RA20 Proposal Submission

Contents:

PURPOSE:

To establish a policy for preparation and submission of proposals for sponsored research, instruction, and outreach projects.

PROCESS:

Federal Awards: Budgets must be prepared in accordance with the cost principles defined in Subpart E of the Uniform Guidance (2 CFR 200). (See also RA21 Development of a Proposal Budget.) Cost sharing, when required, should be proposed as per the guidance in 2 CFR 200.306. (See also RA50 Cost Sharing.) Guidance for development of cost proposals for federal contracts is found in Section 15 of the Federal Acquisition Regulations (FAR).

Non-Federal Awards: Proposals for non-federal awards should follow the guidelines set by the awarding organization. Federal costing policies and proposal development guidance should be used as a basis for development of these award proposals if no other guidance exists.

Authorization to Submit: Principal Investigators do not have the authority to submit proposals on their own. Investigators should contact their college/unit Research Administrator as soon as they learn of a funding opportunity. This is to ensure sufficient time to develop an appropriate cost proposal, complete all sponsor-required forms and certifications, and secure all required approvals. Approval is evidenced by signatures on the proposal and on the University's Internal Approval Form (IAF). After the Principal Investigator (PI) and any co-investigators have signed the IAF, the proposal must be signed by all designated approvers, which may include the investigators' Department Heads, Associate Deans, Campus Chancellors, and/or Campus Directors of Academic Affairs. The Associate Vice President for Research/Director of Sponsored Programs and their authorized delegates serve as the final approver.

Timeline for Submission: Principal Investigators ought to provide proposal preparation staff ample time to ensure sponsor guidelines are followed; budgets adhere to RA21 Development of a Proposal Budget required approvals are secured; and all forms, representations, and certifications are accurate and complete. Proposals requiring institutional cost-sharing and/or comment on contractual terms and conditions require additional time. As a general rule, Principal Investigators are strongly encouraged to submit all proposal materials to their designated proposal preparation staff at least five (5) days prior to the proposal due date. College/unit research offices reserve the right to establish their own internal submission timelines.

Other Support: Many sponsors require submission of information about senior/key personnel at the proposal stage (“Other Support” also known as “Current and Pending Support”). Other sponsors may collect such information immediately prior to the issuance of an award (“just-in-time”) or with the submission of progress reports. Sponsors request this information to evaluate project personnel’s current level of activity, to ensure that personnel have sufficient time to perform the project, and to confirm that there is no scientific or other overlap among various commitments.

As a condition of submitting proposals and/or accepting awards at the University, all project personnel must abide by all proposal guidelines and award requirements, including any requirements to disclose Other Support. Sponsors typically require senior/key personnel to identify any pending University proposals or active University awards on which they are listed as project personnel. Sponsors may also require disclosure of resources or financial support in direct support of project personnel’s research endeavors, including research performed at other institutions and research performed as private consulting, whether paid or unpaid and whether inside or outside a faculty member’s appointment period. Many sponsors are particularly interested in foreign components associated with research, including for example research activities performed in foreign countries and/or on behalf of foreign institutions. Some sponsors may also require disclosure of University internal funds (including start-up funds, gift funds, etc.).

Many of the above activities may have already been disclosed to Department or Unit Heads (via AC80 disclosure), the Conflict of Interest program (via RP06), or other parties (via AD77). However, since there can be Sponsor-required Other Support disclosures that otherwise would not be disclosed under the above-referenced policies, and there is no single University resource that possesses all of the above information, it remains the responsibility of all project personnel to ensure that their submission of Other Support information is accurate and complete.

Malign Foreign Talent Recruitment Programs: Per Public Law No. 117-167, Federal agencies must require recipient institutions to “prohibit covered individuals participating in malign foreign talent recruitment programs from working on projects supported by research and development awards.” As a condition of applying for Federal funds (including Federal flow-through funds), all Penn State senior/key personnel must certify that they are aware of this prohibition and do not participate in a malign foreign talent recruitment program. Full definitions of “covered individuals” and “malign foreign talent recruitment programs” can be found here.

Limited Submissions: Certain solicitations limit the number of proposals that Penn State can submit. Such proposals must be coordinated through the Office of the Senior Vice President for Research in accordance with RAG20 Limited Submissions.

Additional proposal preparation guidance can be found on the Preparing Proposals website.

FURTHER INFORMATION:

For questions, additional detail, or to request changes to this policy, please contact the Office of the Senior Vice President for Research, or the Office of Budget and Finance.

CROSS-REFERENCES:

Other Policies which may have specific application and should be referred to:

AC80 Faculty Outside Professional Activities and Conflict of Commitment

AD77 Engaging in Outside Professional Activities (Conflict of Commitment)

RA03 Eligibility to Serve as Principal Investigator (PI)

RA21 Development of Proposal Budget

RA50 Cost Sharing

RAG20 Limited Submissions

RP06 Disclosure and Management of Significant Financial Interests

Revision History:

• March 4, 2024 - Added a new section on Malign Foreign Talent Recruitment Programs
• July 11, 2023 - Editorial changes:
  • References to the Corporate Controller changed to the Associate Vice President for Budget and Finance
  • References to the Office of the Corporate Controller changed to the Office of Budget and Finance
• December 30, 2019 - Policy updated to include Other Support section.
• September 11, 2017 - Policy updated to include Timeline for Submission and Limited Submissions section. Policy Guideline RAG20 was also inserted in the Cross-References section.
• February 26, 2016 - This new policy has been created as part of the policy reorganization brought about by the implementation of the Uniform Guidance (2 CFR 200).
• October 31, 2013 - Changes have been made throughout the policy to reflect current operations, made in conjunction with an update to the Procedures for the Administration of Subawards. The new link to that document reflects the updates to the Subaward process.
• July 24, 2006 - Editorial changes: links were revised because of changes to the Grants & Contracts website.
• February 28, 2003 - Editorial change: form URLs updated
• September 27, 2002 - New Policy