Sponsored Projects Office Institutional Review of Proposals

Overview

All proposals received by the Sponsored Projects Office (SPO) on or after September 1, 2019 will receive an “institutional review.” This means that SPO Contract and Grant Officers (CGOs) will review proposals only for “institutional issues” that could create financial, audit, and/or policy risks for the University. CGOs will no longer review the technical or administrative sections of proposals for compliance with sponsor’s requirements. See the specific listing below. The Vice Chancellor for Research (VCR) has determined that this approach to proposal review is needed to allow SPO staff more time for award negotiation and set up and to enable campus Principal Investigators (PIs) to access their awarded funds sooner.

Proposal components not reviewed by SPO:

• The PI’s eligibility for the funding program.
• The PI’s “Exceptional PI Status” approval.
• The accuracy of what the PI has listed/described as “current and pending” support.
• The accuracy of the amounts calculated in the budget for anything other than F&A.
• Noting problems with the appearance, format, order, and content of the technical or administrative sections of the proposal.
• Noting grammar, spelling, numbering, and typo errors.
• Determining whether an outside entity should be treated as a subrecipient or a contractor/vendor.
• Ensuring that all attachments required by the sponsor have been included/submitted.
• Fixing any major submission errors prior to submitting the proposal to the sponsor.
• Obtaining late proposal approval from the VCR for the PI.

If you have any questions or comments about how these procedures will be implemented, SPO’s role in the proposal review process, and/or the FAQs provided below, please use the Institutional Proposal Review Feedback Form.

An overview of the specific proposal elements that are included in an institutional review is below.

Faculty, postdoctoral scholars, staff, and students who plan to submit proposals to non-profit and government sponsors will be subject to the following requirements if the proposal is received by SPO on or after September 1, 2019:

1. PIs who want their assigned Berkeley Regional Services (BRS) Research Administrator (RA) to review and assist with the administrative components of his/her proposal must submit the proposal with a final administrative section and a draft technical section to their assigned BRS RA no later than seven (7) working days before the sponsor’s deadline.
   
   The BRS RA then will review and assist with the administrative components of all proposals submitted by this internal deadline and use sponsor validation software (when available) to help the PI identify/correct any submission errors prior to submission to SPO. The PI will be responsible for preparing all required elements of the technical section of the proposal according to the guidelines from the sponsor. The BRS RAs will not be reviewing the technical sections of the proposal. Proposals submitted to the BRS RA less than seven (7) working days before the sponsor’s deadline will be submitted by the BRS RA to SPO “as is.”
   
   Note: Departments and units not currently receiving research administrative services from Berkeley Regional Services may impose the same or different internal proposal review deadlines. See FAQ #3 below for additional guidance.
   
   
2. The PI is required to submit a draft technical section and a final administrative section of his/her proposal to SPO no later than four (4) working days prior to the sponsor’s or target deadline. (This is a day later than required under past VCR policy.) At minimum the proposal must include:
   
   
   1. All of the currently listed minimum required fields to save and submit the proposal in Phoebe.
   2. A budget in the sponsor’s format or an internal budget with all institutional rates displayed, each subrecipient’s total costs listed, and any proposed cost sharing included.
   3. A draft of Berkeley’s SOW (must be clearly identified if part of a larger project).
   4. Required proposal forms (filled out) that contain University identifying information and/or require SPO signature.
      
      
   SPO then will conduct a review of the institutional elements (see below) of on-time proposals and check for submission errors using sponsor validation software (when available). SPO will no longer review the technical and administrative sections of the proposal for compliance with sponsor requirements. SPO’s comments addressing any identified institutional issues will be provided to the PI and BRS RA within two (2) working days. Proposals submitted to SPO after the four (4) day internal submission deadline will be processed as “late” proposals as specified under the VCR policy.
   
   
3. As required under VCR policy, the final version of the proposal (with final technical section and final administrative section) should be submitted to SPO no later than eight (8) business hours before the sponsor’s (or target) deadline.
   
   SPO then will recheck the proposal to ensure SPO’s previous institutional comments have been addressed and identify any remaining submission errors using sponsor validation software (when available.) Proposals with institutional issues and/or submission errors will be referred back to the PI and the BRS RA for correction. SPO will submit the proposal to the sponsor after all institutional issues and/or submission errors have been addressed. Proposals submitted to SPO after the eight (8) hour internal submission deadline will be treated as “late” proposals and processed as specified under the VCR policy.

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Frequently Asked Questions

Question 1: Won’t the Institutional Proposal Review have a negative impact on Berkeley’s proposal submissions and success?

This model has been used successfully by sister campus, UC Irvine, for several years. During this time, proposal numbers and funding at UCI actually increased. Although the transition to the new model was initially a challenge for some, UCI reports that only a few proposals were not accepted for review in the early days of implementation.

Question 2: Without SPO’s “second pair of eyes” reviewing the sponsor’s proposal requirements, won’t there be more submission errors leading to the rejection of Berkeley proposals?

Over the last few years, federal sponsors have made error checking software available to PIs. Federal proposals prepared in Workspace (Grants.gov), ASSIST (NIH), FastLane/Research.gov (NSF) and others federal submission systems now generate error reports so that critical submission problems can be corrected before the proposal is routed to the sponsor. It is now possible for PIs and RAs to find and correct any fatal submission errors without SPO’s assistance. This improvement allows SPO CGOs more time for the time consuming process of award negotiation and set up—a long-term pain point for the campus.

Question 3: Can you provide an overview of how the proposal submission process will work?

A visual overview of the new proposal review process is provided below:

Question 4: What happens if a proposal does not meet the seven (7) day internal BRS RA deadline described above?

BRS RAs cannot guarantee that a proposal will be reviewed. Such proposals will be submitted to SPO at the 4 day deadline “as-is.” The PI will be solely responsible for ensuring that the draft technical and final administrative sections of the proposal adhere to the sponsor’s guidelines.

Question 5: What if my department/unit is not served by Berkeley Regional Services; will the BRS and SPO internal deadlines apply to my proposals?

Departments and units not currently receiving research administrative services from Berkeley Regional Services may impose the same or different internal proposal review deadlines and processes. PIs in these units are encouraged to discuss the department/unit’s requirements for proposal review before undertaking a proposal that will be submitted through SPO. Note that SPO’s internal deadlines and institutional review process will be same for all proposals submitted through SPO.

Question 6: What happens if a proposal is submitted by the BRS RA to SPO “as is” by the four (4) day deadline?

SPO will return the proposal to the PI and the BRS RA without review if the proposal does not contain a draft technical section and a final administrative section with sufficient information for an institutional review.. At minimum this should include:

1. All of the currently listed minimum required fields to save and submit the proposal in Phoebe.
2. A budget in the sponsor’s format or an internal budget with all institutional rates displayed, each subrecipient’s total costs listed, and any proposed cost sharing included.
3. A draft of Berkeley’s SOW (must be clearly identified if part of a larger project).
4. Required proposal forms (filled out) that contain University identifying information and/or require SPO signature.

If the proposal is accepted for review by SPO, SPO will review the institutional elements of the proposal and check for submission errors using sponsor validation software (when available). SPO’s comments addressing any identified institutional issues will be provided to the PI and BRS RA within two working days. SPO will not review the administrative or technical sections of the proposal for compliance with sponsor requirements.

Question 7: Will the VCR’s late proposal policy change?

A proposal will be considered “late” if a draft technical section and a final administrative section with sufficient information for SPO to conduct its institutional review is not submitted to SPO at least four (4) days before the sponsor’s deadline. (See Question #6 above to see the minimum required for an institutional review). The proposal also will be considered late if the final version of the proposal is not submitted to SPO at least eight (8) business hours before the sponsor’s deadline.

For such situations SPO will follow VCR policy related to “late” proposals: Late proposals will be reviewed for institutional issues only and submitted to the sponsor “as is” but only after any institutional issues have been corrected and after all other proposals due on the same day are submitted. Submission errors for late proposals will be addressed by SPO only if time permits.

Question 8: Do the internal deadlines for BRS and SPO apply to all proposals submitted through SPO?

PIs should contact the BRS RA and SPO CGO assigned to their unit at least three (3) weeks before the proposal is due to discuss alternative review/submission procedures and timelines for proposals with any of the following characteristics:

• The proposal guidelines indicate that submission of the proposal will commit the University to specific award terms and conditions.
• The proposal includes direct costs of over $10M per year or the RFP/RFA notes other requirements requiring UCOP review (e.g. publication approval, citizenship restrictions)
• The proposal requirements are significantly complex and/or involve multiple institutions and/or involve multi- or inter-disciplinary efforts.

Question 9: Can a PI submit a proposal to SPO earlier than the internal deadlines listed to accommodate the PI’s schedule?

Yes. This new model will allow SPO to provide comments addressing any identified institutional issues within two working days after the proposal is received in acceptable form by SPO. SPO will approve/submit the proposal to the sponsor after receiving the final version of the proposal with no remaining institutional issues or submission errors.

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Overview of Institutional Proposal Review by SPO

SPO Contract and Grant Officers will perform an institutional review of all proposals to government and non-profit sponsors submitted and/or approved by SPO on or after September 1, 2019. CGOs performing an institutional review will:

1. Review institutional eligibility requirements and ensure all identifying proposal information provided about UC Berkeley, Sponsored Projects Office, and/or The Regents is required, accurate, and/or correct
   
   Rationale for Institutional Review: SPO is required to make legal attestations, certifications, representations and assurances on behalf of The Regents. Inaccuracies and errors may result in legal, financial misunderstandings or other risks in the award stage. For example, award agreements or checks for payment may get lost in the mail if a wrong address was listed in an award. Also, awards could be questioned or possibly recalled if material facts about our organization are misrepresented at the proposal stage.
   
   
2. Review all items requiringSpecial Review (usually requiring additional layers of compliance) in the Phoebe Proposal record for completion, including human subjects, animal subjects, conflict of interest, export control, background IP, exceptional PI status, etc.
   
   To ensure compliance with federal and/or other sponsor’s policies related to various aspects of research administration, it is important that all items requiring further review and approval by other offices within RAC are identified at the proposal stage. In our Institutional Review, SPO CGOs will review the proposal to ensure that any items requiring further review by a University office are flagged for the appropriate office to insure compliance with Federal and State regulations and University policies governing these areas.
   Rationale for Institutional Review: As a reminder, it is the PI’s responsibility to ensure that the information provided is accurate. Proposals that are submitted with incorrect or incomplete information in these sections of the Phoebe record are likely to be delayed at the award stage as the components identified in these sections require further review and approval by a separate office within Research Administration and Compliance (RAC).
   
   
3. Confirm that the appropriate F&A cost base and other UC rates have been applied
   
   SPO will review the proposal budget for the use of the appropriate F&A cost base, F&A rate, and fringe benefit rates and will provide comments and/or corrections to the proposing team. As part of the Institutional Review, SPO’s responsibility will be to assess any associated financial risks to the University should the F&A rate deviate from the campus’ current federally negotiated F&A rate. If the sponsor does not require a detailed the budget at the proposal stage, the proposal may be submitted without a detailed budget. However, SPO will require an internal budget with enough detail to confirm that the F&A and fringe rates will be applied appropriately should the project be funded. SPO will require the responsible Berkeley Regional Services Research Administrator to correct any errors and/or obtain and upload to Phoebe appropriate justification (e.g., sponsor policy) for deviations to the campus’ federally negotiated F&A rate.
   Rationale for Institutional Review: Proposals that are submitted with the incorrect bases and/or rates may result in a financial loss to the University and any unrecovered costs may affect the livelihood of the project and the ability for the Principal Investigator to conduct the research.
   
   
4. Ensure specific University costs are applied as required
   
   Proposals usually include a budget, a detailed breakdown of the financial support requested from the sponsoring agency in accordance with sponsor policy. Budgeting for project needs is the responsibility of the PI with the assistance of the Berkeley Regional Services Research Administrator assigned to his/her unit. SPO will review budget proposals for inclusion of appropriate University-mandated costs such as GAEL and UCRP.
   Rationale for Institutional Review: Failure to include appropriate University-mandated costs may result in funding deficits or an inability to carry out the project. Deficits will be cleared by the campus deficit reduction policy and this can impact department/unit/college resources.
   
   
5. Review budgeted costs for consistency with campus and federal cost principles
   
   SPO will review the proposal budget for compliance with the guideline set out in the OMB Uniform Guidance; it is given consistent treatment with policies and procedures that apply uniformly to both federally-financed and University activities; and it conforms to any limitations or exclusions included in the terms and conditions of the award.
   Rational for Institutional Review: Grants and contracts awarded by the federal government to UC Berkeley are subject and mandated to follow federal government administrative requirements, cost principles, and audit requirements. SPO CGOs will provide review comments if the budgeted expenses are not allowable costs or outside of the federal requirements.
   
   
6. Verify that there is appropriate documentation of any committed/in-kind University or third-party cost sharing
   
   SPO will review any proposed cost sharing to determine that it is required by the sponsor and allowable. Committed cost sharing in a proposal represents a binding commitment by the University at the award stage and, as such, is subject to audit under federal and other sponsor regulations. SPO will comment if acceptable cost sharing documentation is not included with a proposal submission.
   Rationale for Institutional Review: Unverified cost share commitments represent a potential financial liability for the University. If the pledged cost share is not met, it may result in a loss of agency funding and/or impact department/unit/college resources and funding. Any quantifiable share cost offered in the proposal to a non-federal agency also may become a legally binding and accountable commitment of the University upon award.
   
   
7. Ensure all required internal documents have been included in the Phoebe record
   
   SPO CGOs will review proposals to ensure that all internal documents as required by federal and state law are included and will provide comments to the proposing team. Internal documents include but are not limited to: Conflict of Interest forms, NASA Access Restriction Checklist, NIH NRSA Fellowship Assurance Certification, NSF Certification Page (signed by appropriate AOR), Subrecipient Commitment Form, and Fair and Reasonable Cost Analysis and Sole Source Justification (for Federal Contract proposals).
   Rationale for Institutional Review: Failure to comply with federal and state law can result in a reduction of agency funding and this can impact department/unit/college resources.
   
   
8. Determine if anything in the sponsor’s guidelines or award terms would prevent submission of the proposal or acceptance of an award if the proposal is funded
   
   SPO will review the sponsor’s guidelines or award terms and will notify the proposing team if any guidelines or award terms will prevent submission of the proposal.
   Rationale for Institutional Review:The University cannot accept any award terms that conflict with or violate University Policy and undermine the University’s free and open academic environment or restrict the PI’s right to publish, develop and license intellectual property, and/or choose personnel to work on the project without citizenship restrictions.
   
   
9. Review of any terms, conditions or commitments at the proposal stage that obligate the University (financially, programmatically, or otherwise) at the award stage
   
   SPO will review the proposal for terms, conditions, or commitments that obligate the University beyond the technical scope of work included in the proposal and provide guidance or language to navigate the situation. This may require SPO to request appropriate informed consent from the Key Personnel and the Department to proceed with proposal submission. This would also include contractual language embedded in the proposal document(s)
   Rationale for Institutional Review: If a proposal is funded, failure to provide what is promised in the proposal may result in a reduction of agency funding, and this can impact department/unit/college resources. Failure to address terms or commitments that obligate the University at the proposal stage may result in a violation of University policy, California State Law, or what is in the long term best interest of the University.
   
   
10. Review and signature of certifications, assurances and representations
    
    SPO will review the certifications, assurances and representations, and secure documents that require SPO Authorized Official signature.
    Rationale for Institutional Review: SPO Authorized Officials are responsible for making certain institutional representations, and certifications when signing funding applications/proposals. By approving a proposal for submission, the University is acknowledging that any false, fictitious, or fraudulent statements or claims may result in criminal, civil or administrative penalties for the person(s) signing the proposal, as well as the University.
    
    
11. Communicating issues and concerns identified during the Institutional Review
    
    SPO will communicate any issues or concerns to the proposing team on an as needed basis and at the discretion of the SPO CGO. These comments will primarily focus on anomalies or areas other outside factors that may jeopardize the proposal submission.
    Rationale for Institutional Review: Not all proposals are created equal. Thus, SPO may be required (at the SPO CGO’s discretion) to address risk issues or anomalies not specifically described in this document as the core elements of a standard Institutional Review, but reside within the proposal or proposal submission instructions.
    
    
12. Approve/successfully submit proposals on behalf of The Regents
    
    As Authorized Organization Representatives of The Regents, SPO will submit proposal documents on behalf of the University. In certain cases, where there is flexibility in the submission process, SPO will provide submission guidance to the proposing team.
    Rationale for Institutional Review: Only SPO has the authority to submit proposals on behalf of the University or the authority approve a designee (e.g., PI) to submit based on specific Sponsor requirements (e.g. electronic submission portals).