Frequently Asked Questions 

Proposal Submission Deadline Policy

To submit the most successful proposals for all OSU Researchers, internal deadlines are required to manage increasingly complex sponsor submission processes. The current 3-day deadline is frequently breached and not enforced. Last minute proposals submitted “as-is” are no longer tenable because:

1. Fragmented Sponsor submission portals include more dual factor authentication and error checks that require significant time for submission even if OSRAA proposal analysts attempt to limit their review.

2. Rush submissions negatively impact timely submitted proposals because they prevent workload balancing and planning. Rush proposals create a crisis for the OSRAA proposal analyst team that prevents other proposals and initiatives from being properly addressed.

3. Proposals that could have been successful if more time was available to properly review and submit are being rejected without review by sponsor agencies.

4. Increased compliance requirements that require review by various departments at time of proposal submission require OSRAA proposal analyst team coordination with other offices that cannot be timely completed for a rush proposal.

Enforcement of the Policy will be delayed until communication and education efforts can be completed.

From July 1, 2023 until October 31, 2023 the RO will engage in efforts to disseminate the new policy to the OSU research community.

Starting November 1, 2023, the policy enforcement mechanism will to be implemented. OSRAA will continue to attempt to review and submit all proposals but late proposals will not be reviewed until timely submitted proposals are reviewed.

1. Notification of policy violation will be sent to ADR’s/unit leadership. Repeat violations of policy by individual PI’s may result in additional steps through a performance improvement plan.

2. Proposals violating this policy will be tracked for periodic review.

The Draft Proposal must be received by OSRAA at least five (5) full business days (excluding weekends and holidays) prior to the Sponsor Submission Deadline. For example, if the Sponsor Submission Deadline is 2:00 PM on Friday May 12th, then the application should arrive in OSRAA on or before 2:00 PM on Friday May 5th. If there is a university holiday, then the deadlines are pushed back to allow for the same number of business days/hours. This means that proposals must be routed in Cayuse with sufficient time for Cayuse Departmental Review to be completed prior to the 5-day deadline. Also, any changes to the Draft Proposal (except for the technical narrative/scope of work) after Cayuse routing starts should be only at the direction of the Cayuse reviewers. The Final Proposal must be received by OSRAA at least twenty-four (24) hours (excluding weekends and university holidays) prior to the Sponsor Submission Deadline. For example, if the Sponsor Submission Deadline is 2:00 PM on Friday May 12th, then the final proposal should be ready for review on or before 2:00 PM on Thursday May 11th. If there is a university holiday, then the deadlines are pushed back to allow for the same number of business days/hours. If the Sponsor Submission Deadline is after 5 PM PT, OSRAA will submit the proposal during business hours and no later than 5 PM PT.

OSRAA requires the Draft Proposal with 5 full business days for review. OSRAA expects the department to complete its required approvals, forms, etc. prior to routing.

Not necessarily. OSRAA will submit the application as soon as it is ready to be submitted. Sometimes that will be earlier in the day on the submission deadline, in other instances, depending on the number of changes necessary, the application may not be submitted until the final hours prior to submission deadline.

The submitter should mark the due date as 5 full business days ahead of the date it arrives in OSRAA and note the deadline as “Soft”.

There are no exceptions to the policy. Proposals that are large or complex may require additional time for successful review and submission.

This data is periodically reviewed by university officials to identify trends in late proposal submissions. As trends are identified, OSRAA works with RO and department leadership to find solutions to better serve the university research community.

• Cayuse SP record and paired 424 (when applicable)

• Final OSU budget and justification

• All final subaward/contractor/consultant paperwork

• All final biosketches/CVs

• Final current and pending support or other support documentation 

• Any documents/forms requiring institutional signatures 

• Approved F&A waiver forms

• Approved internal cost share and third-party cost share letters 

• Proposal announcement guidelines or URL

• The draft technical narrative/scope of work

• Final Technical/narrative documents

• All documents in the Draft Proposal

• All other required submission documents ready for submission to sponsor that are not listed in the Draft Proposal definition.

Decisions on F&A waiver requests are expected to be made before a draft proposal is submitted for routing. For forms and procedures, see https://research.oregonstate.edu/osraa/forms.

Additional time is recommended for large or complex proposals. If you are submitting a large proposal (there is no hard definition of a large proposal but we are typically talking about $1M per year) or complex proposal (large number of subawards, complex cost sharing, etc) then please notify proposals@oregonstate.edu so that we can prepare for the deadline and discuss when materials will be needed for a full review and successful submission.

Budget Development

For proposals in which OSU is the lead organization and is subcontracting with another organization, Office for Sponsored Research and Award Administration (OSRAA) needs to approve a project narrative and budget for the subcontractor. A signed letter or email from the organization's Authorized Organizational Representative must be included, along with a copy of the organization's negotiated F&A cost rate, if available.

For a revised budget that needs authorized organizational representative signatures, OSRAA needs a copy of the new budget and any other materials being submitted to the agency. If any changes have been made to the project narrative, a copy of the new narrative should be supplied as well. 

If the sponsor limits or does not allow F&A costs, the investigator must provide to OSRAA, with the proposal, a copy of the sponsor guideline stating the F&A cost policy . OSRAA will accept this limitation if it is a standard policy applied across all applicants for the sponsor or the sponsor’s specific program.

Any University cost-share commitments should be indicated in the Cayus proposal record and approved by the appropriate authorizing official for the source of those funds. External commitments need to be documented by letter or email from an authorized official.

OSRAA encourages investigators to include a reasonable increase in all budget categories to account for inflation in subsequent budget years. Typical increases for salaries and fringe benefits are 1-3% per year, and for tuition 5-10% per year.

When budgeting work to be performed from an outside organization, it is important to properly identify the work as a subaward or a procurement. Please refer to this guidance that explains the difference between the two types of activities:

Subaward or Procurement Determination

Cover Page

The TIN number and other frequently-needed OSU information are available on the Commonly Requested Information page. Be aware that this information changes frequently, so it is a good idea to bookmark this page rather than printing the information.

Submissions

OSRAA needs to approve, at a minimum, a completed Cayuse proposal record approved by all department, college and unit authorizers, project narrative and budget. In addition, any other forms being submitted to the sponsor must be submitted to OSRAA for approval.

OSRAA requires a minimum of three working days for review and approval of a proposal. Under extraordinary circumstances, and if the office is notified in advance, OSRAA may be able to review proposals in a shorter time.

A proposal being submitted to another organization in which OSU is a subawardee under the organization requires the same University approval as other proposals. OSRAA needs at least an approved Cayuse proposal record a project narrative and budget representing OSU's portion of the project. The investigator should contact the lead organization to determine if any additional information is needed.

Electronic Submissions

You ywill need to change your password.

Reset it yourself on the Fastlane webiste- select the Password Reset tab. Or, call (7-4933) or email (osraa@oregonstate.edu) Office for Sponsored Research and Award Administration and we will reset your password.

 

Procedures for submitting collaborative proposals to NSF depend on whether OSU is the lead institution. Consult the NSF Proposal & Awards Polices & Procedures Guide (PAPPG) for guidelines and instructions.

LABOR DISTRIBUTIONS ON SPONSORED PROJECTS

A Labor Distribution (LD) should be processed immediately after an error is discovered and for updates to future distributions. Labor distributions can be processed once the OSRAA Labor Distribution Form is completed and authorized.

Examples of circumstances that require LD adjustment:

  • Delays in funding resulted in charges being initially directed to a non‐sponsored project account

  • The Principal Investigator (PI) discovers an error during a monthly account reconciliation review

  • The PI or other project personnel change their effort and there is a delay in the communication of this change, or it is communicated after the current period payroll cutoff dates

During the effort certification process, the certifier realizes that payroll does not accurately reflect effort

Pending index accounts are strongly recommended if a delay in award funding or execution is anticipated. The timely set up of a pending index will likely eliminate the need to process retroactive labor distributions and other cost transfers. 


If a sponsored award does not have an index established in OSU’s financial system and no pending index has been requested and created, labor charges must be posted to a departmental or gift index while awaiting set up of the project index. Under no circumstances should sponsored awards be used as holding accounts for expenses which will subsequently be transferred elsewhere, including charges to competing or noncompeting continuations of the same project if a notice of award or new index number has not yet been received.

Required signatures are determined based on the situation, but, in general, the PI(s) for all indexes for which the form reflects a change in effort and a representative of FSS* should always sign the form.  Additional signatures may be required based on the situation, as outlined in the OSRAA Labor Distribution Guidelines.   You may also refer to the LD approval decision tree to determine which approvals are required on your form based on the situation.

Yes. However, once certification of effort has been completed, only in certain circumstances will subsequent salary adjustments be permitted. If a PAR was previously signed, the PI must provide an explanation as to why the effort was certified prior to reallocating salary.  If it is determined that a redistribution of salary is appropriate, the PAR form must be revised, recertified and filed in OnBase. The completed LD form should be attached to the corrected PAR form.

Federal regulations governing administration of sponsored project personnel expenses (2 CFR §200.430 (i-1,viii)) require that institutions receiving sponsored awards have support documentation available for how payroll allocations are determined and subsequently entered into the accounting system. These allocations must be under the direction of the PI or an individual that understands the tasks and objectives to be conducted and the individuals that need to be assigned to those tasks or program objectives. 

Additionally, sponsored project salary expenses must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Filing the LD form when future labor distributions are updated for new or continuing projects allows OSU to document this internal control system. 

 

Lastly, this facilitates proactive identification of significant changes to key personnel effort before they take place, ensuring compliance with sponsor prior approval requirements. 

Yes, authorized signatures are captured electronically through DocuSign.

Yes, as long as the email identifies the labor distribution and contains the certifications regarding effort of key personnel and whether there is a change in the scope of work. The detailed email must be attached as back-up documentation to the OSRAA Labor Distribution form filed in OnBase.

This is no longer an OSRAA requirement, but if a department head, dean, or director still wants to review/sign labor distribution forms for the PIs in their unit, an additional signature line may be added to the form by the form preparer.

Consistent with checks and balances built into other expenditure and payroll processes at OSU, a distribution of labor should be signed by an authorizer who did not prepare the distribution. This ensures segregation of duties and further documents OSU’s system of internal control.

If more rows are needed for current and/or revised distribution sections, additional lines may be unhidden or inserted into the Excel LD form, or you may add additional distribution blocks to the form as needed.

The justification must include sufficient information to describe and document the circumstance necessitating the LD.  The new salary distribution must reflect where the individual worked or is expected to work during the period(s) affected by the redistribution. The level of explanation will vary depending on the situation.  The OSRAA Labor Distribution Guidelines provide information on what justification is required based on the situation.

 

Example 1: Cost transfer of prior period pay
Jane Doe’s GA salary was set up on Dr. Bird’s nest project N0254A due to a transposition error. The salary should have been set up on Dr. Lyon’s jungle project N0524A since that is where Jane Doe worked. The error was discovered when Dr. Bird was reviewing PAR forms for the prior quarter.   

 

Example 2: Future period adjustment 
Dr. Lyon’s salary distribution is being updated from index N0524A to the continuation project index N0524B created for the current budget year. 

 

Example 3:  Future period adjustment to pending index for bracketed funding

Dr.  Lyon’s salary distribution is being updated to the pending index established for the next budget period of this award.  The anticipated modification for the upcoming budget period has not been executed, but a pending index has been established so that project expenses can be recorded in the appropriate period.

Key Personnel are individuals, typically Principal Investigators, Project Directors, and Co-Investigators, whose effort is absolutely essential to the success of the proposed activity, either because of their critical leadership positions within the proposal (and consequently their intellectual guidance) or because of the uniqueness of the expertise they are contributing relative to the proposed scope of activity. The replacement of any of these individuals requires approval from the sponsor, as does disengagement from the project or reduction of committed effort by 25% or more.  Importantly, the level of key personnel effort includes all project effort, whether reimbursed by the sponsor or paid from institutional sources (i.e., cost share).  Note that a sponsor may have a more specific definition of key personnel, per the terms and conditions of the specific award.  OSRAA will identify Key Personnel in the PI Letter when the award notification email is distributed. 

While it is important that the PI maintain a good relationship with the Program Officer, this is not sufficient for documentation of sponsor approval. Any decrease of 25% or more of key personnel planned project effort, or change to the scope of work, must be approved prior to the change and in writing by the sponsor's administrative/grants officer. The request must be processed through OSRAA in advance of the change. 

OSU maintains compliance with effort monitoring and certification requirements in several ways, one of which is asking the PI to confirm whether the current LD will revise key personnel effort by 25% or more from what was committed during the current project budget period. 

 

Per federal regulation (2 CFR §200.308 part c (iii)), OSU must have a process in place to identify and seek prior sponsor approval for a reduction of 25% or more of the original amount of time devoted to the project by key personnel. 

 

Similarly, if key personnel effort is increased 25% or more, OSU needs to confirm that the revision does not signify a change to the scope of work, which also requires prior approval of the sponsor. 

If these significant effort changes are only addressed during the quarterly PAR certification review, OSU is not in compliance with the federal prior approval regulation, as PARs are after-the-fact effort confirmation. OSU would then be in the noncompliant position of asking sponsor approval for a significant effort reduction or change to the scope of work after it has already taken place.

OSRAA and FSS* have a strong partnership and dual roles in enforcing financial and administrative compliance for sponsored programs.  After a pilot program in which FSS served as the sole administrative approver for these type of LDs in some units, OSRAA feels that compliance objectives are reliably met and efficiency is achieved by having FSS approve without needing additional approval from OSRAA.

*Some units may be authorized to approve their own LDs in lieu of FSS, e.g., RO C&I, OSU Cascades. Contact OSRAA for more information

Managing Awards with Bracketed Funding / Restricted Carryforward on Sponsored Projects

Bracketed funding, also referred to as bracketed spending is a subset of project funding restricted to a shorter budget period than the overall sponsored project period of performance. These funds may need to be tracked, reported, or invoiced separately from other project funds and do not have automatic carryforward of any remaining funds into future periods of performance or task(s) without sponsor approval. 

Carryforward is the unspent or unobligated balance of funds from a prior budget period(s) which the recipient may request to use in the current budget period to meet the needs or support the objectives of the project.  Awards on which carryforward is restricted will be treated as bracketed funding. The terms carryforward, carry forward, carry over, and carryover are often used interchangeably, and, at OSU will all be taken to have the same meaning.

Given that the terms have been used interchangeably at OSU and that there was not previously a policy or process to define them, we chose to focus on the big picture at this time and apply broad definitions that includes the various terms and forms of the terms (carryforward, carry forward, carry over and carryover).  The goal of this policy and process is to manage awards where carryforward of unobligated funds from one budget period to the next is restricted. 

The new procedure’s purpose is to:

  • Define roles and responsibilities when award terms indicate bracketed funds.
  • Create a common understanding of the process and when it applies so that 
    • Award terms are communicated to principal investigators and their fiscal and administrative research support teams from the time the award is accepted,
    • Costs are recorded properly recorded in the designated budget period,
    • Financial system flags are established to alert staff of expiring budget periods,
    • Claims and reports are completed accurately and timely using system events and reporting tools,
    • Carryforward requests are made timely and, when necessary, expired funds are deobligated and removed from the expired indexes,
    • New indexes are created timely as a procedural step in the transition from one budget period to the next, and
    • Expired indexes and funds are terminated on a timely basis.
       

The policy is effective January 1, 2024.
 

There are no exceptions to the policy.  When the sponsor sets terms that require prior approval to use remaining funds in the next defined budget period, the Bracketed Funding / Restricted Carryforward policy applies and the procedure will be initiated at award acceptance.

a.    The award terms will indicate that carryforward is restricted and OSRAA will include that information in the PI Letter at award acceptance as described in the procedure. 
b.    When the budget period is coming to an end, OSRAA will send a bracketed index closeout notification email to the PI and to FSS with guidance about when the budget period ends, when it is necessary to have expenses finalized, and on how to request carryforward if needed.

a.    The award terms will indicate that carryforward is not automatic, and that prior sponsor approval is required. If carryforward is not granted, the unobligated (unspent) funds will expire.
b.    The Grant and Contract Officer will identify that the award has restricted carryforward and will provide the restricted budget period. This will then be included in Banner and communications will take place prior to the budget period expiring, to enable the termination of the expiring period and to have indexes available for expenses in the new budget period.
 

a.    The reduction recognizes that the spending authorization from the sponsor has a time limit and sponsor approval is needed to use the funds after that timeframe. 
b.    Until and unless the sponsor approves a carryforward request, the funds in the expired budget period are not available to use. When approval is granted, the approved amount will be added to the current budget period total.

a.    Also known as 2 CFR Part 200, the Uniform Guidance is an authoritative set of rules and requirements for Federal awards that superseded guidance from earlier OMB circulars. It establishes uniform administrative requirements, cost principles, and audit requirements for Federal awrds to non-Federal entities. 
b.    The complete document may be found at the following site: Code of Federal Regulations National Archives: https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200?toc=1.
 

a.    If there are no terms that restrict carryforward, the policy does not apply.
b.    However, if new budget/budget periods are added with later amendments and carryforward is restricted in the amendment, the award will be updated to reflect the change in terms and the policy will be initiated and communicated as laid out in the procedure.
 

a.    OSRAA will send out advanced notices for bracketed indexes 60 days ahead of the current budget period end date.  The notice will also provide a due date for final expense figures to be provided to OSRAA and instructions about how to request carryforward if it is needed.
b.    At the same time, Set-up will be provided with a list of new indexes to create to support the continuing budget period so expenses can be posted to the correct budget period. The new indexes will be shared with the PI and fiscal support unit when they are available.

a.    When carryforward is restricted, requests are based on program need and are not automatic.  The PI will need to identify this need and provide a justification telling how the funds will be used to support the funded program.  
b.    If the funds will be used differently than originally authorized, a rebudget form will be needed as well as the carryforward request.

Instructions and the template will be found on the OSRAA Forms webpage: https://research.oregonstate.edu/osraa/forms.

There are other instances of bracketed awards that are bracketed by something other than budget period (task, PI, Participant Support, supplemental funding, or a combo of one of these plus budget period). I hope those will still be flagged as Bracketed in FRAGRNT as well, even if the process to manage them in Banner may be different.
a.    There are a lot of reasons for having different indexes to separate funding for different tasks, PIs, orgs, participant support, supplemental funding, and reporting requirements, and this policy is aimed at the situations where funding is allocated for a particular budget period that is different from the performance period and where carryforward is not automatic. 
As outlined in the procedure, we will rely on contract officer to identify whether carryforward is restricted by the sponsor and to flag the award to ensure that the budget period is recorded.  From this, we will now have a consistent process to make sure that required reporting, billing, and draw events take place timely, that carryforward requests take place according to the terms of the agreement, and that expired budget periods are closed out.

Indexes assigned to allow reporting by task, to limit the F&A rate for participant support or supplemental funding, and/or to allocate a budget to a co-PI will continue, but these would not be coded as bracketed funds in Banner for that reason alone. If the supplemental funding or task has a different budget period and the funds cannot be carried forward for other purposes, the policy and procedure would apply

a.    The “bracketed funding” flags are being renamed to “carryforward restricted?”, and the PI letter notes “Yes” or “No”. When carryforward is restricted, it will be marked “Yes” and the current budget period is provided. This information will be captured in Banner to allow for timely reminders of the period closing and related carryforward requests, reporting, invoicing, and draws.
b.    As part of the implementation process for the new policy / procedure, OSRAA will update Banner records for existing awards in preparation for the January 1, 2024 launch date.

a.    In addition to OSRAA staff and the assigned fiscal support unit, the following resources are available:

OSRAA Policies: https://research.oregonstate.edu/osraa/osraa-policies

  • RO Policy 24-006: Bracketed Funding / Restricted Carryforward on Sponsored Projects

OSRAA Frequently Asked Questions (FAQs)

OSRAA Training 

  • Standard Operating Procedure: Managing Awards with Bracketed Funding / Restricted Carryforward on Sponsored Projects
  • Workflow: Managing Awards with Bracketed Funding / Restricted Carryforward on Sponsored Projects
  • OSRAA Outreach and Education recording, 11/16/2023

OSRAA Forms

  • Carryforward Request Template
  • Rebudget Form for Sponsored Projects
  • Rebudget Guidance and Prior Approval Matix

Finance and Administration Controller’s Unit Forms

  • Sponsored Award Closeout Checklist 

Federal Uniform Guidance: