (PI) Eligibility and Criteria for Exceptions. A copy of the approval memorandum must be part of the final proposal package submitted to the Office of Sponsored Research.

      Stanford University requires all Principal Investigators to review their obligations for stewardship of sponsor funds and compliance with applicable regulations. For that purpose, specialized briefings are conducted. Individuals may also certify their review of this material on a web site (https://www.stanford.edu/dept/DoR/PIship/).

      Those ineligible for principal investigator status may be identified as Associate Investigators, but not as Co-Principal Investigators.

      Professors Emeriti must be recalled to active duty during the period of any research grant or contract for which they are Principal Investigator. This is done by the academic department, which submits a Short-Form Appointment Request through the Dean's and the Provost's Offices. Permission to submit a proposal is contingent upon this appointment, and no formal acceptance of the grant or contract may be made until the appointment is in hand. A signature of departmental approval on the proposal routing sheet signifies the department's willingness to recall the faculty member.

      Proposals must be submitted in the name of the individual who will be primarily responsible for the scientific, technical, and fiscal direction of the project. Submission of the proposal in the name of a "nominal" principal investigator who then delegates primary responsibility to an ineligible PI is inconsistent with the responsibility of Academic Council members for the intellectual direction of the University and is not permitted.

   2. EDUCATIONAL COMPONENT
      

      Sponsored projects should have an educational component, typically evidenced by student involvement (either with or without charge to the project), for purposes of training and support of students doing thesis or dissertation-level research.

   3. OPENNESS
      

      Proposals must not result in a grant, contract, or any form of agreement whose terms would violate the policy on Openness in Research adopted by the Academic Senate (Research Policy Handbook 2.6). The University will not accept a project which violates this policy. To avoid questions of conflict of interest or non-compliance with the Openness in Research policy, the full identity of a particular sponsor must be made known for all sponsored projects. [See Openness in Research checklist.]

   4. PRESENCE AT STANFORD
      

      In cases where the principal investigator of an on-going campus-based project will be away from campus for a period of three months or more, another Academic Council member should be named as Acting PI to assume direction of the project, subject to approval of the sponsoring agency. In addition, in the case of federal grants, such absences require prior written approval by the sponsor. See discussions related to this subject in the following Research Policy Handbook documents:

      4.1,	Faculty Policy on Conflict of Commitment and Interest
      3.1,	Fiscal Responsibilities of Principal Investigators
      10.3,	Acting Principal Investigatorship

3. POLICIES RELATED TO RIGHTS AND SAFEGUARDS
   

   Any proposals for activities involving:

   • human subjects (for either medical or non-medical research)
   • laboratory animals
   • radiological hazards
   • biohazardous agents, including recombinant DNA

   require the approval of a protocol by the appropriate Administrative Panel for Research Compliance (see Research Policy Handbook 1.4). These Panels assure Stanford's compliance with applicable federal regulations in these areas. Questions in this regard may be directed to the Research Compliance Director.

4. POLICIES PERTAINING TO UNIVERSITY COMMITMENTS
   
   1. COMMITTED LEVEL OF EFFORT
      

      The level of effort, expressed as a percentage of the total professional effort, that a faculty member commits to spend on any sponsored project must be consistent with other academic duties. The total percentage of effort committed (1) in the budgets of active sponsored projects, (2) for cost-sharing and other contributed effort, (3) teaching, and (4) administrative efforts must not exceed 100% of the individual's total University appointment.

      Stanford University requires a commitment of efort on the part of the Principal Investigator during the period in which work is being performed. This effort may be expended during the aademic year, summer quarter only, or both. Committed effort shall be direct charged or cost shared.

      This requirement does NOT extend to:

      • equipment grants
      • seed grants for students/postdocs where the faculty mentor is named as PI, dissertation support, training grants or other awards intended as "student augmentation"
      • limited-purpose awards characterized by Stanford as Other Sponsored Activities, including travel grants, conference support, etc. (see Categories of Sponsored Projects, Research Policy Handbook 3.4, for definition and further examples of Other Sponsored Activities.)
   2. SPACE
      

      If the project cannot be housed within pre-identified existing available department or laboratory space, commitments for the additional space required need the approval of the Department Chair, Dean, and other offices as appropriate unless they are of a minor remodeling nature for which funds have already been approved. The University cannot commit itself to finding incremental space for a project whose needs have not been reviewed and approved in advance.

   3. COST SHARING
      

      Whenever Stanford University agrees to pay a portion of the allowable costs of a sponsored project, i.e., those costs which would otherwise be paid by the sponsor, the University has made a cost sharing commitment. Any proposal including such a commitment must be so identified on the Proposal Development & Routing Form. Note that any promise to provide effort or other services as part of a proposed project at no direct cost to the sponsor constitutes a cost sharing commitment. Voluntary effort above and beyond what was committed does not have to be treated as cost sharing. See Stanford policy on Cost Sharing, Research Policy Handbook 3.5.

   4. SUBCONTRACTS
      

      Proposals that include large or complex subcontracts for specialized equipment or services should be reviewed with the OSR Contract Officer before preparing the final proposal. Subcontracts for research or development must comply with the applicable clauses of the prime contract. See also Subcontracts, Research Policy Handbook 3.7.

      Public Law 95-507 requires each Government Prime Contract over $500,000 to have an approved subcontracting plan. The Procurement Department provides coordination and assistance in this regard.

   5. USE OF CONSULTANTS
      

      When retention of consultants is proposed, advance consultation with the Procurement Department (for SLAC, the resident Staff Counsel) is encouraged. See also Retention of Consultants (Research Policy Handbook 9.5), or refer to the definition of "employer/employee relationship" in section 1 of Administrative Guide Memo 35 [pdf file].

   6. PARTICIPATION BY FACULTY OR STAFF FROM MULTIPLE DEPARTMENTS
      

      The appropriate Department Head and Dean's Office must approve participation of faculty or staff in sponsored projects outside their own academic department or School via an authorizing signature on the Proposal Routing Sheet.

   7. HOSPITAL SERVICES
      

      Proposals for biomedical research, including clinical trials, may require pricing information for hospital services. Contact the Research Management Group in the School of Medicine for this information.

   8. USE OF SLAC FACILITIES
      

      Main campus research proposals contemplating use of the SLAC laboratory facilities require prior coordination and approval by the SLAC Associate Director for Business Services.

   9. FACILITIES AND ADMINISTRATIVE (F&A), I.E., INDIRECT COSTS
      

      Stanford's policy is to apply the University's full relevant F&A cost rate to all externally-sponsored research projects. Proposals including provision for indirect cost recovery at rates or bases less than those established by the University's negotiated agreement with the Federal Government require written approval from the appropriate School Dean and, in some cases, by the Vice Provost and Dean of Research before submission to OSR. Such approval will be granted only for compelling reasons.

      Some non-profit sponsors, who have established their own policies on the levels of Facilities and Administrative costs which they will fund, may be pre-approved for a waiver of Stanford's negotiated F&A cost rate. OSR and the Office of the Dean of Research maintain the list of these sponsors.

      See also Indirect Cost Waivers (Research Policy Handbook 3.10).

   10. TUITION
       Projects proposing to fund tuition charges as direct costs, particularly for future years, should be checked with the office of the School Dean to be sure the rates quoted are consistent with University estimates. See Tuition Allowance for Research Assistants (Research Policy Handbook 3.9) and Estimated Tuition Charges for Sponsored Projects [Stanford-only access]
5. ADVICE AND ASSISTANCE
   

   The Office of Sponsored Research and the Office of the Vice Provost and Dean of Research are available to assist with unusual or special questions in connection with sponsored project proposals. In the School of Medicine, questions may also be referred to the School Research Management Group.