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 email@example.com so that we can prepare for the deadline and discuss when materials will be needed for a full review and successful submission.
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:
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.
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.
Fill out the Fastlane Registration form (PDF) and submit it to OSRAA
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.
A Labor Distribution (LD) should be processed immediately after an error is discovered and for future distributions. Labor distributions can be processed once the OSRAA Labor Distribution Form is completed and authorized.
If a sponsored award does not have an index established in OSU’s financial system, labor charges must be posted to a departmental, gift or pending 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 to competing or noncompeting continuations of the same project for which the notice of award or new index number has not yet been received.
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 labor distributions and other cost transfers.
No. LD forms must be completed for all labor distributions affecting sponsored projects, regardless of the timeframe. However, only certain forms require OSRAA approval.
LD forms that may be processed by authorized by Financial Strategic Services (FSS) partners and directly filed in OnBase, without OSRAA approval:
LD forms require OSRAA approval in the following instances:
Complete the OSRAA Labor Distribution Form through DocuSign and file in the Payroll role in Nolij. OSRAA approval is not required for current or future period LDs unless key personnel effort is revised by 25% or more for the project budget period or the project scope of work is changing. See Labor Distribution Instructions for specific DocuSign guidance.
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 Nolij. 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, significant changes to key personnel effort are flagged and captured before they take place, allowing OSU to comply with sponsor prior approval requirements.
Yes. As of Fall 2017, all 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 in DocuSign.
A minimum of two signatures/approvals are required for every LD – the PI and the Business Center/Department authorizer.
A third signature - Dean/Director/Dept. Head – is required if the LD is for a distribution of PI’s labor.
A fourth signature – OSRAA - is required if the LD meets the criteria needing OSRAA review and approval.
Multiple PIs may approve the LD in DocuSign. Each PI must be added as a Recipient in DocuSign so that the form will route to each approver.
An individual may not approve their own labor distribution. The PI’s supervisor should sign the LD. For example, a PI who is Dept. Head should obtain Dean (or official designee) signature on the LD. The PI still completes the certifications for 25% effort revision and change in scope of work.
Obtaining a secondary level of approval for an individual’s own effort distribution documents OSU’s system of internal control, complying with requisite federal regulation, such as 2 CFR §200.430.
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 multiple forms may be used, as long as all forms are signed by each approver.
The justification must include sufficient information to describe and document the circumstance of the LD, including why the salary was charged incorrectly to the original index and how the salary directly benefits the receiving project. The new salary distribution must match where the individual worked during the period(s) affected by the redistribution. If the transfer is 90 days or more from the initial payroll charge, include an explanation as to why salary was not transferred in a timely manner.
Also include information as to a change to the scope of work or revision of key personnel effort by 25% or more, if applicable.
Jane Doe’s 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 not immediately discovered because Dr. Bird has numerous students assigned to N0254A.
Dr. Lyon’s salary distribution is being updated from index N0524A to the continuation project index N0524B created for the current budget year.
Dr. Green’s salary distribution is being updated from P0123B to P0123C because a new index had to be set up for a change in F&A rate for year three of the grant.
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 project 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 (cost-share).
Note that a sponsor may have a more specific definition of key personnel, per the terms and conditions of the award. OSRAA will identify Key Personnel in the PI Letter when the award notification email is distributed.
The certifications for change in key personnel effort and change to scope of work are applicable and required on all LD forms. If the LD is for non-key personnel, the certification may indicate that the distribution “will not” revise key personnel effort by 25% or more.
An increase in effort of 25% or more for key personnel should also be reviewed to assess whether there has been a change in the scope of work and the impact, if any, on other sponsored awards. If there is a change in the scope of work, it 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.
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.
The LD certification for revision of key personnel effort is for the current project budget period, not the specified period of distribution on the LD. The certification is intended to promote proactive dialogue between the PI, Financial Strategic Services, and OSRAA regarding whether the change requires prior approval from the sponsor.
While it is true that project plans often change and effort may fluctuate over the life of the award, OSU is required to have an established method of monitoring effort changes as they occur, in order to comply with the requirement to request sponsor prior approval for key personnel effort changes of 25% or more.
Not necessarily. OSRAA will review the LD within the parameters of the regulations governing the award and specific project terms and conditions. If there is a significant revision in effort for the current project budget period but project effort will be at or near the promised level of effort over multiple budget periods, sponsor approval may not be required as long as OSU documents that the overall project effort meets the individual’s level of effort promised in the proposal and/or award.
For example, if effort is reduced more than 25% for the current budget period but will increase in a later period (or has already increased in a previous period), it may not be necessary to request sponsor approval because OSU can document that the overall effort commitment for the individual will meet the promised effort over the life of the project. The PI should still indicate on the LD form that the effort is being reduced 25% or more for the current budget period and provide information about the overall level of effort remaining as committed. OSRAA will review the LD and determine if any action is needed or if the form may simply be filed as documentation.
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 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.
Part of OSRAA’s review of the LD form is to determine the specific effort requirements under the terms and conditions of the particular sponsored award. This is why it is important to include enough information on the LD form to explain when overall project effort will not be revised by 25% or more, even if the current budget period’s effort is significantly changed. Examples below show scenarios where effort is changed but may not rise to the level of requiring sponsor approval.
Note that these are provided only as examples - some sponsors have more restrictive prior approval terms.
Dr. Doyle’s effort on S0123A will be reduced by 30% for the months of June-September, 2016 so that he can increase effort on DA247B where the research is season dependent. Dr. Doyle’s effort for S0123A will increase again to focus on S0123A project work in October, after the current season. Overall project effort for S0123A will not be reduced by 25% or more and he will fulfill his effort commitment on the award.
Dr. Bennett will be increasing her effort on G0125C by 30% because the graduate student on the project left unexpectedly and the field analysis must be completed. The scope of the project will be unchanged.