| Policy Title | Review and Approval of Sponsored Project Documents Policy |
|---|---|
| Policy Category | Academic/Research Policies |
| Original Policy Approval Date | April 12, 2017 |
| Policies Superseded | None |
| Responsible Office | Office of Sponsored Research and Programs |
| Related Policies | Principal Investigator Eligibility and Assurances Policy; Facilities and Administrative Costs Recovery and Distribution Policy |
| Frequency of Review | 5 Years |
| Date of Next Review | July 2030 |
I. Scope
The Review and Approval of Sponsored Project Documents Policy (“Policy”) applies to all University faculty and staff who plan to submit a Proposal for a Sponsored Project to a Sponsor.
II. Policy Statement
The purpose of this Policy is to ensure that all Proposals to external Sponsors undergo a suitable level of review prior to submission by the Office of Sponsored Research and Programs (OSRP), which is the only office authorized to submit and legally obligate Proposals on behalf of Arcadia. OSRP’s review ensures that:
- Personnel and other-than-personnel resources required for the project and provided by the University will be available in the event of an award,
- Budgets proposed and associated justifications are accurate, and the full Proposal is complete and complies with applicable University and sponsor requirements, and
- Certifications and assurances represented by OSRP upon submission are supported by current, available documentation.
This internal pre-review facilitates the University’s adherence to its applicable policies and procedures and in the event of an award, the Sponsor’s award terms and conditions.
III. Policy
It is the Policy of Arcadia University that all Proposals for external funding be internally reviewed as described herein prior to submission by OSRP to the Sponsor. Internal review protects the University’s interests by ensuring that:
- The proposed activities are aligned with the University’s mission;
- The materials submitted adhere to the Sponsor’s instructions;
- The resources needed to conduct the Sponsored Award will be available; and
- The University can comply with all applicable certifications, assurances and other requirements associated with the Award.
In the event a Proposal does not follow this Policy, the University reserves the right to withdraw a Proposal following its submission or reject an Award that has been granted.
A. Internal Proposal Review
Most Proposals will be reviewed and approved only by the chairs and deans of the Investigators involved as well as the OSRP prior to submission. Any Proposal whose total project cost exceeds $500,000 or includes voluntary or mandatory cost sharing or other institutional costs will also be reviewed by the Provost.
(i) Responsibilities
The Principal Investigator/Project Director (PI/PD) shall be responsible for preparing and submitting to OSRP a complete Grant Proposal Routing and Approval Form (GPRA) no less than 10 business days before the Sponsor’s submission deadline. The GPRA identifies:
- The PI/PD and other Investigators identified in the Proposal.
- The Sponsor, funding opportunity title and number, submission deadline
- Project information e.g., start/end dates; indirect cost rate applied, etc.
- Compliance requirements, e.g., IRB, IACUC, hazardous substances, export controls, etc.
- Institutional obligations, e.g., cost sharing, course release, etc.
- IDC distribution
- PI/PD and Investigator certifications and assurances
- Review and approval by PI/PD and Investigator department chairs/supervisors, deans.
An accurate budget and associated justification is foundational to the chair and dean review and approval. Therefore, the PI/PD should work with OSRP as early as possible to ensure the budget’s accuracy and completeness. To meet the GPRA internal submission deadline (see Budget Development and Internal Review Timeline presented below), PI/PDs shall be responsible for verifying that all collaborating Investigators fulfill the Financial Conflict of Interest (FCOI) reporting and training requirements and all other certifications prior to application submission as attested by their signature on the GPRA form.
The PI/PD is responsible for distributing electronically the completed GPRA with the applicable proposal documents to all Investigators and their chairs/deans for their certifications, review and approval according to the Budget Development and Internal Review Timeline presented below.
Chairs and deans shall be responsible for ensuring, and their signature so attests, that personnel and non-personnel resources required (e.g., space, course release, student support, cost sharing, etc.) are available and will be provided in the event of an award; and that to the best of their knowledge, the funds requested are reasonable given the scope of the proposed project.
The OSRP is responsible for the accuracy of budget developed, completeness of justification, and adherence to applicable regulations and requirements, including but not limited to debarment and financial conflict of interest.
(ii) Budget Development and Internal Review Timeline
| Business days before the Sponsor submission deadline: | What to provide to OSRP: |
| As soon as decision is made to apply | -The solicitation URL or other available instructions -The application deadline (if there is more than one) -Investigators: the PI/PD and other Arcadia faculty or staff participating -Non-AU collaborators and their OSRP points of contact |
| 15 business days before | Draft budget materials following: -OSRP Budget Template -OSRP Budget Justification Template -Draft project narrative for comparison to the budget NOTE: the Provost’s signature will be required for projects whose total costs > $500,000 or include cost sharing regardless of the $ amounts. |
| 10 business days before | Final Materials from Collaborators –Subrecipients. Subrecipient Commitment Form (or equivalent) from Authorized Organizational Representatives of individuals/teams collaborating via subawards, their budget and justification, negotiated indirect cost agreement if applicable. –Consultants. Letters of collaboration specifying work to be performed, rate of compensation, and total payment. –Contractors/Vendors. Quotes for large purchases Materials from AU investigators |
| 7 business days before | The final, complete application for securing final internal approvals and upload to the Sponsor portal or/and submission to the Sponsor. |
Adherence to this timeline ensures OSRP has sufficient time to conduct internal review and protect the university interests as specified in Section II and III of this Policy.
PIs/PDs are strongly encouraged to notify OSRP as early as possible about their intent to submit a proposal, especially for complex projects involving multiple institutions and collaborators, and significant institutional commitments.
(iii) Non-adherence to the Internal Review Timeline
If final Proposal documents are submitted to OSRP less than seven (7) business days before the submission deadline to the Sponsor, OSRP will make reasonable efforts to review the Proposal but cannot guarantee the proposal submission to the Sponsor. The PI/PD and their supervisors will be promptly notified of the situation and possible scenarios discussed if time and PI/PD are available.
IV. Definitions
Authorized Organizational Representative (AOR). The administrative official at Arcadia University who (i) certifies that Arcadia will comply with all applicable assurances and certifications referenced in the Proposal or applicable instructions; (ii) certifies that Arcadia will be accountable both for the appropriate use of funds awarded and for the performance of the project or activities resulting from the Proposal; and (iii) represents that the organization complies with applicable Federal laws and regulations, including required certifications and assurances, its application, and the terms and conditions of individual awards.
Award. Funds that have been awarded to the University by a Sponsor for a particular Sponsored Project.
Financial Conflict of Interest (FCOI). A significant financial interest that could directly and significantly affect the design, conduct, or reporting of research. All Investigators must disclose SFIs related to their institutional responsibilities as required by federal regulations and University policy.
Investigator means any person, regardless of title or position, who is responsible for the design, conduct or reporting of research proposed to an external sponsor. Investigators include the PI/PD, key or senior personnel or co-investigators.
Principal Investigator/Project Director (PI/PD). The individual/s designated by the University to have the appropriate level of authority and responsibility to direct the Sponsored Project.
Proposal. An application or letter of intent that outlines a proposed Sponsored Project and contains all information requested by a Sponsor for a Sponsored Project.
Sponsor. The organization or funding agency which will fund a Proposed Project.
Sponsored Project Documents. All required documentation required by the Sponsor for its consideration for a Sponsored Award that is authorized by the AOR.
Sponsored Award. A formal written agreement memorializing the Award, such as the grant agreement, sub-award agreement, cooperative agreement, contract, or fellowship, etc.
Sponsored Project. Externally funded activities in which a formal written agreement such as a grant, award, sub-award agreement, cooperative agreement, contract, or fellowship is executed between University and the Sponsor. Gifts are not included in this definition and are not covered by this Policy.
University. Arcadia University, its colleges, schools, affiliates, divisions and subsidiaries.
V. Effective Date
This Policy is effective on the date that it is approved by the President.
VI. Date of Approval
April 12, 2017, revised April 22, 2019; June 6, 2022
