Preparation and submission of proposals for sponsored funding, most commonly research, is regular, ongoing activity for faculty. Proposal writing is part of a faculty member's appointment and time spent in preparation of the proposal must be compensated by the University using non-sponsored funds.
Writing a Proposal and Compensation
There is no guideline or directive from the UW (or the Federal government) on the minimum appropriate effort required for grant writing.
- Effort devoted to proposal preparation varies broadly by faculty member and the type of proposal (e.g. new, renewal, supplement).
- The level of effort should be based on each faculty member's individual situation and actual experience.
- Effort devoted may vary from proposal to proposal.
There may be times when a faculty member can prepare a proposal when they are not being compensated by the University. This may occur during a pay period when they are clearly not being paid from either grant and contract funds or non-grant funds paid through the University. For instance, a faculty member with a 9 month appointment may have one or two pay periods in the summer when they are not being compensated by the UW.
Generally, any departmental/school sources including, but not limited to, indirect cost recovery, gifts, endowments and state funds may be used to fund proposal preparation time and funding should be consistent with the percent effort spent on the proposal preparation.
Non-federal grant funding cannot be used to support grant writing unless specifically permitted by the sponsor. While not all non-federal grants and contracts are subject to the same rules as federal grants and contracts, the University is still bound by the cost accounting standards and the issue of consistency in how costs are classified.
Proposal preparation costs are specifically noted in the Code of Federal Regulations, Title 2, Subtitle A, Chapter II, Part 220, J10 (formerly OMBi Circular A-21i) as indirect and the University must be consistent in classifying them as such.
- Indirects may not be charged to Federally funded grants
- K Awards are an exception. See Proposal Preparation and K Awards
In addition, it could be viewed as a violation of the University's fiduciary responsibility to expend the non-federal sponsor funds in a manner that does not directly benefit the project they are intended to support.
Minimum Level of Effort
Federally funded research programs are expected to have some level of committed faculty or senior researcher effort, paid or unpaid (i.e. cost shared) and this must be noted in the application.
Most sponsors will accept the level of involvement of key personnel to reflect "as needed" except the National Institutes of Health (NIHi). NIH defines key personnel as the PI and other individuals who contribute to the scientific development or execution of a project in a substantive, measurable way, whether or not they receive salary or compensation under the grant. Therefore, an "as needed" level of effort is not acceptable for NIH grants.
- There is not a required minimum level of effort.
- It is required that the effort be measurable.
NIH grants now have an "Other Significant Contributors" field available. This allows the PI to identify individuals who have committed to contribute effort to the scientific development or execution of the project but are not committing specified measurable effort. In these cases, "participate in the design of test methodologies" or "as needed" should be used in the proposal instead of dollars and/or percentages.
100% Sponsored Funded Research Faculty
Care should be taken with faculty funded at 100% on sponsored research during periods of time, e.g. FEC cycles, when they are writing a proposal. Faculty should consult with their department administrator and/or chair to determine the source of funding for the effort required to complete the proposal. Department or college administration is responsible for assuring the provisions for funding these costs are in place.
NIH, in consultation with the Office of Management and Budgeti (OMB), has confirmed that limited charging of bid and proposal preparation, as a direct charge to a K Award, is allowable since it is the goal of these awards to train young investigators in all phases of research including preparing proposals.