Pre-Award Resources

1. “I am not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from current transactions by an federal department or agency.”
   As required by 31 USC 6101, prohibits the federal government is prohibited from engaging in procurement relationships with organizations or their principals who are debarred or suspended from doing business with the federal government.  For example, Dr. J. Reece Roth, the professor emeritus at the University of Tennessee in Knoxville, who was found guilty for export control violations, is currently listed on the “Excluded Parties List.”
2. “I have not and will not lobby any federal agency on behalf of this award.”
   As required by 31 USC 1352, no federal appropriated funds may be used to influence an officer or employee of Congress in connection with the making of any federal grant, cooperative agreement, or contract.  Funds other than federal funds that have been used to influence an officer or employee of any agency must be declared via completion of federal form, “Disclosure of Lobbying Activities.”  A detailed discussion of lobbying can be found on the OSP webpages in the document entitled “Federal Lobbying Regulations;” however, an abbreviated version is provided in this document as follows:
   Lobbying activities include oral, written or electronic communications to a government official regarding:
   1. formulation, modification, or adoption of Federal legislation
   2. the administration or execution of a Federal program or policy
   3. formulation, modification, or adoption of a Federal rule, regulation, Executive order, policy or position of the United States Government
   4. the nomination or confirmation of a person subject to confirmation by the Senate
   5. Lobbying activities do not include:
   6. a speech, article, publication or other material that is distributed and made available to the public through a medium of mass communication
   7. a request for a meeting, a request for the status of an action, or other similar administrative request
   8. testimony given before Congress or submitted for inclusion in the public record
   9. information provided in writing in response to an oral or written request, or in response to a request for public comments in the Federal Register
   10. required by subpoena or civil investigative demand
   11. written comment filed in the course of a public proceeding -made by the media if the purpose is gathering and disseminating news and information to the public
3. “I am aware of and agree to abide by the Stevens’ Drug Free Workplace Policy.”
   The Drug-Free Workplace Act of 1988 requires some federal contractors (Stevens) and all federal grantees (Stevens) to agree that they will provide drug-free workplaces as a precondition of receiving a contract or grant from a federal agency.  Stevens’ responsibility as a recipient is to notify employees that as a condition of employment on a federal contract or grant, the employee must a) abide by the terms of the policy statement; and b) notify the employer, within five calendar days if he/she is convicted of a criminal drug violation in the workplace.  See Stevens’ Drug-Free Workplace Policy on the Human Resources webpage. 
4. “I have filed the annual certification and any required updates with my department/college under the SIT Policy of conflict of Interest and agree to update the certification as needed and abide by this Policy.”
   As required by 42 USC 216, Stevens has developed and maintains Conflict of Interest Policies at 10.3.1 and 10.3.2 that the trustees, officers, faculty, staff, and others…avoid ethical, legal, financial, or any other actual or apparent conflicts of interest and ensure that their personal activities and interests to not conflict with their obligations to the Institute or its welfare.  Stevens’ Faculty Handbook also contains information specific to conflicts of interest in government sponsored research.  Additionally, in compliance with the requirements of 42 CFR 50, if this proposal is submitted to NIH/PHS/DHHS, a current “Conflict of Interest Certification” must be on file with the Provost or the proposal cannot be submitted.
5. “I agree to be bound by the terms and conditions of the external grant or contract which supports this proposal activity and, in consideration of the information and facilities made available to me by the University or the outside sponsor, to assign copyright and patent rights and observe the tenets of the “Stevens IP Policy” in accordance with the terms and conditions stated in the Faculty Handbook.” 
   Each sponsor has specific terms and conditions under which they award financial support for research.  For example, some want material submitted in a specific format and some federal sponsors require prior approval for all material presented at conferences and meetings.  OSP will perform a review of the award terms and conditions and note any special items on the “Sponsored Research Agreement (SRA).”  The Stevens’ Faculty Handbook contains information regarding the “Copyright Policy” at 10.6.
6. “I certify that the information submitted within the application is true, complete and accurate to the best of my knowledge and I understand that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties.” 
   As required by 31 USC 3729-3733, “…any person who knowingly presents, or causes to be presented, a false or fraudulent claim for payment or approval; knowingly makes, uses, or causes to be made or used, a false record or statement material to a false or fraudulent claim; …knowingly makes, uses, or causes to be made or used, a false record or statement material to an obligation to pay or transmit money or property to the Government…is liable to the US Government of not less than $5,000…” 
7. “I agree to accept responsibility for the scientific conduct of this proposal and to provide the required progress reports if an award is made as a result of the application.” 
   As required by 42 CFR 93 and 45 CFR 689, most federal agencies rely on NIH/PHS/DHHS and NSF’s codification regarding research misconduct in order to determine a circumstance of such misconduct.  Although not exhaustive, research misconduct is considered to be fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or in reporting research results.  All recipients of federal funds engaged in scientific research must have policies and procedures in place to identify, deal with and report any circumstances of misconduct.  Stevens’ “Policy on Research Misconduct” resides at 10.4 and 20.12 in the Policy Library
8. “I understand that any award that ensues as a result of this proposal is made to the University and not to me personally; however, I understand that I assume fiscal responsibility for any ensuring award as a result of this proposal.”
   As stated in OMB Circular A-21, an award or “…sponsored agreement…means any grant, contract, or other agreement between the institution and the Federal government…”  Further delegation in A-21 allows the “…institution [to authorize] the principal investigator or other individual to have primary responsibility…if no one person has complete control over all aspects of a financial transaction…”  The OSP “Sponsored Projects Reference Manual” speaks to the ‘overall responsibility and delegation of authority’ at Section 8.2 where it states, “…at the Institute, the PI has overall responsibility for the technical and fiscal management of a sponsored project.  This includes the management of the project within the funding limitations of the sponsored award…while responsibility…may be delegated to administrative staff, accountability for compliance…ultimately res with the PI.” 
   It is important to understand that the primary relationship between the sponsor and the university places the burden of primary responsibility on the university to provide ‘systems’ and processes adequate to project management; however, the institution has delegated overall responsibility for the management and reconciliation of project accounts on the PI, or his/her designee.  In the event of willful or knowing fraud and/or mismanagement of project funds, the federal government will also seek relief from the individual PI under the province of 31 USC 3729-3733 (the False Claims Act) as discussed in #6 above.

All proposals should be entered into the Proposal Alert System that is maintained by the OSP Pre Award Operations.   This OSP office will work with the faculty to prepare the proposal by ensuring all documentation meets sponsor requirements, budgets are maximized for all necessary costs, cost-share commitments and/or overhead waivers are described and appropriate responsibility is assumed, information is loaded into the correct e-portal and the Proposal Routing Form is completed and all signatures are obtained. 

Only the Executive Director of OSP (as the authorized institutional official) and the OSP Director of Pre Award Operations can sign proposals on behalf of the Institute.

With greater frequency, proposals are being submitted electronically. For example, the federal government increasingly is mandating use of Grants.gov for proposal submission processing. Investigators should be sensitive to the fact that many of the associated submission deadlines have hard time cut-offs, past which the proposal will not be accepted. Therefore, it is essential that proposals be finalized in a timely manner, with enough advance time-flexibility to allow OSP Pre Award staff to proceed with the submission steps associated with electronic submission and still meet the strict deadlines imposed by sponsors.

OSP keeps the Institute’s official copy of record for all proposals submitted in COEUS.  Proposal information is entered for tracking, record keeping, reporting, and Institute management planning purposes.

If you have any questions, please do not hesitate to contact Chrissa Papaioannou, Director of Pre Award Operations at (201) 216-8051 or cpapaio1@stevens.edu.

In several occasions research faculty have to request Institutional matching in the development of budgets for research projects. This match comes in the form of various requests such as reduced overhead rates, RA tuition assistance, in-kind matching of direct costs, etc. All these requests if granted, have direct implications in the cost structure of our research enterprise either directly, cost-share, or indirectly such as, for example, reduction of our overhead recovery rate set by the government. In any case, these matching allowances are a true cost to the Institute.

The Institution is inclined to look favorably upon such requests as an investment to the growth of our research enterprise, only after a thorough consideration of the justification for such investment.

Any request of cost share in a research grant of ANY type, is made by the PI prior to investing time to write a proposal.  The request should contain at minimum the following information:

• Agency to which the proposal will be submitted
• Anticipated total budget and duration of the project
• The type and itemized dollar value of the cost share request (i.e., overhead reduction, equipment purchase, student support, etc.)
• The reason for such request (such as, funding agency limits the overhead rate etc.)
• A justification as to why such request for an Institutional investment of this type should be made, including specific future benefits to the research initiative of the PI, benefits to the name recognition of Stevens, etc.)

The request should be first submitted to the Dean of the School of the PI for review. A copy of the request should also be submitted to the OSP Pre Award Director.  The Dean will forward the request to the Provost with his/her recommendation for consideration.  The Provost will notify the PI, Dean and OSP Pre Award Director on his final decision.

If you have any questions, please do not hesitate to contact Chrissa Papaioannou, Director of Pre Award Operations at (201) 216-8051 or cpapaio1@stevens.edu

Universities differ from for-profit entities in many regards and among the primary elements of divergence are those of compensation and the level of effort. 

The Federal government recognizes that the multiple and varied duties that comprise faculty workload and assignments are not totally predictable.  It is also the case that faculty do not accumulate or report vacation/accumulated and reported time off/sick time and typically work on a task for as many hours as is needed to achieve finality; thus the concept of tracking faculty effort via the number of hours worked is not practical.  For all these reasons faculty effort on sponsored research is proposed and reported as a percentage of effort rather than the number of hours. 

The Federal government’s recognition of this concept as it regards compensation and effort for faculty supported on sponsored projects is clearly stated in the various OMB Circulars relevant to institutions of higher education:

• “For each kind of recipient, there is a set of Federal principles for determining allowable costs.  Allowability of costs shall be determined in accordance with the cost principles applicable to the entity incurring the cost….The allowability of costs incurred by institutions of higher education is determined in accordance with the provisions of OMB Circular A-21, ‘COST PRINCIPLES FOR EDUCTIONAL INSTITUTIONS.’”   (OMB Circular A-110, C27)
• “In the use of any methods for apportioning salaries, it is recognized that, in an academic setting, teaching research, service, and administration are often inextricable intermingled.  A precise assessment of factors that contribute to costs is not always feasible, not is it expected.  Reliance, therefore, is placed on estimates in which a degree of tolerance is appropriate.”  (OMB circular A-21, J10b(1)(c))
• “…therefore, the payroll distribution system may reflect categories of activities expressed as a percentage distribution of total activities…”  (OMB circular a-21, J10b (2) (d).

While we appreciate a prime proposer’s obligation to present the most accurate estimate of proposed costs and always include the proposed percentage of effort and corresponding existing salary for a named faculty participant, we cannot provide a proposed number of hours as a level of effort.  If funded, the billed Stevens participation will be at the proposed level of effort. 

In instances where a funding agency has a limit on the number of research proposal submissions per Institution, the following process shall be followed:
The Form for Limited Solicitation Submission must be completed and submitted to the OSP Director of Pre Award Operations NOT LATER than EIGHT WEEKS before the required proposal submission date.

If the number of submissions to the OSP Director of Pre Awards is higher than the number allowed by the agency, then the OSP Director of Pre Awards will arrange for the Academic Council to review all the submission forms and identify the proposals to be approved for submission.  The PIs of the approved proposals will be notified within two weeks from the above deadline such that there will be six weeks available to prepare the proposal. Please note that the Academic Council may require that a presentation be made by selected PIs as part of the evaluation process.

The approved proposals must be prepared in accordance with all the requirements of the funding agency as described in the solicitation and will be submitted by the Director of Pre Awards. For more details on procedures for the preparation and review of a proposal, please refer to the PI Proposal Checklist.

The OSP office of Pre Award Operations will make every effort to provide adequate notification to the research community as to which programs have Institutional submission limitations.  A list of such proposal solicitations will be posted regularly in the OSP Pre Awards website.   Please note that is not possible for the OSP Pre Awards Office to track all solicitations from all agencies and identify such limitations.  If you identify any solicitations that have such requirements and are not included in the posted list please notify the OSP Pre Awards Director, Chrissa Papaioannou, at cpapaio1@stevens.edu.

Please note that by completing and submitting the Form for Limited Solicitation Submission as a PI you COMMIT that, if approved, you will prepare and submit a full proposal. If emergencies arise that negate the withdrawal of the commitment you must contact your Dean and the Director of Pre Award Operations immediately so that runner-up proposers may have the opportunity to submit.