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School of Medicine Virginia Commonwealth University VCU Medical Center

Grant Submission Process

Instructions and Guidelines for Submitting
Sponsored Programs Proposals

Revised: November, 2007

Introduction

According to established University policy, faculty who wish to receive research and training grants from or provide research and training services to external entities, including the federal, state and local governments, private industry, public and private foundations or other entities, must submit their proposals for internal review and approval prior to submission to the external agency or organization. The Dean, School of Medicine, must approve all sponsored programs proposals submitted by or involving any faculty or staff in the School of Medicine. All proposals approved by the Dean must also be reviewed and approved by the University’s Office of Sponsored Programs Administration (OSPA).

These instructions and guidelines are intended to clarify the policies and procedures concerning the submission and review of sponsored programs proposals and to provide for a more rapid review and approval process.

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General Questions

Who in the Dean’s Office can review and approve sponsored programs proposals?

Only the Dean or his designated representative may review and approve sponsored programs proposals. Individuals who may review and approve School of Medicine proposals are: Jerome F. Strauss, Ph.D., M.D., Dean, Gordon L. Archer, M.D., Associate Dean for Research, George D. Ford, Ph.D., Assistant Dean for Sponsored Programs Administration, and Steve T. Sawyer, Ph.D., Professor of Pharmacology and Toxicology.

Who may submit sponsored programs proposals?

Any faculty member of the School may submit proposals. Non–paid faculty must sign a participation agreement. Graduate students, residents and fellows may submit fellowship proposals with faculty sponsorship. Although not generally expected of staff, any staff member who has the approval or sponsorship of his/her faculty supervisor may submit proposals. Newly–hired individuals who have signed a faculty employment contract have not officially started may also submit proposals.

The proposal should normally include only individuals who are employees of VCU. If individuals who are not currently VCU employees are included in the funding proposal, please be aware that this does not guarantee that the individuals named will be hired. EEO policies require a position search or waiver, if no search is warranted. The proposal should clearly identify any individual who is not currently an employee of VCU.

Is it necessary to submit a complete, polished proposal?

It is not necessary to submit a complete, polished proposal. However, it is necessary to submit enough of the application to judge what overall techniques are being proposed, what experimental subjects will be used and what general idea is being addressed. At a minimum, the proposal should include the required “Sponsored Programs Internal Approval Form,” the sponsor’s “face page,” the complete budget for every year in the proposal, the proposal abstract, identification of the key personnel involved in the project, a calculation of the Facilities and Administrative Costs (F&A) and a description of the resources and environment available to the project.

What does the reviewer look for?

Primarily the reviewer is looking to see that you are proposing to do something that meets all ethical standards and that it complies with all School, University, state and federal policies with regard to sponsored programs. The reviewer may make suggestions but will not make a judgment as to the scientific quality. Please note that all proposals must adhere to accounting standards as detailed in federal OMB Circular A-21. To insure this, all programs must contain a budget either using the spreadsheet provided by the Office of Sponsored Programs or the budget requested by the sponsoring agency.

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By the Numbers: A Step-By-Step Guide for Completing
the Sponsored Programs Internal Approval Form

All sponsored programs proposals must be accompanied by a Sponsored Programs Internal Approval Form [Word], commonly referred to as the “green sheet.” This form is available from the VCU Office of Research along with a set of instructions.

Page 1

I. Principal Investigator Information

Generally these are self–explanatory. In the case of a fellowship proposal, the faculty sponsor is considered to be the principal investigator (mentor). The applicant fellow is named in a separate line.

II. Sponsor/Agency

Generally these are also self–explanatory. Please check the type of proposal. It must agree with the Facilities and Administrative (F&A) Costs (often referred to as either indirect or overhead rate) entered in Section III.

  • Name of Sponsor (Agency): Provide the name of the agency to which the application will be submitted (e.g., National Institutes of Health).
  • Proposal Identification Number: This number is usually known at the time of submission for renewal applications, supplemental requests and responses to numbered requests for proposals (RFPs). For clinical trials, use the protocol number. Leave blank or indicate “n/a” if the proposal number is not known.
  • Type of Proposal: Select one type: 1) Research, 2) Clinical Trial, 3) Training/Fellowship or Other. “Other” includes equipment grants, conferences, special travel grants, etc.

III. Proposal Information

  • Title: Provide the title for the proposal as it appears on the application.
  • Status of Proposal: Indicate whether the proposal is 1) New, 2) Non–competing continuation, 3) Competing continuation, 4) Supplement.
  • Budget Summary: These numbers must agree with those shown on the budget pages in the body of the application.
  • Facilities & Administrative (F&A) Costs: On PHS proposals you now must calculate Facilities & Administrative costs (F&A costs) as requested on the checklist page. If you need assistance with your calculations, please call the Office of Sponsored Programs Administration (8-6772). Note that if F&A costs are prohibited or limited (less than the University’s full rate), please include documentation (i.e., guidelines from sponsor, letter of request for limitation, etc.), unless the sponsor and rate are listed on OSPA’s web page. Check which base will be used in determining F&A costs: a) MDTC (Modified Total Direct Cost): Consisting of salaries & wages, fringe benefits, materials, supplies, services, travel and sub–grants and sub–contracts up to $25,000 of each sub–grant or sub–contract (regardless of the period covered by the sub–grant or sub–contract). MTDC shall exclude equipment, capital expenditures, charges for patient care, tuition remission, rental costs of off-site facilities, scholarships and fellowships, as well as the portion of each sub–grant and sub–contract in excess of $25,000; or b) TDC (Total Direct Cost): the total of all direct costs. Agreement Type: CR=Cost Reimbursement; FUC=Fixed Unit Cost; TFC=Total Fixed Cost.
    • Additional Guidance: Please note the Dean’s Office will NOT check your calculations. If you make a mistake granting agencies will not allow you to make compensatory changes in the award amounts. The Dean’s Office will check to be sure the appropriate institutional F&A Costs rate has been applied. If you are not sure of the appropriate rate, check with OSPA either by phone or their Web site. If you are requesting a reduction from either the standard institutional F&A Costs rate or the minimum rate allowed by the granting agency, you must attach strong justification which must be endorsed by your departmental chair. Small budgets alone are not strong enough reasons to justify reduced F&A rates.

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Page 2

I. Percent Effort and Percent Responsibility

  • Percent Effort: The table requires percent effort for all key personnel, percent support requested and percent responsibility. The percent responsibility is not the same as percent effort, rather it is how the responsible work will be divided and must add up to 100 percent. Although at this writing this is for informational purposes only, in the future it may be used to determine how the budget and F&A revenues are allocated to different departments. If in doubt, 100 percent responsibility should be attributed to the principal investigator.
  • Portions of your salary requested by the grant/contract? This should match the percent effort you cited in answer to the previous question; otherwise cost–sharing rules are in effect.
    • Additional Guidance: If the proposal requires such an entry, this figure must match that in the proposal. If the proposal does not require such an entry, you may enter any figure you like, although it must be at least 1 percent. Remember it should match the amount of salary support requested; otherwise cost–sharing rules will be in force. The most common mismatch is when agencies such as NIH impose salary caps or limits on what they will allow regardless of percent effort. For example, the current NIH salary cap is $186,600 although it will likely go up in the next federal fiscal year. If you are making over this, you must limit your compensation request to this figure, i.e., 25 percent on a $200,000 salary is limited to a request for 25 percent of $186,600 or $46,650. The difference is a cost–share. See the section on Additional Guidance regarding how to calculate and report this. There are several ways to incorporate this into your NIH budget calculations. The preferred way is to cite your full compensation and if that exceeds the NIH cap but calculate the requested amount based on the cap not your true compensation. In modular budgets you should use your full compensation. The InfoEd system will automatically calculate the cost–sharing for you.

II. Compliance Data

  • Will the project include use of human subjects? Provide the requested information. If you will be using human subjects in your project and have not already done so, please contact the staff in the Office of Research Subjects Protection either through their Web site or by telephone (804-828-0868) for instructions on obtaining review by our Institutional Review Board (IRB). If use of humans is pending, it is the responsibility of the principal investigator to ensure timely submission of updated information to the sponsor.
    • Additional Guidance: “Human subjects” is interpreted to mean any human material including subject information, surgical or autopsy material if subject personal information accompanies it, human blood, serum and human cell lines if not commercially obtained. If there is any question at all, it is the duty and prerogative of the VCU Institutional Review Board (IRB) to decide what disposition is needed. Many procedures are quickly granted permanent exemptions. Inclusion of a copy of an exemption greatly facilitates proposal review. If IRB review is called for, please enter the IRB approval number and date of the most recent annual review. If the approval is “pending,” please give the date of the submission. Remember no trials may begin until approval is granted.
  • Will the project include use of vertebrate animals? Provide the requested information. If you will be using vertebrate animals in your project and have not already done so, please contact the secretary of the Institutional Animal Care and Use Committee (IACUC) for instructions. If use of animals is pending, it is the responsibility of the principal investigator to ensure timely submission of updated information to the sponsor.
    • Additional Guidance: This question applies to live animals, even those which will be used for tissue, blood or cells. It does not apply to perpetuated animal cell lines. Please give the IACUC approval number and the date of the latest annual review. If pending, please give the date of submission. Remember even though approval is not absolutely necessary for proposal submission, many agencies will not review proposals until approval is obtained.

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Page 3

III. Questions (continuing on page 3 of the form)

  • Does the project involve rented off–campus facilities? If YES, is rent included in the budget? Off–campus facilities are facilities not owned by the University for which rent is being charged. The appropriate off–campus Facilities & Administrative (F&A) rate should be used in the project proposal.
    • Additional Guidance: These questions are used by the Office of Sponsored Programs Administration to determine if your proposal is eligible for off–campus F&A cost rates. If rent is not included, you should include some documentation as to why your proposal qualifies for off–campus rates. Please note that the Virginia Biotechnology Research Park is considered on–campus while the McGuire Veterans Affairs Medical Center (VAMC) is off–campus. The creation of the VCU Health System Authority (7/1/2000) further complicates the determination of activities as on– vs. off–campus. Generally, University use of MCV Hospital facilities is governed under a lease arrangement. If you plan to use MCV Hospitals facilities, contact the sponsored programs reviewer for the School of Medicine for further guidance.
  • Does the project utilize wet lab space? If this is a clinical trial, the answer is no by policy. Otherwise the answer is yes unless the proposal exclusively deals with data which can be handled within an office.
  • Does the project require additional/new space at VCU? If the answer is yes, please provide documentation that the request has been approved by the School’s Research Space Management Committee.
  • Does the proposal include one or more other institutions or organizations? Notification is needed by Sponsored Programs Administration in order to provide adequate and appropriate assistance to you in the issuance of your sub–awards. Sub–awards (consortium costs) are for those organizations making a substantive contribution to the goals of the project. Does not include “consultants.”
  • Will program income be generated? Gross income (revenue) derived by the University from activities financed in whole or in part with funds from a sponsored program award (i.e.: service fees, sale of commodities, certain intellectual property income, usage and rental fees). For alternatives, contact OSPA.
    • Additional Guidance: Almost always the answer is NO. If the answer is YES, again OSPA must be notified for the appropriate agreements and to alert Grants & Contracts Accounting. This is necessary because of the potential tax liability, among other things.
  • Does the project involve research on infectious substances (i.e. HIV, etc.)?
    • Additional Guidance: Contact Environmental Health & Safety’s Chemical/Biological Safety Section for assistance in the proper use, storage, etc. of infectious substances.
  • Does the research involve recombinant DNA/hazardous substances (subject to appropriate regulations)? If your proposal includes the use of recombinant DNA, hazardous substances, or infectious waste, you should answer “yes.” Guidelines are administered by Environmental Health & Safety’s Chemical/Biological Safety Section. Specific information regarding approval and procedures should be sought prior to completing this form.
    • Additional Guidance: Answering yes to either of these questions means the institutional Biohazard Committee must approve the protocol.
  • Does the project involve retired faculty? If yes, prior approval by the chair and Dean is required.
  • Does the project require use of HIPAA-Covered Data? See comments under IRB approval.
  • Will sub-contacts be required if funded? This is a way for the departments of co–investigators to have a separate budget.
  • Does the project involve internationals? This is currently for informational purposes.
  • Does this project require delivery of anything more than technical report(s)? Generally the answer is no.
  • Does the project utilize the services of another VCU department or Center? If yes, the Chair or Center Director must sign on page 4.

The PI must sign the bottom of page 3.

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Page 4

  • Award Sub–account Distribution Form
    • If you choose to set up sub–accounts for other departments involved, please fill out the requested information.
  • Required Signatures
    • Note: The PI and all key personnel should sign this form. The Chair or Center Director for investigator must sign and also the Dean of any other school involved.

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Page 5

This is an extra page in case you run out of space on page 4. It may be deleted if not needed.

  • The University now requires that all sponsored programs proposals must be accompanied by a Conflict of Interest Form [Word] signed by all key personnel.

    • Additional Guidance: Voluntary and Mandatory Cost Share. Understanding the difference between these two types of cost sharing can be confusing, however reporting these costs accurately is now federally mandated. A detailed description of cost sharing is included in the School of Medicine’s Cost Sharing Guidelines. Cost sharing occurs anytime the direct or indirect costs of a sponsored program are not fully met by the sponsor. Usually this is encountered when percent effort on a program and percent salary received do not match. However other kinds of cost sharing may occur, particularly in view of the wide diversity of sponsoring agencies to which our faculty apply. Perhaps the most overlooked one is created when the applicant requests an institutional reduction in F&A Costs which amounts to voluntary cost sharing. To accurately account for these costs, our Grants and Contracts Accounting office has established a system where they set up separate accounts to monitor cost sharing dollars. This system does require a lot of extra paper, but it does not, as yet, involve any expenditure of your monies beyond what you have already committed to. With each proposal that contains cost sharing you must submit the OSPA Cost Share Authorization Form [Excel] which identifies the source of cost sharing by account code or third party (in the case of MCV Physicians or the Veterans Affairs Medical Center). At the time of submission of a proposal, only the general area of the account code is necessary, i.e., 1– or 4– or 6–ledger, etc. However, a precise code must be given at the time of award. When it comes to deciding whether or not the cost sharing is voluntary or mandated, the following are the most common situations with regard to faculty:
      1. The agency sets no limits on support but requires you to cite percent effort. Claiming 10 percent effort but only five percent support results in voluntary cost sharing.
      2. The agency caps support but requires you to cite percent effort. Claiming 10 percent effort but $0 salary support (the cap, as say in American Heart Association) results in voluntary cost sharing.
      3. The agency sets no limits on support and does not require you to cite percent effort. (This is the situation with most clinical trials.) Claiming two percent effort but $0 salary support would result in voluntary cost sharing. Note cost sharing on industry sponsored clinical trials is not allowed.
      4. The agency requires the institution to provide matching funds for partial support of the project. This is a mandatory medcost sharing. For example the Commonwealth Research Fund requires a three to one match for all its applications.
      5. A less obvious form of voluntary cost sharing arises when an agency requires a certain percent effort but only provides a fixed amount of support. For example, the agency awards Professor X a development award that requires he spend 75 percent of his effort but only provides $50,000 in direct costs. Since Professor X makes $80,000, there is a difference between the amount provided ($50,000 = $37,342 in salary plus $12,658 in fringe benefits @ 33.90 percent) and the amount needed (75 percent of $80,000 = $60,000). The difference ($60,000 - $37,342 plus appropriate fringe benefits = $22,658 plus $7,681 in fringe benefits @ 33.90 percent = $30,339) is voluntary cost sharing.
      6. The university would like to track data to determine whether voluntary cost sharing is due to policy decisions by the agency or budgetary decisions on the part of the investigator (e.g., you request only 15 percent salary but cite 20 percent effort in the application). You may indicate on the “green sheet” whether or not the indicated voluntary cost sharing is due to agency policy or not. The Dean’s office may provide such information if you do not.
    • Additional Guidance: Graduate Student Support. The School of Medicine is in the process of revising School policies for payment of base salaries/stipends for Ph.D. graduate students beginning with the 2002-2003 academic year. These changes will require additional extramural funding for graduate education. Whenever allowable, a principal investigator should request support for Ph.D. graduate students involved in a proposal according to the following guidelines: If the proposal is research–related, each graduate student named will be an employee of the University and the PI should request a salary ($23,100 for each graduate researcher. The NIH currently limits stipend and tuition and fee support per graduate student to $36,996 per year. For these applications, the PI can request up to the remaining $13,896 to cover full or partial tuition and fees for the student. Currently the differential between in–state and out–of–state tuition and fees is covered by the school. If the proposal is for an individual or institutional training or fellowship program, the PI should request a stipend for each graduate trainee named in the training/fellowship proposal. The NIH currently limits graduate stipend ($20,772) and tuition and fees support on these training/fellowship applications. For information on these limits, contact your department administrator or OSPA. F&A costs apply to graduate salaries and stipends, but not to tuition and fees support. Also, F&A cost rates differ between federal research programs and training/fellowship programs. OSPA’s staff and their VCU Internet site can provide useful information on the appropriate F&A cost rates.
    • Additional Guidance: Please refer to the VCU Policy on Financial Interests in Sponsored Programs for more information. In addition, under the Virginia State and Local Government Conflict of Interests Act, a prohibited conflict of interest arises for an employee of VCU when the employee, or a member of his/her immediate family, has a personal interest in a firm or business which contracts with VCU. A “personal interest” generally is defined as: ownership of more than three percent of the equity or liability of the business or receipt of income or other commercial arrangement worth more than $10,000 annually from the business, which accrues to the employee or a member of the employee’s immediate family. In order to protect the integrity and objectivity of certain federally-sponsored programs, all VCU investigators who have financial interests that in some manner might influence or appear to influence the conduct of projects are required to inform the Office of Sponsored Programs Administration when the proposal is submitted. If the project is funded, the investigator must work with the Office of Sponsored Programs Administration and the School of Medicine to develop acceptable approaches to deal with any conflict of interests.

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Final Note

  • (For Faculty having VAMC appointments) The Department of Health and Human Services (DHHS) requires a “memorandum of understanding” (MOU) between the VAMC and VCU/MCV Campus for faculty applying for sponsored programs that are paid both by VCU and the VAMC. A separate MOU is needed for each proposal. More detailed information regarding these special rules and procedures can be obtained from your department administrator or the Office of Sponsored Programs Administration.
  • Questions? Please direct any question, comments or suggestions to your department administrator or the School of Medicine Dean’s Office. The Office of the Associate Dean for Research will provide as much assistance as possible. Please contact Dr. Ford at 8-0527 or ford@vcu.edu to see what assistance can be provided.

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