These guidelines are intended as a resource for faculty and administrative staff to support the implementation of the processes around funding, initiating, and managing research. The Dornsife SPH Research Office will update these guidelines regularly and will work to keep these guidelines consistent with University policies. If you have any questions or comments (including specific items you would like to see added or suspect require updating) please email the Director of Research Administration, Moira McAndrews at email@example.com.
Activity for which the primary objective is research that is funded by an organization other than the University (also known as extramurally funded research). The funding mechanisms supporting this category include research grants, subcontracts, contracts, cooperative agreements, and gifts. If you have a question as to whether a proposed activity should be considered Organized Research, contact the Director of Research Administration, Moira McAndrews at firstname.lastname@example.org. If a project is considered Organized Research, the expectation is that a funding application will include an indirect cost allocation at the appropriate federally negotiated rate regardless of the sponsor. More on budgeting for Indirect Costs (IDC) here.
Other Sponsored Activities
Other Sponsored Activities are funded activities that are not Organized Research or student instruction. Activities here that might involve research-active SPH faculty include program evaluation or other services, conference/symposia/workshop organization, and infrastructure support. If you have a question as to whether a proposed activity should be considered Other Sponsored Activity, contact the Director of Research Administration, Moira McAndrews at email@example.com. If a project is considered Other Sponsored Activity, the expectation is that a funding application will include an indirect cost allocation at the appropriate federally negotiated rate regardless of the sponsor. More on budgeting for IDC here.
Training and Career Development
Individual Fellowships: Undergraduate, graduate (pre-doctoral) and postdoctoral fellowships focused on research that individual trainees apply for themselves, typically with involvement of an advisor/mentor. Examples: NIH, NSF, HRSA, and AHA Individual Fellowships. At NIH, these are F-series grants. Awards for these activities typically have specific guidance on allowed indirect costs.
Institutional Training Grants: Awards made to institutions, or programs within institutions, to support groups of trainees typically part of a formal disciplinary and/or thematic training program. These awards create “slots” that can be used to support future trainees coming into the program. At NIH these are T-series grants. Awards for these activities typically have specific guidance on allowed indirect costs.
Career Development Awards: Awards designed to promote the career development of specific groups of individuals based on their past training and career stage. For junior faculty, the objective of these programs is to bring candidates to the point where they are able to conduct their research independently and become competitive for other funding. At NIH, these are K-series awards. Awards for these activities typically have specific guidance on allowed indirect costs.
Information on NIH-sponsored training programs can be found here with separate “kiosks” pertaining to the different programs.
Grant: An agreement under which Drexel University conducts research under the direction of a PI generally following a proposal developed by the PI. The PI has a fair amount of autonomy in shaping the direction of the research, though communication with the sponsor is advisable when activities deviate from the proposal. Guidelines exist from federal (and other) funders on rebudgeting grant expenses and are discussed here. Deliverables are generally limited to fairly brief progress and final reports of summary findings and finances, though sponsors expect these to yield scholarship and failure of investigators to be productive in this regard can affect their chances of receiving further funding from the same sponsor.
Cooperative Agreement: A funding mechanism similar to a grant, but where the sponsor more actively participates in the implementation of a project along with University personnel. Reporting requirements vary but there is often a more extensive final deliverable report required.
Subcontracts: An agreement where another organization (i.e. university) assigns a portion of the substantive research work to Drexel University. There will be a subcontract PI at Drexel and an overall project PI at the parent institution. Typically when funds are being sought the Drexel subcontract PI will be responsible for preparing a budget and other elements of a business proposal and scope of work but the main application is submitted by the project PI (though the Drexel subcontract PI may contribute to the development of that application).
Research Contracts: Contracts for the performance for research related services performed by Drexel faculty or personnel. These can be included in funding applications being submitted by a PI at another organization (i.e. university) or can be directly negotiated with a funder. This mechanism can involve fee-for-service pricing, where an investigator has preset fees that combine consideration not only of direct costs but of the indirect costs born by the University (i.e., a laboratory that performs established, non-experimental assays for other researchers needs to consider overhead costs in addition to direct costs associated with the assay when setting fees). However, this mechanism may also be used by certain funders for projects that require direct and indirect cost budgeting (these funders may have guidelines around specific budgeting practices and acceptable IDCs).
Intramural research refers to research activities funded by University sources. These can include individual faculty start-up funds, Departmental, School or University resources. Research projects funded by internal sources still adhere to standards for responsible conduct of research including, as appropriate, IRB review. For internally funded interventional research, the Office of Research maintains an Investigator Initiated Study Advisory Committee to help faculty who are launching such projects understand such requirements.
Competitive Intramural Funding
The University and the School, as well as other Colleges and Schools or Research Institutes, may announce internal calls for proposals. Depending on the focus or theme of the announcement, the request for proposals may be school-wide or to the University at large.
Calls are typically strategically focused and intended to serve as seed or pilot funding for larger scale proposals. Increasingly, University-level intramural funding opportunities will have application material distribution and proposal submission processes run through the Office of Research’s InfoReady Review site. In such cases, a COEUS submission will not be required. Questions can be directed to firstname.lastname@example.org.
Fund set up for Intramural Funding
Requests for new funds for internally funded research will utilize the Fund Request Form. The Fund Request Form has been updated to capture additional information needed by Research Accounting to set up the grant in the Banner Research Accounting Module. Requests for internally funded research funds should include a completed Internally Funded Research Budget Form and internal award letter and be sent via e-mail to email@example.com.
Indirect costs (IDCs) are costs associated with completing research that are not included in the budget as project specific line items (i.e., are not “direct” costs of research). They are also referred to as Facilities and Administrative (F&A) costs or overhead costs. These include facility operation and maintenance, utilities and building and equipment depreciation, administrative costs associated with University units needed to have an infrastructure to conduct research (from Human Resources to the Institutional Review Board). This infrastructure must be in place for investigators to be able to successfully compete for, implement and manage the research that they do; therefore research programs need to contribute to the costs associated with this infrastructure. Under Drexel’s new model of budgeting, Responsibility Center Management, the School will be charged by other units around the University for the infrastructure those units create. The IDC costs investigators include on grants are the source of funds that the School must rely on to cover these charges from other units plus our own infrastructure costs.
Most sponsors, including the federal government, recognize the need for projects to cover indirect costs in addition to line item costs that are included in their budget. Federal allowed IDC rates are negotiated between the University and the Department of Health and Human Services (DHHS) to best reflect the real indirect costs of conducting research at our institution. The link to the official University page where the documentation of the current and historical federally negotiated allowable IDC rates can be found here.
Some sponsors place restrictions on the IDC rate that can be charged on a project proposal. All proposals must include always include the maximum amount of Indirect Costs (IDCs) allowed by the sponsor. However, if this maximum allowable IDC rate is below the federally negotiated rate for that category of activity, pre-approval from the School of Public Health Research Office is needed. The School recognizes that there will be certain important public health projects that can only be funded by sponsors who will not pay full IDCs and that funding from sponsors that do not pay full IDCs can be also be critically important to launching research initiatives that subsequently will be supported by federal sponsors. See below for more information on the pre-approval process.
Drexel uses COEUS as the pre-award budget preparation and routing/approval system. It is the mechanism for creating budgets, sharing proposal documents, obtaining approval on grant and contract submissions and tracking this information across the entire University. All proposals requesting funding or committing Drexel resources must be routed and approved in COEUS in advance of the sponsor deadline. COEUS does not interface with Grants.gov as a system to system grant transmission mechanism, so proposal application packets (adobe forms set) or other application materials to be sent to the funder are typically prepared in parallel with the COEUS record and uploaded in the “attachments” section for routing, approval and then final submission to the sponsor. More information on the mechanics of submitting a proposal through COEUS are given below.
Note that the process described here is consistent with University guidelines. A link to the University Office of Research FAQs on IDCs is available here.
STEP 1: Determine whether a project falls in one of two categories: 1) Organized Research or Other Sponsored Activity. Guidelines for making this determination are below.
Organized Research: Refers to activity for which the primary objective is research (rigorous inquiry, experiment, or investigation to increase scholarly understanding). Even if the project includes other elements, if the primary objective is research, the Organized Research IDC should be used. The federally negotiated Organized Research IDC rate is currently: 56.5%
Other Sponsored Activities: Refers to activity that is not research or instruction and may include: program evaluation or other services, conference/symposia/workshop organization, and infrastructure support. Note, however, that some federal infrastructure programs (e.g., NIH S10 Shared Instrumentation Grants) and conference funding mechanisms (NIH R13 and U14 applications) do not allow any IDC to be budgeted. If the activity also includes research (i.e., will result in scholarship, will involve student research trainees) the investigator should carefully consider whether the Other Sponsored Research rate is more appropriate. If the project is ultimately considered Other Sponsored Activity, the expectation still is that a funding application will include IDC allocation based on the federally negotiated Other Sponsored Activity rate regardless of the sponsor.
The federally negotiated Other Sponsored Activity IDC rate is: 36%
STEP 2: Determine if the off-campus rate applies.
The Off Campus rate is a reduced IDC rate that can apply when the “preponderance” of activities for a project, regardless of whether the project is Research or Other Sponsored Activity, are conducted at a location other than Drexel University’s property. For a project that involves a mix of on and off campus activity, as many public health projects will, investigators should conduct the following exercise to determine if an off-campus rate applies.
- For each of the Drexel personnel listed on the grant, in each year, estimate their effort on significant project activities spent on and off campus.Include all effort, including any cost-shared effort, and don’t try to pull out effort/time associated with occasional off-campus activity (e.g., travel for meetings).For example, a PI budgeted 1.2 calendar months of effort in a year spending virtually all of her project time on campus would contribute 1.2 calendar months to on-campus and zero calendar months off-campus.A half-time research assistant that spent one-third of their work hours in the office on-campus and two-thirds in the field would contribute 2 calendar months to the on-campus and 3 calendar months to the off-campus totals.
- Sum the on- and off-campus calendar months of effort in each year and tally across years to get on- and off-campus project effort totals for all Drexel personnel.
- If the off-campus effort exceeds 50% of the total effort, the project should use the off-campus rate.
The federally negotiated off-campus IDC rate is: 26%
On-campus vs. off-campus activity for projects taking place in Drexel leased space:
If activity occurs in Drexel University leased space and the lease is a direct line item charge in the project’s budget, then that activity is considered off-campus and the personnel time spent in that activity would contribute to the off-campus effort total. However, if the project effort is conducted in University leased space and the budget does not include a line item for the lease cost, then that effort is still considered on-campus and the time spent by Drexel personnel in these activities would count toward the on-campus effort total.
IDC rates for research training activities
Federal Training (e.g., NIH mechanisms) and Career Development (i.e., NIH K mechanisms) grants have their own reduced IDC rate requirements. The NIH IDC rate for these programs is currently 8% but investigators should check the FOA/RFA announcements for the particular research training mechanism.
IDC rates for instructional and other activities
Note that Drexel University has federally negotiated IDC rates for Instructional activities and for Interagency Personnel Agreements (but these are not typically used in sponsored project budgeting at SPH).
Proposals using ANY Indirect Cost Rate other than the Organized Research on-campus rate
For any application (other than a training and career development application) that does not use the on-campus Organized Research rate, the investigator must submit a Reduced IDC Request Form carrying both the principal investigator’s and the department chair’s signature to the SPH Research Office at least 10 days before the proposal submission deadline.
An investigator proposing a project that will use either a federally negotiated Off Campus or federally negotiated Other Sponsored Projects rate (based on the rules described in Determining the appropriate IDC rate to use in a project budget section) needs to complete Sections 1 and 2 of the Reduced IDC Request Form.
An investigator proposing either 1) an on-campusOrganized Research project that will use a rate less than the federally negotiated Organized Research Rate; 2) an on-campus Other Sponsored Activity that will use a rate less than the federally negotiated Other Sponsored Projects rate; or 3) an off-campus project that will use a rate less than the federally negotiated Off-Campus rate, needs to complete Sections 1 and 3 of the Reduced IDC Request Form and attach documentation from the sponsor of the required IDC rate restriction. Acceptable forms of documentation include copies of a specific FOA or RFA or a copy of blanket IDC policy statement (web links or screenshots are acceptable) or written communication (letter or email) from a program official at the sponsor organization. Documentation must explicitly state the required IDC to be used and clearly indicate that the reduced indirect rate is a condition of application acceptance. In these instances, the COEUS submission will also need to include a copy of the fully executed (investigator, department chair, and associated dean for research signatures) Reduced IDC Request Form and the supporting documentation. This documentation must be uploaded in the “institutional attachments” section of COEUS and be clearly labeled as “IDC Documentation”. If the documentation can be limited to, or highlight, that pertaining to IDC policy (as opposed to attaching an entire FOA), that would be appreciated.
Investigators are strongly urged to communicate with their Department Chair before they seriously consider submitting any application that will require an IDC rate other than the federally negotiated Organized Research rate and to submit the Reduced IDC Request Form to the SPH Research Office as soon as possible once they have decided they want to proceed with such an application.
Credit split is the system used by Drexel University to allocate return of IDCs to Schools and Colleges. At the time an application for external funding is submitted, all Drexel investigators included on the application will have been assigned a proportion of “credit” on the project. The total assigned credit must add to 100%. The Principal Investigator is responsible for assigning the credit split among all participating investigators and providing her/his Business Administrator with the final credit split distribution. The credit distributions are entered into COEUS at the time the proposal is submitted (see here for more discussion on submitting proposals through COEUS). Even if an application carries no indirect costs, you are still required to include credit splits in COEUS entries for that application.
Determining the credit split
The credit split is intended to account for the varying contributions (both intellectual as well as human and other resources) participating investigators will bring to the project. The Principal Investigator is expected to negotiate the credit split with the other investigators and come to agreement in advance of the proposal being submitted. As part of the proposal review process in COEUS, the credit split is reviewed by all investigators’ department heads and deans. If a department head or dean is not in agreement with the split documented in COEUS, the COEUS proposal will need to be rejected, so the new credit split can be quickly re-negotiated and re-routed for approvals.
The University does not have guidelines for determining credit split. The SPHRO suggests its principal investigators consider the following when developing a credit split.
- As an exercise, for each grant year, assign all direct costs to the investigator most responsible for assuring that the resources associated with those costs are appropriately applied (split costs as needed – for example, if a research staff member is to be jointly supervised, split the personnel costs between the two investigators). Sum the direct costs assigned to each investigator over the project and divide each by the project’s total direct costs.
- Repeat the above exercise limiting to personnel costs only.
- Consider the difference in the two resulting distributions. (For example, the total direct cost distribution might be influenced by a large subcontract which could bring in proportionately less direct costs and require less oversight than other resources).
- Consider intangibles associated with implementing the project. (Perhaps a jointly supervised staff person will be based full-time in space at only one of the investigators departments).
- Consider the origin of the research idea and the role investigators will play in driving the project forward.
Credit split for investigators with joint affiliations
When an investigator has more than one department affiliation, credit for that investigator should be further split across their departmental units. The Principal Investigator is responsible for recognizing that this must be done with all jointly-appointed investigators on a grant, and should discuss this additional allocation explicitly with those colleagues.
Adjusting credit split once a project is funded
If the credit split on a funded project needs to be modified from the original amounts that were agreed upon at the time of proposal submission (for example if an investigator leaves the University and is no longer involved in the project), this change is requested by the Principal Investigator, with help from their Department or Center administrator, through the University Office of Research Post-Award Administrator who will seek approvals from the departments and deans at all affected units.
Please note, if approved, the change will be implemented on the first of the month following the approved request. Credit split changes cannot be made retroactively so it is important that Principal Investigators anticipate changes that would prompt a credit split and seek approval as soon as possible.
Should you require to change the credit split for a fund, please complete the credit split change form, which is located here under Documents.
Voluntary committed cost sharing is discouraged. Certain funding opportunities have mandatory cost sharing requirements (i.e., PI salary may not allowed to be charged to the grant or when the federal salary cap is in effect). Cost sharing must be approved by the Department Chair, and may require approval at the School and University levels. When a proposal includes Cost Sharing, an account name and number must be entered into COEUS which will fund the cost sharing amount. For example, if an investigator is at the NIH Salary Cap, typically the home department will cover the cost sharing obligation for the difference between the effort requested and the amount eligible to be requested under the grant. As such, the 110100-69xx will be entered as the source of the cost sharing. During post-award, when the application is funded, a partnering account for investigator cost share will be established by ORA to track effort and commitments for compliance.
Guidelines for Nine-Month Appointed Faculty Budgeting Summer Salary on Research Grants/Contracts
Summer salary effort can be budgeted on a research grant for nine month appointed faculty if:
1) the proposed summer effort will be expended on project related work during the summer; and
2) the devotion of effort to the project during the summer is sensible, given the timetable and workflow of the proposed project.
Research budgeted summer effort should be primarily driven by project needs, not workload policy, self-funding expectations, or the opportunity to generate summer salary. Fewer competing responsibilities in the summer does create a reasonable opportunity to increase research effort above the effort being devoted during the academic year. However, a wildly disproportionate shift of effort from the academic year to the summer typically will not be justifiable.
Additional guidelines around budgeting summer effort are:
• There is no minimum academic year covered effort required before summer salary effort can be budgeted.
• The maximum budgeted summer effort (across all projects) is three months.
• If more than two total months of effort are budgeted, a letter must be submitted to the Department Chair attesting that vacation is being reduced (by the amount over two months).
• Effort should be budgeted in fractions of months as appropriate, and all funder guidelines must be followed. Summer salary can be distributed across 1 week in June, the full months of July and August, and 3 weeks in September, for a total of three months.
Additional guidelines for faculty who are above a funder’s salary cap:
• One-third of the amount above the cap will be covered by the faculty member’s discretionary account (1/3 by the Department and 1/3 by the School).
• If a faculty member does not have a discretionary account then he/she may petition their Department to cover the additional third.
Guidelines for Nine-Month Appointed Faculty Budgeting Discretionary Funds to Cover Summer Research/Scholarship Effort
Nine-month Appointed Faculty can budget discretionary funds to cover summer effort on research and scholarship that will support the near-term pursuit of external funding (grants or contracts). Budgeted summer effort should be driven by the need to complete research/scholarship supporting the development of competitive future grant/contract submissions, not opportunity to generate summer salary.
As with summer effort budgeted on grants/contracts, summer effort covered by discretionary funds must:
1) be expended on project related work during the summer; and
2) the devotion of effort to the project during the summer is sensible, given the timetable and workflow of the proposed project.
Examples of research and scholarship activities eligible to be covered by discretionary funds include:
• Developing a grant proposal
• Conducting research that will facilitate the development of a grant proposal in the near future,
• Completing manuscripts directly relevant to the submission of an application for external funding in the near future
• Other preparatory work (e.g. community activities of direct relevance) directly relevant to the submission of an application for external funding in the near future.
Other guidelines for budgeting summer salary with discretionary funds include:
• Coverage for service, teaching, or student supervision is not permitted.
• Discretionary funds cannot be used to support any compensated summer effort (from all sources) above two months.
• Effort should be budgeted in fractions of months as appropriate.
The Department and School must approve in advance the use of discretionary funds for summer salary. Faculty should submit a request to the Department Chair detailing the summer work plan, the summer effort required, and the planned timetable to future grant/contract submission. Once approved by the Chair, the plan should be forwarded to the School Research Office. The Associate Dean for Research will notify the faculty member, Chair, and Department Administrator of final approval. Department and School approval must be obtained before extra compensation can be requested (see below).
Requesting Extra Compensation
Nine-month appointed faculty with summer salary funded through grants, contracts, or approved use of discretionary funds must request extra compensation for this effort. The request for payment is submitted by the Department through an EPAF (electronic personnel action form). The EPAF must be submitted and approved prior to the 10th of each month that the extra compensation is scheduled to be paid. A separate EPAF must be submitted for each month that payment is requested and will specify all accounts from which summer salary will be drawn (1 week in June, July, August, 3 weeks in September).
For faculty salaries above a funder’s salary cap with summer salary budgeted on a grant/contract, all cost-sharing arrangements must be approved prior to submission of the research extra compensation EPAF.
Inflation should be included on all research proposals unless disallowed by the sponsor (Note: While NIH has issued statements indicating that they may reduce award amounts for purely inflationary adjustment, inflation adjustment, consistent with institutional policy, CAN and SHOULD be included in budgets). Currently, COEUS is programmed to adjust salaries at a 3% inflation rate effective on January 1 of each year for all personnel.
The fringe benefit rate to be included in proposal budgets is negotiated with the federal government and included in the University’s rate agreement with DHHS.
Full time regular staff
Part time staff
Currently not charged
These rates are applicable for all proposals regardless of the funding source.
Budget templates/worksheets are available on ORA’s website that have built in calculations for inflation and benefit rates.
A subcontractor (sub-recipient, sub-awardee) is an entity receiving a portion of the funds from a grant award that:
- Has programmatic involvement in the project identified by a separate scope of work, a separate budget and separate organization approval;
- Has a PI of the sub-award and who may be considered a Co-I, or multiple-PI, on the sponsored project with the PI at the home institution;
- Has its performance measured against the objectives set for the sub-award of the project;
- Has responsibility for programmatic decision-making;
- Has responsibility for adherence to applicable program compliance requirements;
- Uses the sponsored funds to carry out substantive aspects project at their institution as opposed to just to providing specific goods or services for a fee
- Has the right it publish project results or serve as a co-author;
- Has the option to develop patentable technology and to share in IP resulting from the project.
Drexel as the subcontractor
If Drexel is participating in a proposal as a subcontractor, the subcontract must still be routed in COEUS as a proposal. Standard elements (although specific list may vary depending on the prime applicant) include:
- Intent to establish a consortium (with PI and ORA signatures)
- Budget and justification
- Scope of work
- Facilities and resources
- Letter of support from PI
- Biosketches of Key Personnel, with personal statement
- Supporting documentation for IDC rate less than the federally negotiated indirect rate appropriate to the type of activity must be uploaded and be supported by the FOA or grant announcement (see IDC section).
Drexel as the prime applicant
If Drexel is the prime applicant with another organization as the subcontractor, the following documents must be collected in order to prepare the subcontract materials for COEUS routing with the rest of proposal materials:
- Subrecipient Commitment Form - completed and signed by subcontracting organization
- Subcontract budget and justification
- Scope of work
- Facilities and Resource Page for the Subcontractor
- Letter of support from subcontracting PI
- Biosketches for subcontracting key personnel
- Contact information for personnel from the subcontracting organization designated as key personnel (for completion of an NIH adobe package)
- Name and citizenship of any personnel from the subcontracting organization listed to be included in the export control section of COEUS.
Budget Implications: Sponsors may set rules on prime institutions charging indirect costs on subcontracts. For example, NIH allows indirect costs to be assessed on the first $25,000 of the subaward. No additional indirect costs can be assessed on a subaward during the approved period of the award under which it was issued. If there is additional funding beyond the originally approved period of the award (e.g., competitive renewal), then indirect costs can again be assessed, on the first $25,000 of each subaward. It is particularly important to keep this in mind when preparing proposal budgets.
Research related services can be performed by personnel outside the prime institution through relationships other than subcontracting. Typically this would involve personnel acting as a consultant or a vendor.
- Is an expert advisor;
- Is paid for time spent on a fixed hourly / daily rate basis;
- Is an individual using their own equipment and materials, not equipment or materials from their institution, for the work on the project;
- Is not employed by Drexel in any other capacity;
- Is not substantially involved in programmatic work on the project including project deliverables such as reports.
A vendor (individual or company):
- Provides goods and/or services ancillary to the project;
- Is paid a flat fee or a fee based on per unit (i.e., sample) charge;
- Provides similar goods or services to many different customers;
- Is not involved in programmatic work on the project; including project deliverables such as reports.
Indirect costs can typically be assessed on the entire amount of consultant and vendor costs, just as with most other direct line item costs. Consultants can be listed as key personnel on a project, although reviewers will typically want to see an appropriate level of effort for any consultants so designated.
Drexel requires documentation of potential financial conflicts of interest at the time a proposal is submitted. On US PHS-funded projects (including NIH grants), Financial Interest Disclosure Forms are required to be filed for all Drexel personnel responsible for the design, conduct, and reporting of research, regardless of the existence of a possible conflict. On other projects, disclosure forms are required only for individuals listed as Senior or Key Personnel. On PHS grants, typically all Senior/Key Personnel will complete disclosure forms as would other personnel involved substantially in the design, conduct, and reporting of research. Staff named in the grant who will not author reports and papers and who are involved minimally in data collection (i.e., data entry only) as well as named consultants not participating as authors or named advisory board members, do not have to complete disclosure forms. For those named individuals, a single document including the following language must still be uploaded in the institutional attachments section of COEUS:
“(insert name(s) & title) is not involved with the design, conduct or reporting of this project and thereby does not require a financial interest disclosure form.”
Any personnel with a significant financial interest to report, must disclose it on the Financial Interest Disclosure Form 2.
For personnel participating in a project as part of a subcontract through another academic organization, individual disclosure forms are not required. The subcontracting organization’s compliance with the US Federal FCOI regulations is verified in the Subrecipient Commitment Form (mentioned in the previous section).
Disclosure reporting should always be done at the time the proposal is first entered into COEUS because it will allow the proposal to move efficiently through compliance review and approval. Investigators are responsible for informing the University OR of any changes in their FCOI status.
Because institutional and individual training grant funding opportunities are limited and highly competitive, School of Public Health faculty are strongly encouraged to include doctoral students on research grants whenever possible. Not only is the integration of doctoral students in the research enterprise a critical component of their training, but also these external funds from research grants will be instrumental to the School’s sustaining and growing its doctoral education programs. The tuition that is included on research grants will be returned to the School as revenue and, in certain instances described below, can provide resources directly to faculty. The decision to include doctoral student on a research grant is up to the faculty member but the extent to which faculty include doctoral students (and doctoral student tuition, in particular) on funded research grants will be a critical determinant of the size and success of our doctoral programs in the long run - so it is of utmost importance that, when considering alternative uses for grant funds, doctoral support is given very high priority.
These guidelines are for faculty who are including doctoral students on a research grant application. They do not apply to training grants, which have their own rules and guidelines for budgeting. Training grants are discussed in the subsequent section.
Compensation for doctoral students required to be included in research grant budgets
When including a doctoral student on a research grant, compensation at the level indicated in this section should be budgeted before tuition is included (unless the funding mechanism has specific rules against funding student compensation). This assures fulltime students of a source of income and certain benefits and is also necessary to access Graduate College Tuition Remission Awards.
Doctoral students included on research grants are required to be budgeted to work year-round at a half-time level of effort.
In order to maintain their fulltime student status, doctoral students cannot work more than half-time. The requested salary for this effort should be equivalent to the NRSA predoctoral stipend based on the latest available guidelines (see Table below) with standard inflation adjustment for out years. If a faculty member wants to include a doctoral student on a research grant but the grant’s budget cannot support this level of effort and/or compensation, a Doctoral Student Funding Waiver needs to be submitted and approved (see below).
Budgeting for additional work during the summer term
A student can work additional hours beyond half-time during the summer term when they are registered for less than the fulltime 9-credit minimum. Under the new University policy, a doctoral student need only be registered for the 9-credit minimum for three of the four terms in an academic year to be considered a fulltime student for the year. Funding for this additional summer salary can be budgeted on a grant (as long as the total amount of salary and tuition budgeted does not exceed the total NIH cap on doctoral student compensation, see below).
Budgeting for fringe benefits
Currently Drexel University currently cannot charge fringe benefits on doctoral student wages, so no fringe is to be budgeted for doctoral student wages in any project years on submitted grants. The University will be renegotiating the doctoral student fringe rate for FY17. More guidance around this will be issued once fringe rates are renegotiated.
Additional notes for including doctoral student salary on NIH budgets
In preparing an NIH grant budget, doctoral students should be included in the Other Personnel section of the SF424(R&R) Budget Form as a “Graduate Students. Effort should be entered as 6 calendar months per included student (i.e., grants with 2 doctoral students would show 12 calendar months). If a modular budget is used, an equivalent amount of salary should be included in the Direct Cost total.
Doctoral student tuition required to be included in research grant budgets
Any grant including salary support for doctoral students should also budget tuition. As mentioned above, 100% of all tuition included in a research grant budget will be returned to the School as revenue. Under new University policy, all full-time doctoral students will register for 27 credits per year (9 credits per term for three terms) as long as they are engaged in full-time course work and/or research activity. It is expected that doctoral students will be engaged in full-time course work and/or research on campus for 3-4 years. Therefore, the annual tuition expense for a full-time doctoral student can be calculated by applying the annual per-credit graduate tuition to this 27-credit load.
In order to determine how much of this annual tuition should be included in a research grant budget, the School of Public Health policy is informed by NIH guidelines for the cap on total doctoral student compensation (wages plus tuition) allowed on research grants. Per NIH policy, this total amount cap is set at the level zero experience level stipend for a NRSA postdoctoral fellowship. Consequently, the maximum amount of tuition that can be budgeted on an NIH research grant is the difference between the total amount of salary charged to the grant and the NRSA zero experience level postdoctoral fellowship stipend amount.
For 2016: NRSA level zero experience level stipend– budgeted salary = maximum amount of tuition to be requested on federal grants (so for grants budgeted using the recommened doctoral student salary this amount is $43,692-$23,376=$20,316)
Because even this maximum allowable tuition amount will be significantly less than the total annual Drexel full-time doctoral tuition, the School will seek approval for any difference between budgeted and actual tuition to be covered by the Graduate College Tuition Remission Award program (and this remission amount should not be included in the grant budget).
This NIH maximum allowed tuition amount, though less than full Drexel doctoral tuition, is still considerable and faculty may find it challenging to include this full amount over and above doctoral student salary on research grants. Therefore, the School is requiring that at least 50% (see Table below) of the NIH maximum allowed NIH tuition be budgeted on research grants including doctoral students. However, faculty are encouraged to include more tuition whenever possible. In cases when the funder is not NIH, amounts above the NIH maximum allowed tuition can be included. When faculty include additional tuition above the SPH required minimum, 50% of the amount above minimum tuition will be returned to the faculty member’s discretionary account one year in arrears. However, student salary still must be budgeted before tuition can be included on a grant.
Summary of key amounts for grants being submitted in FY2016.
NRSA predoctoral annual stipend
NRSA postdoctoral 0-yr annual stipend
Drexel annual doctoral tuition
SPH required annual doctoral student salary
NIH maximum allowed annual tuition to be budgeted on research grants
SPH required minimum annual tuition to be budgeted on research grants
Waivers for including doctoral wages or tuition on research grants below SPH required amounts
If a grant does not allow tuition, has a cap on tuition below the SPH minimum required tuition, or if the PI wants to include a doctoral student on a project but is concerned that the budget, given other direct research expenses, cannot support the minimum required wages and/or tuition, a Doctoral Student Funding Waiver Form must be signed by the Department Chair and submitted to the SPH Office of Research for review at least two weeks (14 days) before the grant deadline. PIs interested in applying for waivers are encouraged to submit the Doctoral Student Funding Waiver Form as soon as possible.
What gets submitted through COEUS
COEUS routing and approval is required for:
- competitive applications to external funders for grants/cooperative agreements,
- non competitive research contracts
- sub-award agreements
- competitive renewals
- non-competitive renewals
- budget revisions (if change results in a difference of 5% or more from the total original budget that was originally routed and approved in COUES)
- certain internal funding proposals/pre-proposals
Note that other research-related documents that do not require COEUS routing, can still require University review/approval. These include:
- Consortium Agreements
- Consulting Agreements
- Cooperative Agreements
- Material Transfer Agreements
- Non-Disclosure Agreements and Confidential Disclosure Agreements;
- Research Teaming Agreements
All of these should be shared with the SPH Office for Research for further coordination with University OR Pre-award Administrator and other appropriate Drexel Offices (Privacy, OGC, IRB).
When a faculty member decides to develop and submit a proposal for research funding, they should inform, as soon as possible, the Department Business Administrator/Grants Administrator with the following application details:
- Due date
- RFA or other application guidelines
- Timeline for submission
- Approximate overall budget
The Business Administrator/grants administrator is responsible for notifying the department chair, SPH office for research, and ORA. The Business Administrator should send the notification via an MS Outlook invitation for the sponsor due date to the following individuals:
If multiple SPH departments are involved, the CO-Is, Business Administrators and Chairs should be included as well. The invitation should contain the following information (if known):
- SPH Investigator and CO-Is
- Link to opportunity or attach instructions
- Applicable IDC Rate
In addition to entering the IDC rate being used in a proposal, which should be in accordance with IDC guidelines, a proposal also must also indicate the base in which IDCs will be applied. There are two standard options:
- Modified Total Direct Costs (MTDC): Use this for most all federal and state proposals.Check the solicitation or ask OR Pre-Award.
- Total Direct Costs (TDC): Some foundations and private sponsors allow indirects on all costs, including tuition and subs >25k.Because the guidelines may vary significantly by sponsor, it is important to confirm directly with the sponsor or request that OR Pre-award confirm with sponsor.
COEUS Under-Recovery: If a sponsor limits the project’s IDC, then the under recovery value will show money we could have collected had we used our normal IDC.
“[The project cost with our normal IDC] – [The lower IDC for this proposal] = Under Recovery/Money we’re losing.”
In the screenshot below, you can see that we are charging a lower IDC rate because the under recovery value is 66,154. This amount shows what we could have collected had we charged the full research rate. This reflects how much the project actually costs the University.
The Under Recovery information is collected for internal purposes, it typically does not get sent to the funder, or referenced in the application materials. The University, college, and dept. needs to know how much a project truly costs in order to make strategic business decisions.
Budget Summary Screen in COEUS showing MTDC Overhead/Under recovery Rate Type with Under-recovery value
To assign credit split, go to the main proposal screen and select ‘credit split’ from the left hand side menu. The screen below will automatically populate with all named investigators on the proposal. The credit split screen will only populate with investigators’ home department. If the split should be assigned to more than one departmental affiliations, the additional department affiliation should be added in the investigator tab, when individuals are selected as investigators on the proposal.
In the example below, Bob and Mike split the credit on their proposal 50/50.
- 100% of Bob’s 50% is going to department 3801
- Since Mike has 2 departmental affiliations, 25% of Mike’s 50% is going to department 3801 and 75% of Mike’s 50% is going to department 3820
The RA count field should not be populated because it is no longer used to track anything internally within Drexel.
COEUS budgets should match the budget submitted to the Sponsor (with the exception of rounding discrepancies)
Each proposal goes through multiple levels of review and approval. Each reviewer (with the exception of the PI and co-investigators) has a primary and alternate/proxy reviewer designated in COEUS. It is anticipated that each approver will respond promptly (either by approving or requesting additional information) to proposals routed to them. Typical response times should be less than 24 hours.
The following chart shows the sequence of COEUS approvals for a proposal along with the role each approver plays in the application submission process.
Faculty should check with Department Chairs and Business Managers/Grants Administrators if Departmental level is needed prior to COEUS routing.
COEUS Approval level:
Investigators (PI, Co-Investigators):
All investigators are responsible for providing the necessary information for preparing the COEUS budget and all application materials (effort, credit split, science section, compliance information) within the established timeframe for routing.
By approving COEUS, Investigators are approving the content and associated documents in COEUS that will be submitted to the sponsor.
Business Administrator/Grants Administrator:
The Business Administrator/Grants Administrator is responsible for preparing the budget in COEUS and all elements needed for COEUS routing. The Business Administrator/Grants Administrator is responsible for ensuring an accurate COEUS record and managing the proposal through its timely submission, which includes assembling the application package, uploading it to COEUS and along with the PI, monitoring the progress of all approvals in COEUS.
ORA Pre-Award Review
Reviews budget, forms, compliance with funder and University policies, all forms, subcontract documents, etc. Provides feedback on all areas or approves without comment. This review should take about one day or less from receipt.
Approves proposed science, credit split, cost sharing, PI effort against other workload commitments (teaching, administrative roles), IDC & Under-recovery, summer salary, space, equipment and consistency with department policies.
SPH Office for Research:
Reviews all proposal content, budget and compliance with funder and school policies.
This is the final school level approval. This level approves overall budget, IDC/under recovery, credit split and potentially proposed science. In order for a proposal to be released by the University to the sponsor, this level of approval is required.
*ORA Review and submission
The proposal should now be ready for submission.
*The time stamp arrival at this level determines the applicability of the Proposal Submission Deadline Procedure
>/= three full business days = Compliant, successful submission
< three business days = Risky, possibly unsuccessful submission
If the proposal involves investigators from other schools or departments, the routing path will be longer as it will involve investigators/department managers/chairs and Deans of other schools.
It is required that at the conclusion of the submission process, the COEUS record shows “submitted” for proposal status so an institutional proposal number must be generated.
COEUS “Best Practices “ when multiple investigators/departments are involved:
If a proposal is initiated in one department, but involves investigators in other departments or schools within Drexel, the following steps are recommended:
- Business Administrator should connect with peer Business Administrator and alert them about the proposal. If help is needed identifying business point of contact, ORA can assist.
- Add the Business Administrator as an aggregator in COEUS.
- Ask them to add or confirm appointment level, salary for their faculty, certify FCOI, collect and share FCOI docs and obtain other Dept./School specific materials.
- Ask them to review the final budget and credit split prior to COEUS routing.
The University Office of Research (OR) has implemented firm deadlines for when proposals must reach their office. Complete COEUS records (including budget and all administrative items) AND complete applications (everything in final version, not draft!) must be received by OR a full three business days before a sponsor’s due date/time. “OR receipt” means that all COEUS approvals up to the SPH Dean’s level have been obtained and all application materials (pdfs, adobe grant package, or other relevant documents) must be uploaded to COEUS.
Here are a few illustrative examples of the proposal submission timeframe:
NIH Deadline for new R01 - Monday Oct 5 (crosses over a weekend)
NIH R01 Renewal Deadline: Tuesday July 5th (crosses over a holiday)
If a proposal is received by this deadline, OR staff will conduct a full administrative review and, for electronic submissions, will initiate as many submissions and will correct submission errors to assure the application is received.
If applications are not received by OR by this deadline then: 1) OR cannot guarantee submission and 2) if submitted, there may not have been enough time for a thorough administrative review of the proposal by OR staff and, therefore, OR reserves the right to refuse the award if it is selected for funding but subsequently deemed non-compliant. For electronically submitted applications, based on the actual receipt time, OR will make a pre-defined, limited number of attempts to submit:
- Less than 3 full days = 3 attempts
- Less than 2 full days = 2 attempts
- Less than 1 full day = 1 attempt
We recommend beginning routing all administrative items including final budget/justification and draft science for approval through COEUS as early as possible (> than 5 business days). The final science sections can be updated during routing. Be sure to allow more routing time if your proposal involves multiple investigators/depts./schools.
Be aware that if the budget needs to change during routing and the COEUS proposal has to be recalled, changed and re-routed – it could impact the timeliness of the submission.
To best prepare, we recommend that investigators do the following:
- Adjust their proposal preparation timeline to reflect the OR due date instead of the sponsor’s due date.
- Work with Department staff to finalize budget and justification as well as all administrative items early so that COEUS routing can get started.
- Keep in contact with CO-I’s, Chairs, Department staff and anyone else in the COEUS routing path.Let them know their prompt attention will be needed. Delays in COEUS approval can have significant consequences on your successful submission.
- Set up the VPN on mobile devices to quickly respond to COEUS requests.
Once all approvals have been obtained in COEUS, the proposal is ready for submission.
Most proposals are submitted directly by University OR through funder web portals. Many federal proposals are submitted through grants.gov (more information below).
Investigators should refer to the submission requirements in the funding solicitation and coordinate submission roles with the University OR Pre-award PA and Department Administrators to ensure a timely submission.
Submitting through Grants.gov
NIH and most other federal proposals will be submitted through Grants.gov. For NIH proposals, the Grants.gov application is further routed to eRA Commons. All PIs submitting an NIH proposal must have a Commons Login.
The University OR pre-award administrator is responsible for actually submitting the proposal; however, Department Administrators and PIs should stay in close touch with OR pre-award staff during the submission.
Errors and Warnings During eRA Commons and Grants.gov submissions
During electronic submission it is common to receive warnings and error messages that something needs to be addressed.
The word error is used to characterize any condition which causes the application to be deemed unacceptable for further consideration. Generally, errors will indicate significant inaccuracies, inconsistencies, omissions, or incorrect formatting that have been identified in the body of the application. The pre-award administrator at OR will contact the PI and the Department Administrator to inform them of changes required. The pre-award administrator will often be able to correct some of frequently flagged administrative errors independently (ie, missing or incorrect FWA number, extra spaces in some text boxes).
Conversely, the word warning characterizes any condition that is acceptable, but worthy of bringing to the applicant’s attention. It is at the applicant’s discretion, whether a warning condition requires any action. Errors must be corrected. Warnings do not need to be corrected.
Successful electronic submission
Upon successful submission of a proposal through grants.gov, the pre-award administrator will send the PI, Business Administrator and SPH RO an email confirmation that the proposal was successfully submitted. However, a PIs responsibility is not complete until they have logged into commons to review their proposal to ensure everything looks as intended. During the transmission of the grant, problems can occur and figures and other pages can become distorted. It is prudent to review and confirm that the proposal is intact upon review of the image in eRA Commons.