III.  PROPOSAL DEVELOPMENT PROCESS  

Chapter III covers the next phase where the Investigator is ready to begin actually developing the research proposal. In the context of this Handbook, a “Proposal” is a request for funding to support a research, training, instruction, or service program that is an appropriate undertaking for members of the GW community. Proposals describe the work to be undertaken, its significance, the qualifications of the proposer(s) to carry out the tasks, and the resources available to support the program. They usually include an estimate of the costs that will be incurred. Because successful proposals result in awards that are legally binding agreements on the University, care must be taken in their preparation to verify that the:

• information presented is accurate and complete;
• program meets with the goals of the department, school, and University;
• sponsor policies and requirements are acceptable to the University;
• proposal text complies with University policies and procedures; and
• required approvals are documented prior to submission.

For a quick, interactive reference and guide to all the major steps involved in submitting proposals for sponsored research at GW, as well as links to the latest forms and checklists to facilitate the whole process, please see OVPR's Proposals in a Page.

Section 5: Proposal Process Overview

5.1: PRELIMINARY/PRE-PROPOSAL PLANNING - Steps for Successfully Proposing and Performing Sponsored Research at GW

For anyone contemplating conducting research at GW, the first thing to verify is eligibility to conduct research. After a brief discussion on how to verify this, this Section provides a discussion on the importance of early and effective communication within the prospective researcher’s department, school or college and the kinds of coordination that should occur with GW departments dedicated to supporting and facilitating research to better enable the proposal process to proceed smoothly.

5.1.1. Increasing Chances for Successful Research

In addition to all the people and resources identified in the preceding Roles and Responsibilities Section, this Handbook is dedicated to providing effective step-by-step guidance to researchers and those involved in supporting researchers in their efforts to successfully propose and conduct research at GW.

5.1.2.1. Importance of Early Coordination:  It is very important for Principal Investigators to recognize the advantages of early feasibility discussions with the appropriate Chair/Dean to ascertain initial information as to whether a proposed program is consistent with the University’s mission, size and resources. This is particularly true for proposed programs that will require any costs, space, equipment or other services to be provided by GW. Principal Investigators should gather general information about department priorities and objectives and consult with the department Chair and Dean early in the process to verify that there are adequate resources, space and facilities for pursuing the proposed line of research.

Additionally, it is also very important to plan for early and close coordination with and among the University’s core offices that support research. By touching base early, the Principal Investigator alerts the appropriate people who will become instrumental later in helping the Principal Investigator to verify that the proposal is properly prepared and submitted and that any resulting award is effectively established and executed. To provide advance notice about proposals being prepared, the prospective researcher should contact the appropriate RSC assigned to the applicable school/department as soon as the decision is made to pursue the proposal opportunity. By doing effective preliminary planning during the 30-90 day period prior to proposal submission deadline, the Principal Investigator can complete the preparation phase with a solid sense of the sponsor’s expectations, a thorough understanding of the proposal submission requirements, a well-coordinated approach for ensuring necessary participation and support in the proposal processing and submission phases from the Principal Investigator’s department as well as other internal reviewing organizations. In any event, the Principal Investigator should advise the Research Services Coordinator at least 25-30 days before proposal submission is due. A complete list of OVPR staffing is available at the OVPR website at http://www.gwu.edu/~research/orsstaffing.htm

The Research Service Coordinator can assist in budget preparation and review guidelines with Principal Investigators to point out any obstacles to be dealt with early in the process (cost sharing requirements, consortial or subcontract documentation, etc.).  Where appropriate, the RSC will provide applicable Facilities and Administration rates, Fringe Benefit rates, or other applicable rates as well as other basic information needed in the proposal. Additionally, the RSC can explain whether advance coordination with other organizations such as OHRCTT for any compliance reviews would be appropriate given the nature and purpose of the proposed research endeavor.

As a further note, Principal Investigators should be aware that if other individuals, including those employed at GW, and/or outside organizations will be included in the proposed research, it is the Principal Investigator’s responsibility to obtain their agreement to participate as well as the approval of their respective departments or organizations. Doing this as early in the process as appropriate, and communicating these requirements to the RSC from the beginning, will better enable the proposal submission deadlines to be met in a timely manner.

5.1.2.2. Proposal Limitations/Solicitation Limits on Number of Applicants:

Occasionally, proposal guidelines state that there is a limit to the number of proposals an institution can submit. If you note such a limitation for a competition you are interested in, please send an e-mail right away to Ann Laura Walker, OVPR Information Specialist, notifying her of your interest to submit an application to that competition.

Once the OVPR is aware of a faculty member preparing a proposal for a limited submission competition, the Information Specialist will disseminate the competition information to appropriate Deans, Chairs, and OVPR staff on campus to determine if other faculty members are working on a proposal submission for the same competition. If an RSC becomes aware of such a proposal, then the RSC or his/her Team Leader should notify the Information Specialist so that a wider dissemination of the information is done to the campus community.

Simultaneous to the campus notification, a post on the OVPR website regarding the internal deadline for the limited submission will be done. Once all of the inquiries of interest to submit to a limited proposal competition are received in the OVPR by this internal deadline, then the Vice President for Research will oversee the selection and nomination process to determine which proposal will be submitted on behalf of GW. Then the faculty and their RSCs will be notified as soon as possible.

Please visit http://www.gwu.edu/~research/competitions.htm for information about the current competitions with limited proposal submissions.

In addition to the webpage listed above, another webpage on the OVPR website has been created for other potential funding opportunities with limited proposal submissions. This listing is sent via a listserv from Community of Science (COS) and is only posted to make the campus community aware of other potential limited proposal submission competitions that will require OVPR review. Please visit http://www.gwu.edu/~research/coscompetitions.htm for more information on the COS list, typically updated on a weekly basis.

5.1.2.3. Proposal Preparation Costs – Another important reason for early coordination at the Department and School/College level is that, with limited exceptions such as non-competing continuations, time spent on proposal preparation is University Compensated Time within the meaning of GW’s applicable Effort Certification Policy, available at http://my.gwu.edu/files/policies/EffortCertificationFINAL.pdf. In accordance with the applicable regulations and this GW Policy, Principal Investigators can not charge one sponsor for competing continuations or new proposal work for that sponsor or another sponsor, even if similar work or work in the same field is involved. 

5.1.2.4. Lobbying Restrictions and Certifications: In accordance with the University’s Policy on Use of Federal Funds for Lobbying, it is GW’s Policy to comply with applicable law that federal funds may not be used  to influence or attempt to influence any member of the Executive or Legislative branches of Government (including any agency employee) for the purpose of securing a grant, contract or cooperative agreement or any extension, renewal or modification of any of these. The OVPR routinely certifies on federal awards that the University will abide by these restrictions, so if there is any reason to believe that the certification would be inaccurate for any reason, contact the Managing Director for Research Support and Analysis immediately. For further information on this Lobbying Policy, please see http://my.gwu.edu/files/policies/LobbyingPolicyFINAL.pdf.

5.1.2.5. Special Proposal Planning Considerations Requiring Additional Compliance Reviews: Early coordination and consultation with OHRCTT will greatly facilitate any special approvals that may be required due to anticipated involvement of compliance-related subject matter as further described in this section. For more information, please refer to the OHRCTT website at http://www.gwumc.edu/research/.This is particularly important in order to enable timely action to be taken in advance of any anticipated start dates for pharmaceutical/clinical trial agreements.Special approvals are required for research involving one or more of the following:

• Human Subjects - The Office of Human Research (OHR) operates within the Office of Health Research, Compliance, and Technology Transfer, and is the University's agency for compliance with federal regulations regarding the protection of human research subjects. Federal regulations require that all research involving human subjects or analysis of data gathered from human subjects, regardless of funding status, be reviewed by the OHR prior to the implementation of any research activity. 

GW’s Committee on Human Research, Institutional Review Board (GW IRB) continually reviews human subject research protocols at intervals appropriate to the protocol’s degree of risk, but not less than once per year. There is no grace period for extending the continuation of research related activities beyond a study’s expiration date. For further information regarding Human Subject Research, please refer to the University’s Continuing Review Policy for Medical and Non-medical Human Subject Research at http://my.gwu.edu/files/policies/ContinuingReviewPolicyFINAL.pdf. Additionally, for information regarding GW’s Humanitarian Use Device Policy (a medical device intended to benefit patients by treating or diagnosing a disease or condition that affects or is manifested in fewer that 4,000 individuals nationally), please refer to http://my.gwu.edu/files/policies/HumanitarianUsePolicyFINAL.pdf

• Use of Animals in Research - The Animal Research Facility (ARF) provides space, equipment, and care for laboratory animals used for research and teaching purposes. Various federal agencies and private research foundations regulate the use of vertebrate animals used or intended for use in research. Working closely with the Institutional Animal Care and Use Committee (IACUC), ARF provides the highest standards of humane care and use of laboratory animals and assures compliance with University and federal regulations. They share responsibility to assure that the use of animals in research programs are necessary, that the investigator has included in the protocol measures to eliminate any unnecessary pain and discomfort to the animals, and that alternatives to the use of live animals have been considered.

Investigators contemplating using laboratory animals in research or teaching must acquire from ARF a copy of the "Principles of Proper Laboratory Animal Use in Research" manual and complete and submit to The Animal Research Facility, Ross Hall B-12, the IACUC-A form entitled "Proposal for Laboratory Vertebrate Use in Research or Teaching (A/1-01),” Appendix E.

Access to ARF is granted to individuals with an IACUC approved protocol that have received appropriate training in laboratory animal use (call 4-2941).

All lab animals must be purchased through ARF. Blanket Purchase Orders with responsible providers are available to facilitate simplified acquisition of animals for research. Animals admitted to Ross Hall must be quarantined in ARF quarantine rooms.

All continuing research programs must be renewed annually. The investigator must complete and submit to ARF the form entitled "Proposal for Continuation of Laboratory Vertebrate Use in Research or Teaching (IACUC-B)," Appendix E. 
For further information, see GW’s Use of Animals in Research Policy at http://my.gwu.edu/files/policies/UseofAnimalsFINAL.pdf or see the OHRCTT website at http://www.gwumc.edu/research/animal.htm

• Radiation/Radioisotopes - The Radiation Safety Office promotes safe use and handling of radioactive material and radiation-producing machines throughout The George Washington University, according to federal and local regulations and according to the University's Nuclear Regulatory Commission "broad-scope license" commitments. This includes the use of radioactive material and radiation-producing machines in various specialties and in numerous research programs.  For any research or other use of radioisotopes, the form entitled "Authorization to Use Radioactive Materials or Ionizing Radiation" must be completed and submitted to the Radiation Safety Office, and approved by the Radiation Safety Committee, prior to initiation of the research study or other use. For further information, refer to the Office of Radiation Safety’s webpage at http://www.gwumc.edu/research/radsafety.htm


• Lab Safety/Hazardous Materials - The Office of Laboratory Safety and Compliance (OLSC) is responsible for occupational and environmental health and safety for the George Washington University Medical Center (GWMC). The primary focus is the safe management of biological and chemical hazards associated with research and teaching laboratories throughout the George Washington University. In compliance with applicable institutional policies and federal regulations, OLSC works with the faculty, staff, and students to provide a safe and effective research and teaching environment. For further information, see the Health and Safety Manual, http://www.gwumc.edu/research/labsafety.htm. Additionally, questions can be addressed to GW’s Office of Risk Management,  http://www.gwu.edu/~riskmgnt/.


• Bloodborne Pathogens –As part of the Office of Laboratory Safety and Compliance’s overall safety procedures, specific guidelines for proper handling of bloodborne pathogens are set forth in the Health and Safety Manual, Section 6.0. GW’s approach to eliminating or minimizing the risk from bloodborne pathogens is provided in the University’s Exposure Control Plan that applies to any human or animal blood, body fluid, cell line, or rDNA material as described in the Health and Safety Manual. For further information, see the Health and Safety Manual, http://www.gwumc.edu/research/labsafety.htm


• Research Involving Recombinant DNA/Gene Therapy - By federal decree, every biomedical research facility performing publicly funded research must have an Institutional Recombinant DNA Advisory Committee (IRAC). As such, GW’s IRAC is required to review each and every funded or proposed protocol and/or grant, which utilizes recombinant DNA technologies. This does not include procedures that merely use DNA as a biochemical substrate. It is best loosely understood as, “any attempt to express a recombinant gene or protein in a host other than the natural host”. As such, the materials that GW’s IRAC needs in order to complete its review includes a fairly detailed description of the genes, vectors, hosts, and procedure/protocols that  will be employed in the proposed research, and safety precautions that are in place to protect workers. For further information, contact the Office of Recombinant DNA, or check the webpage at http://www.gwumc.edu/research/dna.htm. See, also, the Health and Safety Manual, http://www.gwumc.edu/research/labsafety.htm


• Select Agents – University policy requires that Select Agents be used only for valid research purposes and that written approval from the Office of Health Research, Compliance and Technology Transfer be obtained prior to ordering, possessing or using Select Agents. Select Agents are infectious agents, biologically-derived toxins and genetic elements from Select Agents that are reasonably believed to be capable of producing disease or toxicosis.  GW policy regarding the proper use of Select Agents is available at, http://my.gwu.edu/files/policies/SelectAgentsPolicyFINAL.pdf.

5.2. STEPS IN PROPOSAL PLANNING

To provide an initial orientation to the process of proposal preparation and to facilitate advance planning, the following chart presents the main steps in the Preliminary/Pre-proposal Process.

Step	Actions/References
1. Locate appropriate internal and/or sponsored funding source(s).	To identify potential funding sources, See: links to Section 4: Sources of Research Funding Section 4.1 Non-Sponsored Research Funding Section 4.2. Sponsored Research Funding Section 4.3. Funding Search Checklist
2. Review  applicable program and/or sponsor information and guidelines.	To learn more about the sponsor, research Sponsor Guidelines . Examples of supplementary sponsor information include: NSF Grant Proposal Guide NIH Guide for Grants and Contracts Applying for a National Endowment for the Humanities Grant Department of Energy Department of Defense Department of Homeland Security
3. Early feasibility consultations help ensure efficiency and success of proposal effort.	To verify feasibility, consult with Department Chair/Dean as appropriate, especially if: the proposal limits the number of applicants from each institution cost sharing or special space, equipment or other requirements apply.  See: Section 5 Preliminary/Pre-Proposal Planning
	Department chair, director, and/or dean If matching or cost sharing is required, or if the program will require course release/replacement, or if the program will involve allocation of department or school resources, consult with department chair and/or dean before beginning to write the proposal. Associate VP - Health Research, Compliance & Technology Transfer For proposals originating in the Medical Center or having substantial involvement of Medical Center personnel, if Medical Center matching or cost sharing is required, or if the program will require course release/replacement, or if the program will involve allocation of Medical Center resources, consult with AVPHRCTT. Vice President for Research If matching or cost sharing at the University level is required, E-mail the VP at lmchalupa@gwu.edu. OVPR Research Service Coordinator The appropriate RSC will work with you to determine whether there are special conditions that must be met in developing the proposal, whether there are any issues with the sponsor or the specific program that should be addressed early in the process, and to establish the timing for submission of the proposal for OVPR review. Contact the RSC as soon as the decision is made to submit a proposal, and, in any event, within 25-30 days of the proposal submission deadline for guidance and assistance. The RSC will also provide guidance as to whether the proposal requires signature by the Managing Director or Vice President for Research, and what processing requirements are necessary for that proposal level. Where time permits, the RSC can assist with budget development. Health Research, Compliance & Technology Transfer Office Consult the OHRCTT if you anticipate requiring compliance review for: Human Subjects Use of Animals in Research Radioisotopes Hazardous Materials Recombinant DNA

BACK TO TABLE OF CONTENTS

5.3. TIMELINES FOR PROPOSAL PHASES

5.3.1 Proposal Development: Countdown Schedule to Submission Deadline
The schedule shown below is an approximation of how a Principal Investigator might plan the proposal development process. Obviously, a complex, multi-institution proposal will require more time; a two- or three-page letter proposal to a foundation could require less.  This is offered as a guideline with the understanding that while all reasonable efforts will be applied to process proposals submitted for review outside these guidelines, late submissions risk missing the sponsor’s proposal deadline.

When planning a proposal schedule, allow extra time for approval of human/animal protocols, coordinating a multi-department and/or school proposal or a proposal that involves subawards with other institutions/organizations, proposals that will require institutional cost sharing, or any other complicating factor(s). Additionally, there are progressively higher levels of signature requirements for certain proposals requiring signature by the Vice President for Research.  Accordingly, please allow additional time when submitting such a proposal. Finally, if an electronic submission is contemplated or required, please add at least another day to better verify that all requirements for receiving and sending an electronic submission are met, to include an internal GW routing sheet showing that all approvals are in order.

Days to Deadline	Tasks
30-90 days	Review program announcement, Sponsor Guidelines, and any other solicitation materials. Prepare outline and/or first draft of research/program plan. Where required, consult OHRCTT regarding human subjects and/or animal use or other compliance requirements such as HAZMAT. Coordinate with participating departments/schools/other organizations. Discuss any personnel, facilities, and space commitments, cost sharing, and requirements for matching funds with chair, dean and/or CRO (University, Non medical Center) or AVPHRCTT for Medical Center).
25-30 days	Consult with RSC to advise and coordinate proposal and to ensure that all prior registrations are made for electronic proposal submissions if required. Discuss budget development with RSC.
20-25 days	Prepare a preliminary budget and review with RSC. Share draft of proposal with colleagues for constructive comments.
15-20 days	Submit budget and justification draft, narrative draft, and sponsor forms to RSC for review to verify compliance with University and sponsor requirements.  Note: Individual drafts of proposal text can be presented/revised with complete budget justification as long as the Statement of Work is represented in the draft.
5-15 days	Respond to questions from RSC, make necessary changes, and prepare final copy of proposal. Route complete proposal to chair and dean for signature, and any other required approvers if additional approvals are required for compliance reasons as indicated in the . OVPR Routing and Approval Form.
10 days	For any items proposed for direct charging that are normally covered through Facilities and Administrative (F&A or Indirect) charges such as departmental administrative and clerical salaries, general office supplies, computers, postage, photocopying, etc., submit the Direct Charging Checklist Approval Form per GW’s Policy on Direct Charging of Administrative Costs.
6 days	For any proposals to be submitted electronically allow extra time to ensure sponsor acceptance and confirmation.
5 days	RSC conducts final review and arranges for return to PI for mailing, electronic submission or with prior coordination with PI, mailing of proposal to sponsor.

 

5.4. PRE-PROPOSAL PLANNING CHECKLIST

Following are questions to keep in mind in qualifying potential sponsors and programs, as well as in evaluating how to best select a target opportunity.

Click here to use the fillable pdf version of the Pre-Proposal Development Checklist.

Section 6: Developing Proposals  

An effective proposal conveys the substance of the planned research in a lucid, comprehensive and compelling manner with contents that meets University submission requirements and sponsor expectations. In an increasingly competitive environment, the challenges of writing winning proposals are considerable. Doing all the proposal planning discussed above will save time and effort later when the pressures increase as the submission deadline approaches. The coordination discussed in the proposal planning phase allows others to provide support and conduct reviews concurrently with the Investigator’s efforts to complete the technical proposal. Then all elements of the proposal will come together and be ready in a timely manner for proceeding to the Proposal submission process as Discussed in Chapter IV.

6.1. PROPOSAL WRITING RESOURCES 

The following references may be useful when writing a proposal. These are only a few of the many such references found on the web as further mentioned in the Appendix to Public and Private Resources/Guidelines, Appendix K.  The best guidance for proposal writing, however, can often be found in the program guidelines.

6.1.1. General Guides

There are a number of general guides for writing effective proposals. Consult a reference librarian and the following sources:

• "Proposal Writer's Guide" by Don Thackrey  
• "A Guide to Proposal Planning and Writing" by Jeremy T. Miner and Lynn E. Miner
• "Developing and Writing a Grant Proposal" from the Catalog of Federal Domestic Assistance

6.1.2 Federal Agencies

Guides written for the more focused purposes of writing proposals for federal agencies include:

• NIH Research Proposals (NIH)
• "Guide for Proposal Writing" (NSF/EHR/DUE).

6.1.3. Foundations

Guides written for the more focused purpose of writing proposals for foundations include:

• "Proposal Writing Short Course"  (Foundation Center)

6.1.4. Workshops
Learning to write winning proposals requires an intensive hands-on experience. Numerous organizations exist to provide that experience, but most charge a considerable fee and require a commitment of 3 to 5 full days of continuous training.
The Office of Research Training & Compliance at GW offers and introductory workshop to writing winning grant proposals. This introduction sets the foundation for improving the probability of award with a Blackboard site for additional help in developing a full proposal as a learner directed experience or in follow-up live sessions with a facilitator.
For the schedule of current sessions, see the ORT&C page at the OVPR Web site at, http://www.gwu.edu/~research/traininginfo.htm, or register on-line at the Center for Innovative Teaching & Learning at, http://cidd.gwu.edu/workshops/.
To request enrollment at the Blackboard site, or for more information about special workshop sessions for your department or center, contact the Office of Research Training and Compliance (ORTC) at 202.994.7991.

6.1.5. Peer Review Groups
Best practice in proposal development means that the sponsor’s reviewers are not the first reviewers of the proposal. Authors of winning proposals have at least three other individuals read through their draft proposals and provide constructive feedback – a content expert, a naïve reader, and a copy editor.
At GW, another avenue for improving the probability of producing a winning proposal to a level greater than 50 percent is through Peer Review Group (PRG) feedback. The PRG at GW is comprised of faculty members who have agreed to commit to providing any other member of the PRG a review of a draft proposal and personal feedback within three days of receipt of the draft. Authors agree to commit to provide the digital file of their draft at least two weeks prior to the sponsor’s due date for submission. All PRG members must first complete the orientation to fiscal responsibility and compliance in sponsored research, the full workshop in writing winning proposals, and attend periodic mini workshops on select topics in proposal writing and award management.
For more information about becoming a PRG member at GW, contact the Office of Research Training and Compliance (ORTC) at 202.994.7991.

6.2. PRE-PROPOSAL CONTACT WITH SPONSORS

In limited circumstances, some solicitations require or restrict certain pre-proposal communications and activities. It is especially important for the Principal Investigator to contact his/her RSC to determine the most appropriate approach for addressing any such pre-proposal submission requirements even if the Principal Investigator has had previous experience with a particular sponsor, or the program announcement or proposal solicitation states a specific course of action. The reason for this is that only certain individuals are authorized to commit the University to a research proposal/program, and care must be taken to verify that any pre-proposal contacts or activities do not commit the University to proceed with a proposal/program.

In all cases involving any communications with sponsoring agencies or prospective sponsoring agencies, the following should be adhered to:

• OVPR is the only officially designated negotiator between the University and sponsoring agencies.
• OVPR knowledge of, participation in, and approval of all negotiations with sponsors that commit the University is required.
• All correspondence requesting approvals from sponsors must be submitted through OVPR.

These pre-proposal activities may take a number of forms as follows.

6.2.1. Letter of inquiry 

A “Letter of Inquiry” is a general presentation of a program idea designed to elicit feedback from a potential sponsor.  No commitments should be made in the letter.  Letters of inquiry do not require OVPR review and no formal routing is required.  It is recommended, however, that a copy of any such correspondence be forwarded to your RSC so s/he may be prepared for the proposal development effort or agency inquiries that may result from the letter.

6.2.2. Concept papers

The prospective sponsor may request concept papers. Concept papers tend to be approximately two-to-four pages in length, and they highlight key features of the anticipated proposal. Normally, these are sent to the program officer after telephone conversation requesting permission to submit a concept paper. The program officer may comment on areas to highlight, what should be avoided, and activities that should be included. Generally, in shortened form, these would include:

(1) Project title.
(2) Statement of need - with relevance to sponsor's mission.
(3)  Goals and objectives - overall goal, specific objectives, quantifiable.
(4)  Methodology - related to objects, anticipates questions, objections, snags.
(5)  Resources and personnel.
(6)  Generalized budget - with cost sharing (if required) and F&A, which should be coordinated with the appropriate RSC to verify that it does not commit the University and the information is accurate.

6.2.3. Letter of intent. 

A “Letter of Intent” expresses the intention to submit a proposal in response to a particular program announcement or request for proposals.  Letters of intent are generally solicited by the sponsor in conjunction with an announcement that is expected to generate widespread interest.  Agencies generally require that such letters present only a general statement of the intended program theme.  If the letter of intent contains budget estimates or representations, it should be reviewed and approved by the appropriate RSC prior to submission.  The Managing Director of Research Support and Analysis will sign the letter as an indication of the institution’s concurrence with the planned submission.
                                        
6.2.4. Preliminary proposals (pre-proposals)

 Preliminary proposals, like letters of intent, are generally solicited by the sponsor.  A preliminary proposal usually includes a one- to five-page program description.  It may also require a draft budget and some indication of GW’s willingness to support the program through a commitment of resources.  Any document that mentions budget figures or commits GW personnel, facilities, and/or other resources requires OVPR review initiated through the RSC and institutional signature approval.

6.2.5. Personal contacts with sponsors

Whether, when and how to make contact with sponsors (phone, e-mail, visit) may be determined by timing - before, during, or after proposal submission.

6.2.5.1. Before Proposal Submission: Prior to proposal development and/or submission, Principal Investigators may establish contact with program personnel, especially if there is a need to clarify unclear areas in the guidelines for a particular program.  Program officers in federal agencies can be extremely helpful.  It may be advisable to initiate contact via e-mail to establish a time for a personal visit or a telephone call.  Program officers prefer to talk to the Principal Investigator, especially when the issues relate to the content of the proposal. Sponsors may have guidelines for such contacts to protect fairness in the process and the appearance of impartiality in granting awards. Sponsor contact information and guidelines may be obtained from the appropriate RSC or consultation with applicable solicitation documents which generally provide such information.

6.2.5.2. During Proposal Development: Some sponsors, while not requiring pre-proposals, will review drafts or comment on concept papers.  The National Endowment for the Humanities, for example, has traditionally offered to read draft proposals if they are received well in advance of the deadline.  Such feedback gives agency perspective and helps to establish rapport with a program official who, in some cases, can be the deciding factor in whether a program is funded. 

6.2.5.3. After Proposal Submission: Many sponsors have a set schedule for when proposals are reviewed and when funding decisions are supposed to be made.  Any status questions may be addressed by:

(i) For those agencies with internal review processes, the Principal Investigator may call the program officer concerning the proposal's status.
(ii) For sponsors with a grant and contract staff, call the Grants or Contracts Office to see where the proposal is in the process.  Although grants officers rarely make funding decisions, they are good people with whom to establish a relationship.  They have detailed knowledge on agency requirements, upcoming deadlines, new programs, etc.   For NSF, status checks on proposals is commonly done on-line.  This saves a lot of time, although it eliminates the opportunity to establish contact with sponsor staff.
(iii) Contacting the appropriate RSC to request initiation of a status check with the sponsor.

Section 7: Budget Proposal Overview

7.1. BUDGET PROPOSAL DEVELOPMENT

The budget describes the costs to be incurred by the program and explains why each is needed. The budget should establish the fiscal feasibility of a program and be aligned with its methodology. Reviewers use the budget as a mutually reinforcing summary of the entire proposal, so considerable thought should go into its preparation. Further, reviewers tend to be knowledgeable of the costs of research and are experienced in estimating time and effort. They examine the budget in the context of the program narrative, evaluate whether sufficient and appropriate personnel to perform the work have been included, and match the overall budget to the work proposed.

Budget requirements may vary widely by type of award, cost reimbursement or fixed price, or by sponsor, federal or private. Most sponsors provide detailed instructions and printed forms for budget preparation. RSCs have expertise in the development of budgets and stand ready to assist in their preparation. RSCs can also supply budget templates to assist those Principal Investigators who prefer to prepare their own budgets before conferring further with their RSC. A list of all forms can be found in Appendix E

7.1.1. Proposal Budget Objectives

According to The Grantsmanship Center, a good proposal:

• Identifies budget period requested
• Includes estimated program costs that are allocable, allowable, and reasonable
• Includes all program costs – both direct and indirect
• Shows how each item is calculated
• Has a budget that does not exceed maximum award amount available
• Supports equipment costs with vendor quotes
• Meets any cost sharing/matching requirements
• Identifies and documents any third party matching commitments
• Takes annual merit increases into account
• Fully describes and justifies items in a budget narrative
• Is concise, organized and provides a “clear” picture of the program
• Is provided on any budget forms that may be required by the funding source

7.2. COST PRINCIPLES AND REQUIREMENTS BY SPONSOR

In order to prepare a proposal budget, it is necessary for the Investigator to understand basic principles regarding the kinds of costs that may be appropriately placed in the proposal. This Section provides a brief overview of these cost principles including specific references to standards applicable to federal programs.

7.2.1. Federal Sponsors - Cost Principles for Charging Direct and Indirect Costs / OMB Circular A-21
The US Office of Management and Budget (OMB) has issued, in conjunction with college and university representatives, Federal Management Circular A-21, "Principles for Determining Costs Applicable to Grants, Contracts and Other Agreements (“OMB circular A-21”) with Educational Institutions." This publication identifies allowable direct cost categories and prescribes a standard distribution and allocation method for the recovery of F&A (indirect) costs. Because OMB Circular A-21 also establishes standards for consistency in the treatment of costs for institutional accounting, the OMB Circular A-21 regulations apply to grants, contracts, and other award vehicles accepted by the University. Exceptions to the OMB Circular A-21 principles require the approval of the Vice President for Research.

Pursuant to OMB Circular A-21, Section C, costs charged to federally sponsored programs must be reasonable, they must be allocable to the particular program charged, they must be allowable charges under applicable federal standards and they must be permitted under the terms of the specific award and charged in a consistent manner, in that similar costs incurred in like circumstances are treated in a similar manner. Following is a brief discussion of each of these concepts as they apply to sponsored programs.

7.2.1.1. Reasonable:  According to OMB Circular A-21, a cost is “Reasonable” if the nature of the goods or services acquired or applied, and the amount involved therefore, reflect the action that a prudent person would have taken under the circumstances prevailing at the time the decision to incur the cost was made. In other words, the costs would be considered reasonable for the performance of the work by a prudent person taking the same circumstances into consideration.

Among the considerations in evaluating reasonableness are whether the cost is: (i) necessary for the operation of the institution or (ii) necessary for the performance of an award and (iii) the cost is consistent with institutional policies.

7.2.1.2. Allocable:  According to OMB Circular A-21, a cost is “Allocable” if the goods or services involved are chargeable or assignable to such cost objectives in accordance with relative benefits received or other equitable relationship. In more simple terms, Allocability means that:

• Only expenses that specifically benefit a program can be charged to that program, or
• If an expense benefits more than one program, it is to be allocated among the programs in proportion to the benefit each program receives, or
• It is necessary to the overall operation of the institution and is deemed to be assignable in part to sponsored programs.

7.2.1.3. Consistent: Consistent treatment of costs is a basic cost accounting principle and is required by OMB Circular A-21 to assure that the same types of costs are not charged to federally sponsored programs both as direct costs and as indirect costs. According to OMB Circular A-21, a cost is “Consistent” if costs incurred for the same purpose, in like circumstances, are either direct costs only or F&A (indirect) costs only, but not both. That is,  charges in like circumstances are treated in like manner as either direct or indirect charges, and such charges are treated the same from one department to the next and all across the University.

As an example of unlike circumstances, an administrative person could be charged as a direct charge IF special “unlike” circumstances were present, such as a where a program requires a specific person to be dedicated to it for an administrative purpose, such as a technical typist hired to do specific program tasks, or where the program qualifies as a major program. A “Major Project” For guidance on what constitutes a Major Project, see the appropriate RSC.

7.2.1.4. Allowable: The costs charged to an award must be permitted (i.e., “Allowable”) under the terms and conditions of the award, GW’s policies, and OMB Circular A-21 cost principles. In this regard, it is important to recognize that the fact that a cost requested in a budget is awarded as requested, does not confirm a determination of allowability. For example, organizations are responsible for presenting costs consistently and must not include costs associated with their F&A rate as direct costs. A cost could also subsequently be determined to be unallowable because of the category of cost. Examples of budget items that are usually unallowable include: alcohol, entertainment, gifts, unusually high salary increases, and salary greater than any agency salary cap. See Appendix L for a more comprehensive list of costs determined to be Unallowable on federal programs. For GW’s policy on the Identification and Treatment of Unallowable Costs, see http://my.gwu.edu/files/policies/Identification&TreatmentUnallowableCostsFINAL.pdf.

7.2.3. Cost Principles applicable to Clinical Research

For a discussion of cost principles related to Clinical Research, see the Clinical Research and Medical Billing Supplement, Chapter VII, Section 22, Clinical Research and Billing Supplement.

Section 8: Preparing Well-Supported Budget Proposals

With the Budget Proposal Overview as background regarding the various types of direct and indirect costs and the sponsor guidelines for what may be charged to grants, the following section covers the specifics of actually proposing these costs on grant proposals, including the specific categories of direct and indirect costs.

8.1. PROPOSING DIRECT COSTS

8.1.1 Proposing Project Staff

The Principal Investigator must verify that all individuals who will be devoting time to the proposed budget are included in the budget. Research programs can be staffed through internal transfers or external (new) hires. New full-time hires must be retained for the program consistent with GW’s Equal Employment Opportunity Office, although waivers of certain recruiting requirements are available in appropriate circumstances.  New part-time or wage positions may be established using more simplified procedures appropriate to their more limited roles. Please refer to Section 15.1 for more information about actually hiring staff when that time comes in the program cycle.
In preparing the proposal, consideration has to be given to how the research program will be performed and the categories of staff that will be required to provide the requisite proficiencies and capabilities to accomplish the program technical requirements. In this regard, GW has established eight academic research staff positions, as summarized below, for use in assembling proposal bidding estimates for staffing requirements in furtherance of potential research programs.

Research Assistant
Carries out research/development activities.  Preparation of literature reviews and/or data collection forms and procedures, data collection or administration of experimental procedures, data analysis or assistance in writing reports.  Works under immediate supervision.  Primary job functions do not require exercising independent judgment.  Reports to a supervisor or manager.  A BA/BS in related discipline is required or an equivalent combination of education, training and experience is required.

Senior Research Assistant (Researcher I – Academic)
Carries out research/development activities. Makes detailed observations, analyzes data, and interprets results. Compiles results and prepares technical reports and documentation of outcomes.  Requires a bachelor's degree and 1-3 years of experience in the field or in a related area. Has knowledge of commonly-used concepts, practices, and procedures within a particular field.  Performs activities similar to those of a Research Assistant but is more experienced and independent.

Research Associate (Researcher II – Academic)
Carries out research/development activities. Makes detailed observations, analyzes data, and interprets results.  Compiles results and prepares technical reports and documentation of outcomes.  Requires a master's degree and 1-3 years of experience in the field or in a related area.  Familiar with standard concepts, practices, and procedures within a particular field.  Performs a variety of tasks.  Works under general supervision; typically reports to a Principal Investigator.  A certain degree of creativity and latitude is required.

Senior Research Associate (Researcher III – Academic)
Carries out research/development activities. Makes detailed observations, analyzes data, and interprets results.  Compiles results and prepares technical reports and documentation of outcomes.  Requires a master's degree and at 3 - 5 years of direct experience in the field. Familiar with a variety of the field's concepts, practices, and procedures.  Performs a variety of tasks.  Typically reports to a project supervisor or project manager.  A wide degree of creativity and latitude is expected.

Post-Doctoral Scientist (Post doctorate Scientist)
Primarily a temporary position in which the incumbent plays a substantive role in planning and conducting research. Requires Ph.D in the field or in a related area. Familiar with a variety of the field's concepts, practices, and procedures. Performs a variety of tasks. Performs work under the supervision of experienced researchers.

Research Scientist
Assumes the responsibilities for planning, conducting and supervising research at a level functioning similar to that of an Assistant Professor.  Requires a master's degree/PhD and at least 5 years of experience in the field or in a related area to include two to five years of research and/or college-level teaching in a field basic to the work to be performed.  Familiar with a variety of the field's concepts, practices, and procedures. Relies on extensive experience and judgment to plan and accomplish goals. Performs a variety of tasks. Leads and directs the work of others.

Senior Research Scientist
Assumes major responsibilities for planning, conducting and supervising research at a level functioning similar to that of an Associate or Full Professor.  Requires a master's degree/PhD and at least 8-10 years of experience in the field or in a related area; as well as, two to five years of research and/or college-level teaching in a field basic to the work to be performed.  Experience must include planning, conducting and reporting as primary responsibility. Familiar with a variety of the field's concepts, practices, and procedures. Relies on extensive experience and judgment to plan and accomplish goals. Performs a variety of tasks. Leads and directs the work of others.

Lead Research Scientist
Assumes leadership responsibility for  planning, conducting and supervising research for a research/studies group; for example, directs a complex center or institute or carries out major research administration responsibilities associated with multiple and substantial grants or contracts.  Requires a master's degree, PhD and at least 10 years of experience in the field or in a related area.    Experience must include supervising the activities of a research or studies group or unit and for planning, conducting and reporting major research investigations or studies. Familiar with a variety of the field's concepts, practices, and procedures. Relies on extensive experience and judgment to plan and accomplish goals. Performs a variety of tasks. Leads and directs the work of others.

Note:  These ranges are for University/Medical Center research positions.  We realize, however, that certain technical areas and competencies may require salaries above these published maximums.  These requests will be approved on a case by case basis.

8.1.1.1.  Proposing Faculty Compensation: As provided in the Faculty Handbook, Faculty members have an annual base salary for either the academic or fiscal year. When a faculty member engages in a research program funded by a sponsor, a specific percentage of the researcher’s effort may be allocated to that program in accordance with the actual effort to be devoted and the terms of the award. In accordance with GW Policy for Effort Reporting and Certification, the total combined effort for GW compensated effort and for the sponsored program commitments may not exceed 100 percent (100%) of the faculty member’s available time. For further information, see GW’s Effort Certification Policy, my.gwu.edu/files/policies/EffortCertificationFINAL.pdf, Supplemental compensation for teaching overload may be approved under certain circumstances as described in the Overload Compensation Section of the Faculty Handbook. GW faculty may not be eligible for consulting on GW sponsored research programs, but there are exception to this rule that permit such consulting to occur as provided in Section 5.2 of the Faculty Handbook

• On Academic Year Appointments: Faculty members on an Academic-year appointment may devote up to 100 percent effort on sponsored programs during the three summer months, subject to sponsoring agency percent effort limitations. Additionally, faculty may buy out time during the academic year as provided in the Faculty Handbook.

• On Fiscal Year Appointments: Faculty members appointed on a fiscal year basis (July 1- June 30) generally are not entitled to additional compensation for sponsored research activities except in limited circumstances when serving as a consultant as specified in the Faculty Handbook, Section 5.2. Again, faculty may buy out time during the academic year as provided in the Faculty Handbook.

• Federally-imposed Caps on Salary Reimbursements: Some sponsors impose limits or “caps” on the allowable charges for direct labor of program staff. For example, the salary cap for NIH for Executive Level I effective January 1, 2006 is $183,500. The Medical Center handles this salary cap by setting up a separate PTA Account and a separate Banner Number for any dollars in excess of the NIH salary cap to be collected separately so they are not charged on the award. No compensation in excess of such  salary limits may be charged to that sponsor. Information regarding the currently applicable salary caps may be obtained by consulting with the appropriate Research Services Coordinator. Any compensation to the individual in excess of those salary caps must be absorbed by the Department and, while it is tracked in a cost sharing account to isolate the excess costs, the excess generally will not count for cost sharing purposes if cost sharing applies to the award in question. For further information, please see the Policy on Cost Sharing on Federally  sponsored Agreements, http://my.gwu.edu/files/policies/Cost%20Sharing%20on%20FederalSponsored%20Agreements%20FINAL.pdf

8.1.1.2. Other Project Staff: Several other types of professional and non-professional staff may be employed on sponsored programs in graded positions, including technicians, laboratory assistants, programmers, statisticians, and plant or service staff if allowed under the terms of the award. Such personnel can be regular full-time, regular part-time, or temporary employees. When in doubt about the proper personnel classification and title for program personnel, the investigator should check with the  appropriate Research Service Coordinator within OVPR.
As mentioned in Section 8, Administrative and clerical staff are generally not allowed as direct charges. Consult the appropriate Research Service Coordinator within OVPR before including any administrative or clerical personnel in the budget to determine if an exception might apply.

8.1.2.  Participant Support Costs

8.1.2.1.  Paying Students on Sponsored Projects
The following are methods for supporting graduate and undergraduate students in conjunction with work on sponsored programs:

Full support from sponsor
Stipend - sponsor/tuition - GW
Research Assistantship/Associateship
Temporary (hourly) employee (for sponsored research not administrative support)
Work-Study Student

Full support from Sponsor: PIs may propose stipend or salary/wage support and fringe benefits and tuition from the sponsor. This is the best option, both for the student and for the University. As provided in GW’s Policy on Stipends, http://stipends.gwu.edu, the use of stipends to support students carries certain restrictions. A “Stipend” is a gift to support a student’s education. Stipend recipients cannot be required to perform work. Such gifts may be appropriate where no services are rendered or required. If the work is required to complete the scope of work, then the student should be paid as an employee, not given a stipend. These awards are granted for the purpose of defraying the cost of educational and/or other incidental expenses related to attendance at the University and, under Internal Revenue Service regulations, cannot carry requirements for specific duties or attendance. Stipends are taxable, even though withholding is not taken from them: students need to know this so they can plan accordingly.

Virtually all stipends at GW should be given to registered students at GW. An exception is students brought to GW from other schools for special programs (e.g., NSF’s Research Experiences for Undergraduates program). Stipends paid by grants should be given to students in degree programs relevant to the grant who then conduct their research and educational activities in an area relevant to the scope of work of the award. To document the necessity of the stipend payments, there should be a training component in the grant proposal that specifies these student activities. It is imperative that verification be obtained that the individuals receiving stipends are valid students and valid recipients of the stipend. For a detailed checklist to verify whether a stipend is appropriate, refer to http://stipends.gwu.edu/forms/PmtCharChecklist.pdf. For tax and other implications of stipends, please refer also to the GW Policy on further information on Stipends: , see below and http://stipends.gwu.edu/index.cfm, GW’s Tax Department at http://www.gwu.edu/~tax/international-scholarships.cfm.

When requesting stipend support in a proposal, the Principal Investigator must make a clear and compelling case for stipend funds that includes a discussion of the relationship of the student's activities in pursuit of his/her personal educational goals and the subject matter of the program. Stipend charges are allowable for programs that have a training component. Stipend payments must pass the same tests of allocability, allowability, and reasonableness as other costs. The rate should be based on departmental norms. Consult with the appropriate Research Services Coordinator within OVPR for further information on these rates.

The University does not recover facilities and administrative (indirect) costs on stipends or on tuition, but does apply the F&A rate to salaries/wages and the associated fringe benefits.

Stipend (see above note) from sponsor/tuition from GW: This is an alternative to the first option, but commits the institution to providing for the tuition award. A limited number of tuition awards are available through a department, school, or the Office of Graduate Student Assistantships and Fellowships. It is necessary to get approval to include an institutional tuition award in a proposal from the appropriate University office in advance of submitting the proposal to the Office of the Vice President for Research for institutional endorsement. For further information and a checklist to verify the appropriateness of using a Stipend, refer to http://stipends.gwu.edu/forms/PmtCharChecklist.pdf.

Tuition: Tuition should be based on the current tuition rates plus an increase factor effective in the fall semester of each year. A four-to-five percent increase is generally acceptable. For current tuition rates, go to http://www.gwu.edu/~sao/tuition.html. In proposing tuition, it is imperative that the Principal Investigator verify that the intended tuition recipient is a valid recipient pursuant to the research agreement. The University does not recover facilities and administrative (indirect) costs on tuition.

Information regarding the procedures for setting up tuition awards on sponsored research programs, as well as the corresponding forms, is available at http://stipends.gwu.edu under the tab “forms and letters.”

Research Assistantship/Associateship: In this scenario, the sponsor pays the salary and fringe benefits for a graduate student who is assigned to work on the program. By virtue of their employment, both full-time and part-time research assistants and associates are eligible for employee tuition benefits with no waiting to complete a probationary period. Research assistants must, however, be appointed for six months or longer to be eligible for the benefit. The amount of tuition benefit available differs depending whether the research assistant is employed full-time or part-time and whether s/he is a doctoral or master's student.

**Note that all hires into full-time regular (benefited) positions require that a position be created and recruited according to University policies and procedures. Consult with the University's Equal Employment Opportunities Office, extension 4-9656, concerning recruiting requirements.

A part-time research assistant must be employed for a minimum of 35% time (730 hours/year) to be eligible for tuition benefits. F&A is assessed on salary and fringe benefits.

Temporary hourly wage employee: Hiring a candidate as a temporary hourly wage employee (usually a student) is a good choice if the work is short-term and funds are limited. A temporary position is a transitory position without University benefits. Cumulative employment in one or more temporary positions may not exceed 700 hours in a fiscal year. All temporary positions are ungraded and most are categorized as nonexempt. No tuition benefits apply. Sponsor pays wages, fringe, and F&A.

Work-Study Student: This option is great if a student qualifies for financial aid on the basis of need. Note: Only US citizens are eligible for work-study awards. If an undergraduate or a graduate student has the requisite financial need and is eligible for loans, create a research assistant position with him/her in mind through the Career Center's Student Employment Office. The cost to the award is 30% of the wages and all of the fringe benefits @ 6.1% (the remaining 70% of wages is paid from funds provided through the federal work study program). Contact the Office of Graduate Student Support to have a graduate student nominated as the recipient of a work-study award. Undergraduate students receive work-study awards at admission.

Post-Doctoral Scientist (Post doctorate Scientist): Primarily a temporary position in which the incumbent plays a substantive role in planning and conducting research. Requires a PhD in the field or in a related area. Familiar with a variety of the field's concepts, practices, and procedures. Performs a variety of tasks. Performs work under the supervision of experienced researchers.

8.1.3. Purchasing Goods and Services on Sponsored Programs

The University maintains a number of policies governing the purchase of goods and services on sponsored programs including those promoting opportunities for Disadvantaged Businesses, http://my.gwu.edu/files/policies/DisadvantagedBusinessEnterprisesFINAL.pdf, and those restricting purchases. For example, there are policies restricting purchases from vendors subject to a conflict of interest, http://my.gwu.edu/files/policies/ConflictofInterestandcommitment.pdf or those who are suspended or debarred from doing business with the federal government, http://my.gwu.edu/files/policies/DebarredSuppliersPolicy.pdf.

In accordance with the University’s Bids, Quotes and Sole Source Justification Policy, GW maintains procedures specifically related to the purchase of goods and services under sponsored research programs. The University procures goods and services for sponsored programs based on the standards applicable to federally-sponsored programs. This level of documentation is generally sufficient to meet the rules of state, local or private sponsors as well as the requirements of a specific sponsored agreement. Any additional procurement requirements of a particular sponsored agreement should also be addressed as necessary. For further information regarding applicable polices related to the procurement of goods and services visit the Supply Chain website at http://www.gwu.edu/~supchn/scmain.htm or see the University’s Policies, Section II (F) Procurement, http://my.gwu.edu/mod/upolicy/index.cfm?exp=1&thisTab=2.

8.1.3.1. Capital Equipment: According to the University’s Capital Asset Management Policy, http://my.gwu.edu/files/policies/CapitalAssetMngtFINAL.pdf, Capital Equipment is defined as equipment having a unit cost of $2,500 or more and a useful life of two years or more. Software costing more than $2,500 is categorized as equipment. General-purpose office equipment may normally not be purchased on federal awards. Further, it is necessary to check program guidelines carefully to be sure special-purpose equipment purchases are allowable. Itemize capital equipment to be purchased, providing a description, a written vendor cost estimate, and justification of need. The cost of a single unit of equipment should include related charges, such as those for accessories needed to make it operable, installation fees, delivery costs, insurance, and taxes, if any. Some sponsors may provide needed equipment directly to a program rather than provide funds for its purchase. Under OMB Circular A-21, where the purchase of equipment or other capital items is specifically authorized under a sponsored agreement, the amounts thus authorized for such purchases are assignable to the sponsored agreement regardless of the use that may subsequently be made of the equipment or other capital items involved.

Additionally, when submitting a proposal, Principal Investigators should estimate whether equipment purchases will require renovations, additional power and the like over the life of the program. Principal Investigators should also endeavor to identify several vendors who can provide bids for supplying the equipment. Principal Investigators should also assist with the evaluation of competitive bids received.. Lost or missing equipment is reported to the Fixed Assets Office at http://my.gwu.edu/mod/deptdir/index.cfm?dept_id=1002..” For further information, please see http://my.gwu.edu/files/policies/CapitalAssetMngtFINAL.pdf, and the Furniture and Equipment Capitalization Threshold Policy http://my.gwu.edu/files/policies/FurnitureandEquipmentCapitalizationThreshold.pdf.

8.1.3.2. Consumable Supplies and Expendable Equipment: This category includes, but is not limited to, the following items: chemicals, glassware, small electronic components, computer and printer supplies, and animal purchases. Provide estimated costs for each category. In proposing these types of supplies, differentiate between allowable items, such as computer software and supplies, and general-purpose office supplies in the budget justification.

Costs for general purpose office supplies such as paper, pens, paperclips and the like are recovered indirectly through GW’s F&A rate and are generally not allowable as a direct charge. The same federal regulations that restrict administrative and clerical salaries also identify general-purpose office equipment and supplies as unallowable direct costs. There is an exception to this rule that allows these items to be proposed in the relatively rare cases where Major Project status has been conferred on a program. This categorization allows administrative and clerical salaries as well as general office supplies to be appropriately charged if such a Major Project status exception to normal OMB Circular A-21 principles has been granted. Confer with the appropriate RSC before making any assumptions about whether Major Project status has been conferred on a program.

8.1.3.3. Equipment Maintenance: Any proposed charges for equipment maintenance should be based on charges for maintenance agreements specific to the equipment proposed. 

8.1.3.4. Proposing Independent Contractors (Service Providers/Consultants): A PI may determine to enter into a contractual agreement with an Independent Contractor to help carry out the work proposed under his/her sponsored project award.  Independent Contractors (“ICs”) have unique expertise, provide professional advice and guidance, provide a distinct service or product, typically a report, translation, analysis, or the like that is commercially available to the general public.  The work is usually performed off University premises and offered to many different buyers within normal business operations.  The work performed by an Independent Contractor is ancillary to GW’s sponsored project but necessary to carry out the overall objectives of GW’s sponsored award.  ICs are not employees of the University and may not use GW resources to perform their services.  

A PI should not confuse an Independent Contractor with a Subrecipient.  A subaward is collaborative in nature whereby the subrecipient is performing an actual portion of GW’s statement of work to the prime sponsor.   A subrecipient may be a co-author in a publication or may seek protection for his or her invention.  Subrecipients have their performance measured against the portion of the scope of work proposed to GW and have the responsibility for programmatic decision making.  The scope of work proposed by a subrecipient is generally of a research and development nature performed on a best efforts basis.  The costs proposed are generally based on estimates as the outcome may be unpredictable.

An IC should be proposed in the budget and fully justified in the budget justification to the sponsor during the routing process of the Principal Investigator’s proposal to the prime awarding agency.  If the decision has been made to enter into an Independent Contractor Agreement (ICA) after the primary award has been received, the terms and conditions of the award must be checked by the PI and the RSC in order to determine if entering into an Agreement is allowable.  Prior sponsor approval may be required.

Documentation requirements at proposal submission:

1. IC should be proposed in the budget and fully justified in the budget justification to the sponsor.
2. If the IC is an individual, a copy of the individual’s vitae curriculum or resume should be included.

If GW receives the prime award from the sponsoring agency and the PI wishes to enter into an ICA, a set of forms are required to initiate the process.  Complete the Request for Independent Contractor Agreement form found on the OVPR website.

8.1.3.5. Service Agreements: As with the procurement of goods, purchasing services is subject to the competitive requirements and sole/single source documentation requirements of GW’s Bids, Quotes and Sole Source Justification, my.gwu.edu/files/policies/Bids,Quotes,SoleSourceFINAL.pdf. “Service agreements” generally result in the delivery of a product to the University, such as translations, reports, position papers, abstracts, training, and web pages. Service agreements may be issued to either individuals or companies. Service Agreements are typically paid based on the cost of the deliverable or task to be completed, usually a cost per unit rather than a cost based on labor charges. For example, a publication house will produce 1,000 training manuals for $5,000.

Services are provided by individuals who are not on GW’s payroll or by companies. An individual service-provider needs to complete the “Twenty Factors Test” to be sure he or she should not be classified as an employee, available at http://eas.gwu.edu/home/forms/sc/twentyfactors.pdf.

If a service provider is uniquely qualified to perform the work, a sole source justification must be presented during the proposal submission process. A form of a sole source justification is available at Appendix E, Forms. OVPR has also developed models for service agreements, see Appendix E, Forms. These models may be amended to accommodate individual program requirements.

As with any procurement, it is imperative that Principal Investigators and others in the process avoid even the appearance of a conflict of interest in selecting Service Agreement vendors, consultants and subcontractors.

8.1.4. Travel

Reimbursement of travel expenses are made as provided in GW’s Travel Policy, http://my.gwu.edu/files/policies/TravelandEntertainmentPolicy.pdf. Travel costs should distinguish between Foreign, Domestic, and Local Travel. In the budget justification, indicate briefly the purpose and frequency of expected travel and its applicability to the program. Consult the University Travel Policy for information on booking travel, reimbursement, mileage rates, and other matters associated with travel. http://my.gwu.edu/files/policies/TravelandEntertainmentPolicy.pdf Travel advances may be requested by faculty and staff when traveling on official University business if the proper form is used and it is approved by an authorized person. Please see the Travel Advance Policy for further details on required forms and approvals as well as for information on deadlines for repayments of such advancements that are not needed, http://my.gwu.edu/files/policies/TravelAdvanceFINAL.pdf. The university imposes restrictions on first class/business travel, which are generally unallowable.

For budgeting purposes, the schedule of per diem rates permitted by the federal agencies may be used to estimate costs. The University, however, reimburses on an actual expense basis. Exceptions to this policy require the approval of the Vice President for Research. In addition, some sponsors may place limitations or restrictions on travel outside the United States. Be sure to follow sponsor guidelines. Additionally, any foreign travel to a country on the US State Department Travel Advisory List requires special approvals. For further information on these travel restrictions and approvals, please contact the appropriate Research Service Coordinator.

8.1.5. Other Direct Costs

Following is a partial list of the more common types of “Other Direct Costs” or “ODC” that are charged to sponsored programs at GW.  The emphasis is on what information is needed to enable the Principal Investigator to assemble information for proposing these Other Direct Costs. For further information on how to obtain proposal pricing information for these categories of costs, please contact the appropriate RSC. For information on how to acquire these types of goods or services once an award has been received, please refer to Section 16, Program Expenditures.

8.1.5.1. Animal per diem charges: Charges are based on rates that are approved by the Comptroller’s Office and may be obtained from the Animal Research Facility (“ARF”). Blanket Purchase Orders are available that contain detailed pricing information by species/strain that could be used as a basis of cost estimate for proposal submission purposes. The ARF and the Supply Chain Organization or “SCO” can also assist with assembling this information. The appropriate Research Services Coordinator can also assist in obtaining this information.

8.1.5.2. Communications: This category includes the program-related costs of bulk mailing, postage, commercial carrier, telex, fax, e-mail, long-distance telephone, telegrams or cables, and computer time. Generally, these types of charges are covered in GW’s indirect or Facilities and Administration rate. However, when a program is expected to include a significant amount of these types of charges, they may be proposed as direct costs. As an example, a program that requires mailing a survey to five thousand subjects might include those mailing costs as direct costs whereas a normal program that requires mailing periodic lab results would not include recovery of those minor mailing costs as a direct charge. For further information on when to charge costs that are normally recovered through GW’s indirect cost recovery mechanism, please confer with the appropriate RSC.

8.1.5.3. Payment to Human Subjects: Special Proposal Planning Considerations, http://www.gwumc.edu/research/, in the event the research will involve use of human subjects on any research program at GW, the charges for these subjects would be based on rates proposed to the sponsor for approval.

8.1.5.4. Publication and Printing Costs: This category includes manuscript preparation expenses, illustration costs, and page and reprint charges in established journals. Costs for publication of a book, monograph, or pamphlet usually cannot be charged to a program unless prior approval has been received from the sponsor. GW uses a Service Agreement when a vendor will be providing a tangible deliverable is involved.

8.1.5.5. Rental Costs: This category applies to the cost of rental space in buildings not owned by the University. When programs are conducted in rental space not owned by the University, the off-campus F&A cost rate applies. The category also includes the cost of equipment rental if it is required for the program. In proposing costs for a program, consideration should be given to whether it would be appropriate and more cost effective to lease rather than to purchase equipment required in the performance of that program.  Because GW is not a commercial company, there are no federal or state tax deductions for leasing equipment which effectively increases the cost of leasing. Accordingly, it is usually not in GW’s interests to lease except in rare cases involving highly specialized equipment. For further information, consult the SCO website, http://www.gwu.edu/~supchn/leasing.htm.

8.1.6. Proposing Subawards

When GW plans to enter into a subaward with another organization, the following steps must be completed:

1. Check box D of the OVPR Proposal Routing and Approval from entitled, “Subaward Information.” http://www.gwu.edu/%7Eresearch/forms/routingform.pdf
2. Include documentation as indicated in the first half of the Subaward Proposal Checklist http://www.gwu.edu/%7Eresearch/forms/SubAchecklist.pdf and include with the routed proposal.
   
   The Subaward Proposal Checklist and set of forms have been generated for ease in assisting the Principal Investigator in gathering and preparing the information required to enter into a subaward.

Once the proposal has been submitted to the sponsor, GW will await award notification from the sponsor. If an award is made, refer to Section 14 to review the PI’s Post-Award  roles and responsibilities checklist, specifically Section I for instructions regarding the Research Service Coordinator’s (RSC) preparation of the subaward to the subrecipient. After review and signature approvals of the subaward, a Purchase Order would be set up for billing purposes.

 If a subaward is contemplated after GW’s proposal submission to the sponsor, special approvals may be required from the sponsoring agency prior to issuance of an agreement.  Prior approvals are generally indicated in the terms and conditions section of the prime sponsor’s award document.  Principal Investigators should notify their RSC immediately and the RSC will contact the sponsor for approval.

8.1.6.1. Subaward Cost Analysis: In order to evaluate a subrecipient’s proposed budget, GW requires that a cost analysis be performed prior to award using the Subrecipient Fair and Reasonable Cost Analysis/Basis of Selection and Sole Source Justification Form.  http://www.gwu.edu/%7Eresearch/forms/FairReasonCostAnalPACntrct.pdf
The cost analysis provides a summary level review of the subrecipient’s budget to determine if the costs proposed are reasonable and realistic for the work being performed.

For the University’s policy regarding subrecipients, including annual GCAS review requirements of subrecipient audit reports, see http://my.gwu.edu/files/policies/SubrecipientPolicyFINAL.pdf.

8.2. FACILITIES AND ADMINISTRATIVE (F&A or INDIRECT) COSTS

F&A costs represent those expenses that cannot be readily allocated to any single research or training program but which represent the University's costs for carrying out research and training activities. These costs, which include on-campus space and utilities devoted to research purposes, administrative and library support for the University's research effort, etc., are equally real, but by their nature cannot be directly allocated to a specific program.

Like all other universities with federally funded research grants and contracts, GW prepares and submits a periodic determination of F&A costs based upon operating expenditures in conformance with the OMB Circular A-21 standards. The submission is reviewed by federal auditors and is negotiated by the University with representatives of the University's cognizant federal agency, the Department of Health and Human Services (DHHS).

Indirect costs include the following: operation and maintenance of facilities, including rent and depreciation/use charges on buildings and equipment; library services; research and training administration expenses; deans' and department chairpersons' office expenses, including salaries and wages expended jointly for research and instructional activities; and overall University administration related to sponsored programs.

The current F&A Cost Rate Agreement with DHHS outlines rates for both on- and off-campus activities for both the University and the Medical Center. For current rate information applicable to on- and off-campus and other rate information, please see my.gwu.edu/files/policies/CostSharingonFederalSponsoredAgreements.pdf. These rates must be incorporated into all budgets for sponsored programs. F&A costs are charged on a modified total direct cost base that excludes capital equipment, capital expenditures (alterations and renovations), patient care, tuition remission, space rental, scholarships/fellowships (student stipends), and subcontract costs in excess of $25,000. 

In applications for research and training support to non-governmental sponsors, including foundations and industry, the standard charge for University F&A expenses should be used. When a sponsor has a written policy disallowing F&A costs, or when its policy limits recovery to a lower amount, the University must document the unrecovered F&A costs as cost sharing and absorb the cost itself (see below).
The Office of the Vice President for Research will provide guidance on the F&A expenses to be included in proposals to non-governmental sponsors. Exceptions to University policy on recovery of indirect costs require the specific written approval of the Vice President for Research(University exclusive of the Medical Center) or the Associate Vice President for Health Research, Compliance and Technology Transfer (Medical Center). All requests for exception must be carefully justified with approvals coordinated through the Office of the Vice President for Research.


8.3. FRINGE BENEFITS

Fringe benefits are charged as the University provides a percentage of salaries for all regular full-time employees and certain part-time employees to cover such benefits as retirement, health care, and tuition benefits. The funds generated are pooled and eligible employees may draw from them to the extent appropriate to the terms of their employment. There is a separate rate for temporary hourly wage employees who work 700 hours or less per year. Fringe benefit rates are determined annually; consult the Office of the Vice President for Research or its Web site (http://www.gwu.edu/~research/boiler.htm ) for current rate information.

8.4. BUDGET DEVELOPMENT CHECKLIST

To assist the Principal Investigator and others involved in preparing proposal budgets to verify that all appropriate items are prepared and included, the following are questions considered by Research Service Coordinators when reviewing the proposal budget:

Click here to use the fillable pdf version of the Budget Preparation Checklist.

Section 9: Cost Sharing

“Cost Sharing” is an institution’s contribution to the total cost of a sponsored program. These are costs not covered by the sponsor and, as explained below, may include: cash, equipment, in-kind faculty time or indirect costs covered by a university. Cost sharing at GW on grants and contracts reflects the University's contribution to the costs of doing a sponsored research program and requires the approvals of appropriate offices in the University. Sponsors sometimes expect universities to demonstrate a commitment to a program by providing some form of cost sharing. In these cases, the expectations are laid out explicitly. GW’s goal is to have outside sponsors pay full direct and F&A costs whenever possible, so that the cost of research is borne by the sponsor and not by units within the University. GW strives to cost share only when it is mandated. Consequently, decisions about cost sharing require careful consideration well in advance of proposal submission.  Cost sharing should not be offered where the sponsor does not require it. When cost sharing is necessary and approved as part of the proposal submission process, a Principal Investigator should promise only what the Principal Investigator, department and school can and will deliver. For more information on Cost Sharing, see the University’s policy on cost sharing on federally-sponsored awards as available in the University’s policies at http://my.gw.edu/files/CostSharingonFederalSponsoredAgreements.pdf.

9.1. KINDS OF COST SHARING

Cost sharing may involve Direct-cost sharing and F&A cost sharing.

9.1.1. Direct Cost Sharing

“Direct-cost cost sharing” is the University's provision of faculty time, staff time, equipment, computer support, and other resources as direct support for the program. Direct-cost cost sharing must be charged to a specific departmental, school, or University fund center and requires the written approval of the department chair, dean, and the Vice President for Researchr (University exclusive of the Medical Center) or the Associate Vice President for Health Research, Compliance and Technology Transfer (Medical Center).

9.1.2. F&A Cost Sharing

“F&A-cost sharing” occurs any time the University agrees to recover less than the current federally negotiated F&A rate. This requires the approval of the Vice President for Research (University exclusive of the Medical Center) or the Associate Vice President for Health Research, Compliance and Technology Transfer (Medical Center).

9.1.3. Cost Sharing Goal

Both direct-cost and F&A-cost cost sharing represent real costs to the University. The true costs of doing research include more than the direct costs requested in the proposal for staff time, equipment, and other resources to directly support the work. The true costs of research include the University's investment in a very large and expensive infrastructure without which the research could not be done. GW’s goal as a university is to have outside sponsors pay full direct and F&A costs, so that the cost of research is borne by the sponsor and not by units within the University. Consequently, decisions about cost sharing require careful consideration well in advance of proposal submission.  For copies of the relevant forms for obtaining cost sharing approval, please refer to Appendix E.


9.2. TYPES OF COST SHARING COMMITMENTS

Cost Sharing may be mandatory, voluntarily committed or voluntarily uncommitted.

9.2.1. Mandatory Cost Sharing

“Mandatory Cost Sharing” is a firm requirement documented in writing from the sponsor for cost sharing outlined and required by legislation or the funding agency in order to receive funds. An example would be unrecovered indirect costs if the sponsor imposes an F&A cap that is lower than GW’s actual F&A indirect rate.

9.2.2. Voluntary Committed Cost Sharing

“Voluntary Committed Cost Sharing” is not required, but offered by the applicant to further demonstrate the institution’s dedication to the program. This becomes a binding commitment to the funding agency and part of the award’s terms and conditions. Examples of Voluntary Committed Cost Sharing include unfunded program staff time and unfunded changes to scope of work that are performed.

9.2.3. Voluntary Uncommitted Cost Sharing

“Voluntary Uncommitted Cost Sharing” represents unexpected program expenses that were necessary to complete the program’s work (cost overruns). Voluntary Uncommitted Cost Sharing may involve time and effort beyond the proposed budget, supplying more program materials that are needed, or extra participant fees due to replacing lost study subjects.

Mandatory and Committed Cost Sharing must be disclosed during the OVPR proposal review process by utilizing GWU’s Cost Sharing and Facilities Approval form http://www.gwu.edu/~research/preforms.htm.  This form should indicate the specific organization for direct cost sharing and contain the appropriate departmental/school signatures.

9.3. COMMITTING TO COST SHARING

Committing to direct-cost cost sharing means being willing to provide the resources promised. The commitment made by a department, school, or other unit must be detailed on the proposal's routing sheet. This dollar amount will be shown in the proposal budget, as well as in the final accounting for the program. Moreover, it will be treated as a real cost of doing research when the year-end accounts for the schools are prepared. The investigator should promise only what he, his department, and his school can deliver, and he should not promise more than is necessary to meet a sponsor's requirements.

It is sometimes possible for an investigator to convey institutional commitment to a research program without specifying a dollar amount of direct-cost cost sharing. In the body of a proposal (but not in the budget), for example, the investigator might state that a technician will be available on an as-needed basis to help train graduate students to use a piece of equipment and to keep the equipment in working order, or that a professor with stellar credentials will be available to consult periodically at no cost to the program. The message is that the University has resources that can benefit the program. This sort of informal, non-quantified cost sharing will not satisfy a sponsor who requires that a certain percentage of a program's direct costs be borne by the University. It should not be presented in this way when University resources will definitely be committed to a specific program in quantifiable amounts and formal direct-cost cost sharing is, therefore, appropriate. If this strategy is employed, be sure to point out relevant passages in the text to the RSC before the proposal is reviewed.

9.3.1. Tuition Cost Sharing (University, exclusive of Medical Center)

The University has a limited amount of tuition award money that it can use to support students who receive stipends connected with grants or contracts; some schools are also able to cost share tuition for stipend students. Before tuition cost sharing is considered, however, it should be determined whether the sponsor is open to supporting all or part of the needed tuition costs. Consult the instructions for preparing applications or call the appropriate program officer. Only when the sponsor will not pay tuition costs should the University be asked to do so.
The dean should review the school's available graduate student support funds and agree to cost share using those funds if the proposal warrants it. If the request is supported but department and/or school funds are not sufficient, the dean should forward the request for tuition cost sharing and his/her endorsement of it to the Director, Office of Graduate Student Assistantships and Fellowships. The Director, in consultation with the Vice President for Research, considers and may approve requests for tuition cost sharing within the constraints of the budget for this purpose. Among the criteria considered are: the merits of the proposal, the extent to which it is supported by the department and school and viewed as integral to their strategic plans, the extent to which tuition awards have already been committed to the same investigator or department, and the extent to which such support can help build the University's research capacity.

9.3.2. Equipment Cost Sharing

 When an investigator writes a grant proposal to acquire a major piece of equipment, it is not unusual for the sponsor to require institutional cost sharing. The investigator should discuss this, first with the department chair to determine where the equipment request falls in the department's priorities in terms of its value both to research and to teaching efforts, and then to determine whether the department will contribute to cost sharing and, if so, how much. The department chair then consults with the dean's office regarding the availability of school funds. The dean may, in turn, consult with the Vice President for Research, or, for the Medical Center, the Associate Vice President for Health Research, Compliance and Technology Transfer, to determine the feasibility of contributing institutional funds toward the amount to be cost shared. The University has a limited pool of money for this purpose. As with tuition cost sharing, it must verify that the money is committed wisely to support research central to department, school, and University priorities. The investigator should write a clear justification for the cost sharing request that points out any benefits that the equipment might have beyond the benefits to the proposer's own research effort. Again, cost sharing of this sort is real money, and it may not be possible to support all requests. 

9.3.3. F&A-Cost Cost Sharing

As noted above, Facilities and Administrative costs are real costs of doing research. Research needs to be housed in offices and laboratories, it needs the support of libraries and offices to administer grants and contracts, and it uses utilities and other University resources. F&A costs are calculated every few years when the University negotiates its F&A rate with the federal government. Typically, the negotiation leads to a lower rate than the University requests, meaning that the University is already inadequately reimbursed for its real costs, even when it receives the full, negotiated F&A rate. GW's policy is not to give up any portion of the full, allowable F&A rate unless there is no alternative or an extremely compelling reason. Decisions to approve F&A-cost cost sharing are made by the Vice President for Research or, for the Medical Center, the Associate Vice President for Health Research, Compliance and Technology Transfer. Any such requests must be fully justified.
There is no choice but to sacrifice F&A costs with certain foundations and sponsors who have explicit policies that preclude their paying full F&A. OVPR requires a written statement from the sponsor to this effect to certify that the F&A-cost cost sharing is mandatory. If no written statement can be found in the guidelines, consult the RSC to determine what form certification might take.