DEADLINE PROCEDURES FOR CONTRACTS & GRANTS

A message from Zach Hall, Vice Chancellor of Research:

Since 1993, the Contracts and Grants Office has had a deadline for receipt of proposals of four working days before the agency deadline. This Contracts and Grants deadline was necessary to allow sufficient time for the C&G staff to adequately review proposals before submission to the funding agency. As part of our policy, we also have had a procedure for granting waivers to accommodate those unable to complete their application by the deadline for reasons of an emergency.

Recently the number of waivers requested has exceeded our ability to accommodate them. For some NIH deadlines, for example, over half of the submissions have been late. The reasons given for late submission have become increasing trivial, and some departments are reputed to have a form letter requesting waiver. The resulting flood of late grants has placed an extraordinary burden on our staff, who have been hard pressed to monitor the grants adequately, increasing the risk that grants will be submitted with inadequate compliance documentation. At the same time, NIH has increased its scrutiny of grants, particularly with regard to approval of human and animal experimentation and certification of training. They have recently reiterated their concern to us over the quality and accuracy of applications that are submitted. They have warned us that repeated failure to comply with their policies for submission could have serious consequences for our campus.

As a result of the current situation we are changing our procedures. As of June 1, 2001, Contracts and Grants will operate under the following conditions.

1. The deadline for receipt of proposals by Contracts and Grants remains 9:00 AM four working days before the funding agency deadline. This deadline applies to all proposals, including fellowships and non-competing continuations, and to all funding agencies (private, federal, state and local government).



2. Applications received in Contracts and Grants on or before the four-day deadline will meet any agency deadline, provided that any compliance deficiencies determined during proposal review are resolved in time. Compliance criteria that must be met are: human and animal subject regulations, conflict of interest disclosures, cost accounting standards, and use of appropriate F&A rates. Because every proposal will receive a compliance review, applications received after the deadline run the risk of being submitted late. It is the investigator’s responsibility to submit complete applications in time to meet the agency deadline.



3. No campus waivers will be granted as of June 1, 2001. Instead, the Principal Investigator must submit a letter to the granting agency requesting that the late proposal be accepted for review. The letter must be typewritten, addressed to the funding agency, and provide an explanation as to why the proposal is late.

This change in policy is being implemented so that we can be confident that all proposals comply with university and agency policies, thus reducing our liability as an institution to audit or to corrective action by a granting agency.