Proposal Routing

The below resources and information are provided as a guide for faculty, staff, and students in the preparation of external proposals.

When developing proposal materials, consider your audience: it is not only the scientific review committee at the funding agency but your Chair/Director, Dean, Office of Research Administration, the research administrators at the sponsoring agency, Maryland's various post-award offices (including travel, purchasing, Sponsored Projects Accounting and Compliance), and eventually an auditor.

See: ORA's Tips For A Successful Submission

Proposal Development Services

The BSOS Research Team can help faculty develop external grant proposals with a range of activities. Please visit our Proposal Development Services webpage for more information.

What Gets Routed

Accompanying each proposal should be a memo outlining any anomalies in the solicitation or proposal, any unusual form or signature requirements, submission requirements, etc. Anything one might put in an email to the Chair/Director, Dean's Office, or ORA regarding the proposal's content or submission should instead go into this routing memo and be uploaded in Kuali Research (KR). This document is for internal University use only and will not be shared with the sponsor.

Proposals should be uploaded into KR, certified, and submitted for routing no later than six (6) business days prior to the sponsor's due date. If a solicitation requires the recipient institution to have 501(c)(3) tax-exempt status, the University System of Maryland Foundation (USMF) may agree to be named as the awardee and set up a grant-back account to us when the award comes in. The USMF requires five (5) additional business days' notice of a completed proposal; this is in addition to ORA's 6 days as proposals pass through ORA before going to the Foundation.

The items which must be finalized at the time of routing are:

• routing memo (a sample/template routing memo can be found here)
• budget and budget narrative
• subaward documentation (including budget, budget narrative, letter of commitment signed by an institutional authorized official)
• cost-sharing documentation (including identifying the source of funds)
• indirect cost waivers
• significant project designation requests
• Conflict of Interest training documentation
• for non-funded agreements: a scope of work created by the PI to provide ORA with a basic understanding of the related activities

Other items that should be included in the routing package include:

• funding opportunity announcement
• price quotations for equipment or sole-source contracts
• internal forms that need review and signature by the Dean's Office (e.g. IDC waiver request, universal funding form for cost share, DRIF change, Significant Project request, etc)
• sponsor forms that require signature by ORA (SF424 forms, etc)
• a preview of the entire application in the sponsor grant submission system (it is okay to have a draft at the time of routing but ORA needs a final version at their review point)

NOTE: Scientific content need not be finalized to route a proposal within the University.

Pre-proposals must be routed through the standard process if any of the criteria below are met:

• A detailed budget (that would serve as the basis for an award) is required
• Cost share is required or proposed
• The budget requires institutional approval of a reduced or waived F&A rate
• The pre-proposal must be submitted or signed by an authorized official of the University
• The pre-proposal is being submitted to a corporate entity
• There are known restrictions on intellectual property ownership or publication rights

Why Route?

The routing process allows for several layers of scientific and administrative review throughout the university. Each office that reviews a proposal focuses on different items. A Chair/Director will likely focus on the project description and scientific merit of a proposal, but also look to see if any departmental/center resources are being promised. The Director of Administrative Services in a department may look at the budget and budget narrative to ensure they match and reflect the scope of work. The Dean's Office reviews proposals (specifically budgets, budget narratives, subaward documentation, cost sharing documentation, indirect cost waivers, etc.) to ensure compliance with the State and University rules and regulations regarding allowable and reasonable costs. Finally, ORA reviews proposals to ensure all of the above have been reviewed and adjusted where necessary, but also that the proposal conforms to sponsor guidelines and specifications of the RFP/solicitation. The earlier a proposal can be routed through this system, the deeper a review each step in the process can give to a proposal. As the volume of proposals sponsors receive increases and their tolerance for administrative errors decreases, this routing and review process becomes increasingly more valuable to an investigator.

Who can be a Principal Investigator?

Investigator Certification

Principal investigators and Co-investigators must complete a certification on every proposal submitted on which they are named. The certification is 9-11 questions relating to research conduct and oversight which only the investigators can answer as responsible stewards of the research. As such, this certification cannot be delegated to another individual. First-time investigators take on average about two to four minutes to certify. The certification can be completed using the browser of your choice on any computer or mobile device. Certification can be completed at any time during the proposal development process. For more information on how to certify a KR proposal and what the certifications mean with links to relevant policies please visit the BSOS KR Resources webpage.

Credit Split

Each proposal must designate a split of the credit to investigators and departments. Currently, credit split drives indirect cost return (aka DRIF return). Credit splits can be determined by any reasonable method. The two most common methods are via direct cost dollars and via time or scientific contribution of the faculty named on a proposal. Some on-campus Institutes and Centers may have internal guidelines for determining credit split based on the amount of administrative work involved in the proposal and subsequent award.

Conflict of Interest (COI) is a legal term that encompasses a wide spectrum of behaviors or actions involving personal gain or financial interest. Under University policy, the term "conflict of interest" denotes situations in which a member of the University community is in a position to gain personal benefit (broadly construed) or financial advantage arising from their University position, either through outside professional activities or through their actions or decisions at the University, including research, administrative, or educational activities. Because University employees are also State employees, the Maryland State Ethics Law governing conflict of interest also applies.

Conflicts of interest are not necessarily negative, nor do they all require management plans. Many times all that is needed to protect the investigator and the University is the disclosure of ownership/equity in a company. In order to ensure all Investigators are aware of their responsibilities and potential liability, BSOS has enacted certain COI requirements for research proposals.

COI Requirements for proposals routing through BSOS:

Principal Investigators, Co-Investigators, and key personnel submitting proposals through BSOS must have completed two tasks related to Conflict of Interest (COI) disclosure and mitigation. This requirement applies to all investigators: including students who are Co-Investigators and individuals from other colleges within UMD if a BSOS department or center is the lead unit.

• The first requirement is that all PIs and Co-Is must complete the CITI Program’s COI module and, upon completion, upload their certificate of completion at the link below so the Dean’s Office has the certificate on file. The certificate is valid for 4 years. If you are already certified there is no need to retake the course until your certification expires, simply upload your certificate to the Dean’s Office portal. More information on CITI is below.

UPLOAD YOUR CITI CERTIFICATE OF COMPLETION HERE

• The second requirement is that all PIs and Co-Is must read the UMD Policy and Procedures on COI and initial at the marked spaces in the policy. The initials are being collected via Adobe Sign so once this is completed and submitted there is no other action necessary.

READ AND SIGN THE COI POLICY HERE

If at any point during this process you have questions, please contact Meredith Kleykamp or Rebecca Hunsaker. For more information about Conflicts of Interest, including disclosure forms, please visit the VPR’s website on Conflict of Interest.

The BSOS Dean’s Office will not route proposals to ORA unless and until all Investigators have completed these steps.

For investigators on proposals to PHS agencies (which includes NIH and CDC), NASA, and the NSF a disclosure is also required. This is a Federal requirement, not a campus or BSOS requirement. A disclosure must be filed whether or not there is anything to disclose. For more information on how to complete this disclosure, see the COI website. If a disclosure is not filed at the time of proposal, the award set-up can be delayed while a disclosure is reviewed and adjudicated. NASA is likely going to implement a similar requirement with their next NASA Grant and Cooperative Agreement Manual (GCAM) which comes out in November 2023.

Per the COI Committee FAQs, the COI Committee typically meets the 2nd Wednesday of the month. Disclosures must be completed and routed to the COI office by the first of the month for inclusion in that month's agenda. (This includes review/approval by the Dean's Office.)

In November 2021, BSOS hosted a forum on Conflicts of Interest presented by members of the Office of the Vice President for Research compliance offices and members of the BSOS Dean's Office. You can watch that forum here. The video is available to anyone at UMD. Undergraduate students may request access but should do so using their @terpmail.umd.edu address so it is clear they are UMD students.

CITI Program Information:

1. Go to the main CITI website at: https://about.citiprogram.org
2. Click "Log In" in the upper right corner.
3. Choose "Log In Through My Organization," and begin typing "University of Maryland" in the text box. Choose "University of Maryland College Park" from the resulting drop-down menu option. Click "Continue to SSO Login / Instructions." This will prompt the CAS Login screen and the University Multi-Factor Authentication.
4. Click "View Courses."
5. If you do not have the Conflict of Interest Mini Course in your course list, scroll to the bottom of the page and click "add a course." To access the COI Mini Course answer "yes" to question 5. For other questions, answer at your discretion based on your situation and interest in other courses. This will load the COI mini course, which has three modules you need to successfully complete.
6. Upon completion of the COI mini course you will need to download your certificate and upload per the instructions above. To access and save your CITI certificates log in to your CITI Program account and click “My Records.” You will see a print option next to completed courses, which you can click to download a completion report as a .pdf file.
7. Instructions for navigating CITI are here (https://support.citiprogram.org/s/article/updated-guide-to-getting-started?r=123&ui-knowledge-components-aura-actions.KnowledgeArticleVersionCreateDraftFromOnlineAction.createDraftFromOnlineArticle=1#Affiliations)

Dealing with Salary Limitations

A salary cap is a maximum rate of UM salary for full-time effort that can be charged to a sponsored award.

The salary cap is not on the number of dollars that can be charged to a sponsored project. Rather, the cap is on the rate of pay that can be charged to a sponsored project. For example, the 2021 PHS salary cap for 12 months is $199,300. For personnel whose annualized salary is greater than $199,300 we can charge the grant for their (level of effort) x (the salary cap). NOTE: If current funding was awarded prior to the effective date of a salary cap, the unit must use the rate in effect on the issue date of the current funds. When the next year of funding comes in the new cap can be applied at that time if there are funds available in the budget to do so.

The balance of funds not covered by the sponsored project [(level of effort) x (actual annualized salary)] - [(level of effort) x (the salary cap)] is the responsibility of the department. The department should work with their Sponsored Projects Accounting and Compliance (SPAC) accountant to have a cap account created and linked to the sponsored account.

Below are some sample calculations based on the PHS rate to show how this could affect a department.

12-month faculty

9-month faculty

Summer Salary

Note that in all these scenarios, where the faculty member's base annualized salary exceeds the cap, there is an amount over the cap regardless of level of effort. A department cannot lower an individual's level of effort to get under a certain dollar threshold as it is the rate of pay, not the amount, which is governed by salary limitations.

Federal Agencies with Salary Caps:

• Federal Trade Commission
• Public Health Service (which includes CDC, HRSA, NIH, SAMHSA, FDA, and others)
• National Institute of Justice
• United States Agency for International Development (USAID)
• National Park Service

Salary caps are not limited to federal sponsors, either. Below are some non-federal agencies with salary limitations:

• American Institute for Cancer Research
• Michael J. Fox Foundation
• Patient-Centered Outcomes Research Institute (PCORI)
• Susan G. Komen Foundation

Current NIH Salary Cap information can be found here.

General Guidelines and Recommendations

National Institutes of Health:

• Modular: keep in mind the legislatively mandated salary cap when calculating your budget. When preparing a modular budget (NIH only), you are instructed to use the current cap when determining the appropriate number of modules.
• Detailed: "NIH will not pay requested salary above the annual salary cap. If salary is requested above the salary cap, NIH will reduce that line item to the salary cap, resulting in a reduced total award amount. In future years, if the salary cap increases, recipients may rebudget to pay investigator salaries up to the new salary cap, but NIH will not increase the total award amount,. If you are preparing a detailed budget, you are instructed to base your request on actual institutional base salaries (not the cap) so that NIH staff has the most current information in hand at the time of award and can apply the appropriate salary cap at that time."
• Understanding the Out Years: "We do not expect your budget to predict perfectly how you will spend your money five years down the road. However, we do expect a reasonable approximation of what you intend to spend."
  • Note: This is the language BSOS leans on to justify budgeting the same base salary each year of the NIH grant by using a figure that is equal to the average anticipated base salary during the entire performance period. By using the same base salary each year, we minimize the risk of an award reduction for salary escalation.

Department of Justice (notably National Institutes of Justice and Office of Justice Programs):

• DOJ grant funds may not be used to pay cash compensation (salary plus bonuses) to any employee at a rate that exceeds 110% of the annual maximum salary payable to a member of the Federal Government's Senior Executive Service (SES) at an agency with a Certified SES Performance Appraisal System for that year.
• SES rates can be found on the OPM website.
• For OJP awards specifically: the Assistant Attorney General for OJP may waive this limitation. We must include in the proposal a waiver request to the limitation including a detailed justification in the budget narrative including the particular qualifications and expertise of the individual, the uniqueness of the service the individual will provide, their specific knowledge of the program or project being undertaken, and a statement explaining that the individual's salary is commensurate with the regular and customary rate for an individual with their qualifications and expertise, and for the work to be done.