Frequently Asked Questions

Guidelines for Submitting Extramural Proposals to Sponsored Projects Administration (SPA)

Note: Capitalized terms used in these FAQs have the same meaning as those used in the Guidelines for Submitting Extramural Proposals to Sponsored Projects Administration.

Background, Purpose and Applicability

Do the submission guidelines apply to all proposals?

The Guidelines apply to proposals for which there is Sponsor Deadline and to letters of intent, white papers, or other pre-proposal submissions that contain or propose institutional commitments to which UCI will be expected to adhere (e.g., budgets, cost sharing, space renovations, acquisition of equipment/instruments, etc.).

Are letters of intent, white papers and pre-proposals subject to the guidelines?

Only letters of intent, white papers, or other pre-proposal submissions that contain or propose institutional commitments to which UCI will be expected to adhere (e.g., budgets, cost sharing, space renovations, acquisition of equipment/instruments, etc.) are subject to the Guidelines.

Why does SPA need to conduct an institutional review?

UC Presidential policy requires that all proposals be submitted through the local sponsored projects/contracts and grant office. In addition, UC Contract and Grant Manual, Section 2-120 requires SPA to review proposals for consistency with campus and University-wide policies and procedures. Likewise, the Delegation of Authority to SPA includes the responsibility to determine the necessity for legal review, legal sufficiency, and compliance with University policies with regard to proposals (and awards).

The reason that SPA is charged with these responsibilities and requirements stems from real and present (as well as historical) risks, liabilities and external requirements. For example, the federal government requires (as do most other governmental and non-governmental sponsors) that all funding applications/proposals be signed by an Authorized Official. Under federal regulations and other applicable laws, Authorized Officials are responsible for making certain institutional representations, certifications and warranties when signing funding applications/proposals. Included in these, is an institutional attestation that the information, statements and claims contained in the proposal (and the certifications) are true, accurate and complete to the best knowledge of the Authorized Official.

The institutional review is intended to provide the Authorized Officials in SPA the opportunity to gain an appropriate level of knowledge regarding proposals so that they may reasonably and appropriately make attestations, certifications, representations and assurances on behalf of The Regents. In addition, when SPA approves a proposal, it is acknowledging that any false, fictitious, or fraudulent statements or claims may result in criminal, civil or administrative penalties for the person(s) signing the proposal, as well as the institution. These potential penalties underscored the importance of an institution’s proposal review procedure and practices.

Institutional Review

What is institutional review?

Proposed award terms and conditions contained in the funding opportunity announcement;
Use of facilities and resources;
Cost recovery;
Research protections;
Export controls and foreign national/citizenship restrictions;
Eligibility/debarment screening of subrecipients, consultants and other participants;
Intellectual property issues; and
Many more institutional issues and concerns.

Why does SPA need to conduct an institutional review?

Does SPA conduct a scientific review of the proposed scope of work?

No. However, during the institutional review, SPA spends a small amount of time reviewing the proposed scope of work to identify potential institutional issues involving matters such as: export control, intellectual property, material transfers, use of animals and human subjects in research, human stem cell use, rDNA, use of potential environmental hazards, etc.

In addition, SPA also compares the information from the scope of work about such issues to the information provided in the completed Kuali Research (KR) proposal document. As the office of record for UCI’s extramural proposals, SPA is responsible for ensuring that the information captured in the KC system accurately reflects the information contained in the proposal. The accuracy of this information is important as it is shared with other central administrative units on campus and the UC Office of the President for informational purposes, decision-making, policy development and internal/external reporting purposes.

Will SPA be able to complete the institutional review if a proposal is submitted after the applicable lead time?

Yes, all proposals, including Late Proposals, are required to receive institutional review before being approved and submitted to a sponsor. Since a Late Proposal runs the risk of being submitted after the sponsor’s deadline, it is recommended that principal investigators take appropriate steps to ensure that their proposals are submitted to SPA in accordance with the applicable lead times described in the Guidelines.

Clinical Trials

A study meeting the UCI definition of a clinical trial will be conducted as a cooperative group trial under NIH funding. Can the clinical trial facilities and administrative cost rate of 32% TDC be used?

No. Studies supported in whole or in part with federal funding must apply the applicable Federal research facilities and administrative cost rate.

A study will be funded by an industry Sponsor via a subcontract to UCI, with prime funding provided by the Federal government. Since the funds will be received directly from the industry Sponsor, can the clinical trial facilities and administrative cost rate of 32% be applied?

No. Because Federal flow-through funds are involved, the applicable Federal research facilities and administrative cost rate should be applied.

A study fully funded by a for-profit entity will involve testing of an investigational drug or device in animals. Which facilities and administrative cost rate applies?

The clinical trial indirect rate only applies to clinical testing in human subjects. Pre-clinical laboratory and animal studies are specifically excluded. Therefore, the applicable Federally-negotiated research facilities and administrative cost rate would apply.

A pharmaceutical company has requested that the University run specialized tests on samples obtained in a clinical trial. Would the clinical trial facilities and administrative cost rate apply?

No. The clinical trial rate applies only to studies involving the direct clinical testing of investigational products in human subjects. If the University's sole involvement is to run tests, the applicable Other Sponsored Activities rate would apply.

An investigator has agreed to analyze data collected in an industry-sponsored clinical trial conducted at both UCI and other sites. Which facilities and administrative cost rate applies?

The applicable Federally-negotiated research rate would apply.

The University has been asked by a for-profit sponsor to recruit and enroll human subjects in order to collect data that will be submitted to a patient registry. Is this considered a clinical trial, and would the clinical trial facilities and administrative cost rate apply?

Data collection studies for registry purposes, even if human subjects are involved, are not considered clinical trials. Therefore, the clinical trial facilities and administrative cost rate would not apply, and the applicable Other Sponsored Activities facilities and administrative cost rate should be used.

Proposal Prioritization Methodology and Proposal Types

Why did UCI change its method for prioritizing proposals from the sponsor deadline method to the order of receipt method?

UCI changed its method for prioritizing proposals to ensure that all Principal investigators have fair and equitable access to SPA’s services and to help facilitate the timely review, approval and submission of UCI’s proposals.

Under the Guidelines, how are proposals prioritized for review?

When proposals are first received by SPA, they undergo a preliminary review, in the order that they were received, to determine if the proposal contains all of the information and documents needed for SPA to conduct an institutional review. After completing the preliminary review, each proposal is advanced to institutional review and assigned a reviewing officer. The officer then conducts an institutional review of each proposal in the order in which it was received in their queue.

The proposal review queues can be accessed by logging in to ZotPortal, navigating to the Research tab and clicking the applicable linksin the Kuali Coeus Lookups portlet.

Is SPA's proposal prioritization methodology applied to all extramural proposals?

Yes, the methodology is applied to all extramural proposals, including Late Proposals, proposals with no Sponsor Deadline and after-the-fact proposals.

The “sponsor deadline” methodology previously used by SPA regularly resulted in “last-minute” proposals being reviewed prior to those that were timely submitted to SPA and already in the review queue. As a result, the “sponsor deadline” methodology disadvantaged the principal investigators of the timely submitted proposals. It regularly created situations where these proposals would go without review for several days; thus, denying them valuable review time and inappropriately putting them at risk for unsuccessful submission to the sponsor.

Are most proposals Standard or Non-standard Proposals?

The large majority of UCI’s proposals qualify as Standard Proposals; however, a small portion are Non-standard Proposals, which involve any of the following uncommon circumstances:

The sponsor is a foreign entity.
The proposal is for a U.S. federal government contract – not a grant or cooperative agreement.
By virtue of submitting the proposal to the Extramural Sponsor, UCI is accepting award terms and conditions contained in the funding opportunity announcement.
As part of the proposal, the sponsor requires the submission of a small business subcontracting plan, an intellectual property management plan, a laboratory safety plan, or any other plan(s) that must be developed by one or more UCI central administration office.
The proposal requests funding in excess of $5 million of direct costs per budget year.
A purpose of the proposal is to establish a new UCI center or institute.

Submitting a Proposal – What to Submit

When a proposal is submitted to SPA for institutional review, does it need to be in final form?

To enable SPA to conduct an institutional review and to avoid proposal review delays, principal investigators and departments/units should submit a complete proposal to SPA. A complete proposal includes the proposal information and documents listed below:

A complete KC proposal document with all applicable approvals.
The Extramural Sponsor’s Funding Opportunity Announcement (FOA) or the URL (web address) for the FOA.
All proposal documents and information required by the Extramural Sponsor’s FOA, which may be submitted in draft form – except for the following, which must be submitted to SPA in final form:
1. Application face page (sometimes referred to as the cover sheet)
2. Budget and budget justification
Complete subrecipient proposal package (if applicable), which consists of:
1. A completed and signed “Subrecipient Statement of Collaborative Intent (or MCA Commitment Form for Subawards to other UC Campuses)
2. Scope of work specific to the subrecipient site
3. Budget and budget justification specific to the subrecipient site; and
4. Other subrecipient documents as required by the Extramural Sponsor’s FOA (for example, certifications, assurances and/or representations from the subrecipient).

Please note that the above applies to all proposals, including those being submitted via electronic proposal submission systems.

What happens when the PI or department/unit makes changes to parts of the proposal that are supposed to be submitted to SPA in final form?

SPA needs certain proposals sections and documents in final form for institutional review (see Part C of the Guidelines). The review may be delayed and a proposal may be at risk for submission after the Sponsor Deadline if the principal investigator and/or department/unit make changes to draft documents/sections which then result in changes to the final documents/sections already submitted to SPA. Principal investigators and departments/units should coordinate closely with the Contract and Grant Officer assigned to the proposal regarding any such changes. Doing so will help facilitate the institutional review and on-time submission to the sponsor.

If a proposal involves Vice Chancellor for Research (VCR) cost sharing, does the proposal submitted to SPA need to include the signed VCR cost share letter?

No; however, to facilitate the institutional review, the cost shared amount should be included on the Cost Sharing tab in the KC budget. Please remember that principal investigators and/or department/unit administrators are responsible for securing the signed VCR cost sharing letter and including it with the Final Proposal. When the Final Proposal is submitted to SPA, the signed VCR cost sharing letter must be uploaded in the Internal Attachments panel of the Abstracts & Attachments tab. If the signed VCR cost sharing letter is not submitted with the Final Proposal, the proposal will likely be at risk for submission after the Sponsor Deadline.

If a sponsor has a policy that prohibits Facilities & Administrative (F&A) costs or limits the applicable F&A rate, should the proposal submitted to SPA include an F&A rate reduction/waiver request?

It is recommended that principal investigators and/or department/unit administrators contact the SPA team assigned to the department/unit to discuss the potential for securing an F&A rate reduction/waiver in advance of submitting the proposal to SPA for institutional review. Please refer to Section 484-4 of the UCI Research Policies, Guidelines and Procedures for additional information regarding F&A rate reductions/waivers.

If a sponsor suggests or recommends the use of an F&A rate lower than UCI’s federally- approved F&A rates, what additional information should be included when a proposal is submitted to SPA?

When a sponsor suggests or recommends using a F&A rate lower than UCI’s federally-approved F&A rates, it is recommended that principal investigators and/or department/unit administrators contact the SPA team assigned to the department/unit to discuss the potential for securing approval of an F&A rate reduction or waiver request in advance of submitting the proposal to SPA. After such consultation, an F&A rate reduction/waiver request should be included with the proposal when it’s submitted to SPA. This will help facilitate the institutional review.

Please refer to Section 484-4 of the UCI Research Policies, Guidelines and Procedures for additional information regarding F&A waivers or reductions.

If a sponsor requires an institutional commitment letter from a high ranking official (e.g., Dean, Vice Chancellor, Executive Vice Chancellor/Provost, Chancellor) does the proposal submitted to SPA need to include the letter(s)?

No; however, please remember that principal investigators and/or department/unit administrators are responsible for securing the letter(s) and including it/them with the Final Proposal. When the Final Proposal is submitted to SPA the letter(s) signed by the appropriate official must be uploaded in the Internal Attachments panel of the Abstracts & Attachments tab. If the letter(s) is/are not submitted with the Final Proposal, the proposal will likely be at risk for late submission to the sponsor.

Submitting a Proposal – When to Submit

When should a subaward proposal be submitted to SPA for institutional review?

For subaward proposals (i.e., UCI will be a subrecipient under a proposal being submitted by another entity), the Sponsor Deadline is the date and time set by the prime institution coordinating the collaborative project. For example, if UCLA is the prime institution and they establish March 15 at 5pm as the deadline to receive subaward proposals, then UCI’s subaward proposal should be submitted to SPA in accordance with the appropriate time frame set forth in Part D of the Guidelines.

When should a proposal be submitted to SPA for institutional review if the sponsor grants an extension to its deadline?

If a sponsor grants a deadline extension, then the proposal should be submitted to SPA for institutional review in accordance with the appropriate time frame set forth in Part D of the Guidelines using the new date and time approved by the sponsor.

If a Sponsor Deadline falls on a weekend or a holiday observed by the sponsor, when should a proposal be submitted to SPA for institutional review?

A proposal should be submitted to SPA for institutional review in accordance with the applicable timeframe set forth in Part D of the Guidelines prior to the Sponsor Deadline. In most cases when a Sponsor Deadline falls on a weekend or holiday, the deadline is automatically extended to the next business day. However, this is not always the case. Principal investigators and department/unit administrators should carefully review the funding opportunity announcement for guidance on this issue and when in doubt, verify the deadline with the sponsor.

If a Sponsor Deadline falls on a UC holiday that is not observed by the sponsor, when should a proposal be submitted to SPA for institutional review?

If a Sponsor Deadline falls on a UC holiday that is not observed by the sponsor, SPA considers the deadline to be 5pm on the UC business day immediately prior to the Sponsor Deadline.

When should the Final Proposal be submitted to SPA for submission to the sponsor?

The Final Proposal should be received in KR by SPA no less than eight business hours prior to the Sponsor Deadline. It is recommended that principal investigators take appropriate steps to ensure that their Final Proposals are submitted to SPA in accordance with this lead time to avoid the risk of the proposal being submitted after the Sponsor Deadline.

Why does SPA need the Final Proposal eight hours before the Sponsor Deadline?

Certain aspects of the proposal review, approval and submission process are outside of SPA’s control. Some examples include, but are not limited to:

Excessive workload resulting from multiple sponsors scheduling their deadlines for the same day or the campus submitting a large number of proposals for a Sponsor Deadline (common occurrence around NIH deadline days).
Technical glitches or system outages associated with sponsor submission portals which can jeopardize timely proposal submission.

If a Sponsor Deadline is 11:59pm local time; does this mean that the final version of the proposal may be submitted to SPA at 3:59pm local time?

No. SPA reviews, approves and submits proposals during its normal business hours (8am - 5pm). When a Sponsor Deadline is after 5pm local time, SPA considers the deadline to be 5pm. This means that the Final Proposal should be submitted to SPA no later than 9am local time.