Begin key processes

The bottom line

If any of the processes on this page will be a part of your proposal, you should get each of them started immediately.

There are many different processes involved in writing your proposal, and some of them can be time-consuming. In order to complete your proposal faster, you should identify these processes now and start working on them concurrently.

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Extra compensation for faculty and academic professionals

BOTTOM LINE: Extra compensation is generally not allowable on sponsored agreements. For faculty only restricted consulting arrangements are permitted. If your project requires consulting services from faculty or academic professionals, check to see that ALL of the conditions below are met. If they are, fill out the Justification and Approval Form for Intra-university Consulting Pay and include it with the ORSPA 300A form when you get approval signatures.

List of conditions required for faculty extra pay, referred to as intra-university consulting

• Faculty member is functioning as consultant or otherwise contributing to a sponsored agreement conducted by another faculty member.
• Consultation is across departmental lines or involves a separate or remote operation.
• Work performed by the consultant is in addition to his regular departmental load.
• The consulting arrangement is specifically provided for in the agreement or approved in writing by the sponsoring agency.
  

Extra compensation for employees other than faculty and academic professionals

Related policies: SSP 404-02, SSP 404-04 and RSP 502-01

Extra compensation for non-exempt employees is subject to the university’s overtime policy and cost accounting standards. To pay non-exempt employees for sponsored accounts complete the Cost Accounting Standards (CAS) Exception Form.

Extra compensation for exempt employees other than faculty and academic professionals is governed by university policy SSP404-02 Supplemental Pay. It may be allowable on sponsored projects, when supported by project scope of work, an approved Cost Accounting Standards (CAS) Exception Form and when one of the following conditions is met:

1. The supplemental work is within the employee’s regular job classification and will be paid within the regular pay range, but is performed for a department other than the employee’s assigned department and beyond the employee’s regular hours.
2. The supplemental work is a specific type which is separate and distinct from the duties and responsibilities of the employee’s regular job classification. In this case, the pay rate will be within the range of the assigned pay grade of the job classification which encompasses the supplemental work or at a pay rate approved by Human Resources (HR).
3. The supplemental work is teaching a special interest course which is offered without academic credit. The rate of compensation shall be based on the type of supplemental activity performed and approved by HR.
4. The supplemental work is teaching an academic course which will generate student credit hours. The rate of compensation shall be based on the normal compensation provided for the type of work rendered and shall be approved by Academic Affairs.
   

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Charging facilities & administrative costs as direct costs

BOTTOM LINE: If your project involves direct costs that would normally be charged as facilities and administrative (F&A) costs:

• Be sure to justify the costs in your proposal narrative, explaining the unusual circumstances that support treating them as direct costs.
• Complete the CAS Exception Form and include it with the ORSPA 300A form when you get approval signatures.
• Guidelines are available in General Criteria for the Treatment of Costs Matrix (MS Word).

What are F&A costs?

F&A stands for facilities & administrative costs. F&A costs are expenses that cannot be easily charged to a project. For example:

• electricity,
• building maintenance,
• office supplies,
• administrative staff,
• etc.

Since F&A costs are difficult to charge to a project, they are computed as a percentage of overall project costs.

What are direct costs?

Direct costs are costs that can be directly assigned to a particular project easily and with a high degree of accuracy. For example:

• salaries for people working on the project,
• materials and supplies that are part of the project,
• travel costs,
• etc.

Direct costs must be considered allowable, allocable, and reasonable. They should also be justified and verifiable in the technical proposal as well as the budget narrative.

For more information about F&A costs and direct costs, review the General Criteria for the Treament of Costs.

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Waiving facilities & administrative (F&A) costs

You should make every effort to recover your project's full F&A costs from your sponsor. If the sponsor will not or cannot pay the full amount, you and your academic unit/college/school should make every effort to cover that amount with other funds. If you are unable to cover that amount with other funds, you may request a waiver from the OVPREA. Favorable consideration will be given to the following:

• projects that lead to funding from sponsors that do not restrict F&A charges,
• projects that support research capacity growth in strategic areas, or
• projects that promise greater quantifiable recognition for ASU.

If the OVPREA approves your waiver request, include it with the ORSPA 300A form when you get approval signatures.  In Section G, check the box titled "OVPREA Waiver of Recovery".  If you or your unit is also contributing to the F&A rate, enter the alternate fund account number(s) on the following line title: Recovery Agency/Org#.

If the sponsor is a federal sponsor with an official and uniformly-applied limitation policy

The OVPREA will automatically approve a waiver. RID and IIA will be distributed. A waiver request is not needed.

• Attach a copy of sponsor guidelines to the ASU Proposal Routing and Approval form. 
• In Section G of the Proposal Routing and Approval form, check the boxes titled "Agency Limitation" and "OVPREA Waiver of Recovery".

If the sponsor is NOT a federal sponsor, but has an official and uniformly-applied limitation policy

Situation 1: The PI uses alternate funds to cover the entire F&A rate.

A waiver request is not needed.

• Include documentation of these alternate funds (including the account numbers) with your proposal package. 
• In Section G of the Proposal Routing and Approval form, check the "Agency Limitation" box and enter the alternate fund account number(s) on the following line, "Recovery Agency/Org#".
• In most cases RID will not be distributed. 

Situation 2: The PI is unable to cover the full F&A cost rate using alternate funds, but is able to cover a portion of it.

A waiver request may be submitted. Provide the following to your academic unit/college/school:

• Documentation of the sponsor's policy to uniformly limit F&A on all awards. This could be a copy of the sponsor's policy as found in the announcement, on the sponsor's web site, or on a standard letter. If using a standard letter, it must be written on the sponsor's letterhead and signed by an authorized signatory such as the president, vice president, secretary, or treasurer.
• A one-page, written rationale for why the university should subsidize the project, including a budget. Sample format for requesting a waiver. Note that email waiver request chains with appropriate approvals are also acceptable.
• Document any additional funds to cover the full F&A cost rate, including account numbers, on the waiver request memo and route the request through your chair/unit director and dean to the OVPREA.
• In most cases RID will not be distributed. 

Situation 3: The PI has no alternate funds.

A waiver request may be submitted. Provide the following to your academic unit/college/school:

• Documentation of the sponsor's policy to uniformly limit F&A on all awards. This could be a copy of the sponsor's policy as found in the RFP, on the sponsor's web site, or on a standard letter. If using a standard letter, it must be written on the sponsor's letterhead and signed by an authorized signatory such as the president, vice president, secretary, or treasurer.
• A one-page, written rationale for why the university should subsidize the project, including a budget. Sample format for requesting a waiver. Note that email waiver request chains with appropriate approvals are also acceptable.
• In most cases RID will not be distributed.

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Subcontracts

BOTTOM LINE: If your project will involve a subcontract you should:

• Fill out a Request for Subcontract memo and include it with the ORSPA 300A form when you get approval signatures.
• Make sure your subcontractors prepare their work statement and budget consistent with agency guidelines and submit to ASU in time for ASU to meet the agency deadline.
• Make sure your proposal contains the following information about the subcontract:
  • technical requirements or statement of work
  • budget and budget justification
  • endorsement by that organization specifying the services to be performed by each proposed subcontractor within the general scope of the prime agreement

A subcontractor is any supplier, distributor, vendor, or firm that furnishes supplies or services to ASU.

To start the official process, fill out a Request for Subcontract memo. The memo needs to be printed on departmental letterhead for proper processing. This request may include a sole source justification, or even a bid waiver, if appropriate. Either option will require the approval from Purchasing and Business Services before final negotiations with the subcontractor can be conducted.

After receiving the request, your SPO will verify any sole source or bid waiver approvals, prepare the subcontract, and begin the negotiation process.

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Regulatory compliance

Projects that involve any of the issues listed below require you to obtain special approvals. You may also need to complete required training.

Human subjects

If your project involves human subjects, you must submit a protocol form to the Institutional Review Board (IRB) for approval. Approval must be documented before you can submit the proposal for external funding.

Contact the IRB coordinator well in advance of the sponsor deadline for guidance and assistance (usually at least one month before proposal due date). See ORSPA's Human Subjects page or call (480) 727-6526 for more information.

Lab animals

If you project involves the use of vertebrate animals, you must submit a protocol form to the Institutional Animal Care and Use Committee (IACUC) for approval. Approval must be documented before you can submit the proposal for external funding. No animal may be procured or accepted unless approved by the IACUC. Early on, contact the IACUC chair or secretary. See ORSPA's IACUC page or call (480) 965-2179 for more information.

Biosafety issues

Any research that involves recombinant DNA or infectious agents must be registered with the Institutional Biosafety Committee whether exempt from federal regulation or not.  Contact the chair or coordinator of the Biosafety Committee at least one month prior to proposal due date. See ORSPA's Biosafety page or call (480) 965-2179 for more information.

Scientific Diving

If your research involves scientific diving, See ORSPA's Scientific Diving page or call (623) 845-3277 for more information.

Radiation

You are responsible for ensuring that use of radiation sources complies with federal, state, and university standards.  All projects involving radioactive materials or radiation-generating equipment must be coordinated with the Office of Radiation Safety. See the Office of Radiation Safety page or call (480) 965-0193 for more information.

Hazardous waste

Hazardous waste materials must be properly managed and disposed of. If your project involves hazardous waste materials, refer to the Environmental Health & Safety page or call (480) 965–1823 for more information.

"Export sensitive" items

BOTTOM LINE: If your project involves "export sensitive" items, contact ORSPA's Research Compliance Office at (480) 965-2179. You can find specific lists of "export sensitive" items on ORSPA's Export Controls FAQ page. More information can also be found on ORSPA's Export Control Regulation page.

Federal export control laws prohibit unlicensed export of information related to certain products and technologies for reasons of national security and protection of trade. These laws apply whether or not there is a specific citation to the regulations in an award document. Government rules and regulations govern the transfer of the following items to non-U.S. entities or individuals, regardless of where or how the transfer takes place:

• Commodities (equipment, hardware, or material)
• Technologies (technical data, information, or assistance)
• Software/codes (commercial or custom)

Foreign nationals

If you have foreign nationals involved with your project, be sure to mark it on the ORSPA 300A form. Should your award involve restrictions on foreign nationals, you will need to contact ORSPA's Research Compliance Office at (480) 965-2179.

Foreign national means any person who is not a citizen or permanent resident alien of the United States. A more formal definition:

As defined in 22 CFR 120.16 (Code of Federal Regulations), a foreign person means any person who is not a lawful permanent resident as defined by 8 U.S.C. 1101(a)(20) or who is not a protected individual as defined by 8 U.S.C. 1324b(a)(3). It also means any foreign corporation, business association, partnership, society, trust, or any other entity, organization or group that is not incorporated or organized to do business in the United States, as well as international organizations, foreign governments and any agency or subdivision of foreign governments (e.g., diplomatic missions).

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Representations and certifications

Some federal sponsors may require applicants to provide assurances or to sign certifications of compliance with a variety of federal regulations, such as:

• certification of a drug-free workplace,
• restrictions on lobbying,
• debarment,
• etc.

If any of these forms or certifications need to be included with the proposal, notify your SPO and allow time for completion of the forms. ORSPA will then provide the assurance(s) to the sponsor with the authorized university signature.

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Cost sharing

BOTTOM LINE: If your proposal involves cost sharing, fill out the ORSPA 305 form and include it with the ORSPA 300A form when you get approval signatures.

Note that once you receive your award, you will need to monitor your cost sharing expenditures.

Cost sharing is when ASU helps pay the costs of a project. Sometimes another organization besides ASU may help to pay the costs of the project. This is called third-party cost sharing.

The technical definition for cost sharing is "sponsored project costs that are not borne by the sponsor".

Cost sharing is also known as "matching".

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