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Proposal Review Guidelines

The proposal review guidelines define the level of review performed by OSP based on the date the proposal was submitted to OSP vs. when the proposal is due to be submitted to the sponsor.

Proposal Review Guidelines

Your science/technical content does not have to be complete when you submit to OSP. You can keep working while OSP reviews the rest of the proposal. 
*A full business day is an official Cornell workday between 8:30 a.m. and 5:00 p.m.

MATTERS ENCOMPASSED IN THE REVIEW
(◉ = OSP will review)		FULL REVIEW
If provided to OSP ≥ 5 full business days* before the proposal submission deadline:		LIMITED REVIEW
If provided to OSP < 5 and > 2 full business days* before the proposal submission deadline:		NO REVIEW
If provided to OSP ≤ 2 full business days* before the proposal submission deadline: (Review for Institutional Risk Only)		COMMENTS
A. Sponsor Analysis/Review
◉◉ For non-routine sponsors, OSP will assess the organization's fiscal and operating status. This may include obtaining a Dun and Bradstreet report for the sponsor to help determine financial and other risk to Cornell University before entering into a contractual relationship.
  
B. Internal Notification and Consultation with Other Administrative Offices
◉◉ OSP frequently engages other Cornell administrative offices when consultation is required to help interpret sponsor guidelines, when non-routine terms and conditions appear in a solicitation, when the scope of work or budget are complex, involve risk or require pre-award compliance permissions. The following offices provide guidance to OSP on matters of relevance to their subject area expertise: General Counsel, Risk Management & Insurance, Cornell Center for Technology Licensing, Office of Research Integrity and Assurance, and Sponsored Financial Services.
 
C. Sponsor's Guidelines**
1. Presence and nature of terms and conditions◉◉ OSP reviews the sponsor's guidelines/solicitation to determine if terms and conditions are present.  If present, OSP must review them to determine if Cornell can accept them.  Often, OSP will provide a cover letter objecting to specific terms and reserving the right to negotiate an agreement with terms and conditions aligned with Cornell policy. If the terms and conditons are unacceptable, and non-negotiable, OSP will be unable to submit the proposal.  
2. Limitations on the number of applicants◉◉ Some sponsors limit the number of nominations or proposals that Cornell (including Weill Cornell Medicine) may submit to a particular program. These special limited submission competitions are coordinated by the OSP. The Research Advisory Committee reviews the nominations/proposals received and then selects the submissions to go forward based on how closely the proposed research matches the sponsor's interests and thus has the best opportunity for success.  OSP reviews sponsor guidelines to ensure that if a competition is limited, proposals are first routed through the internal selection process and only those selected are submitted.
3. Submission method and deadline◉◉ OSP reviews sponsor guidelines to determine the method of proposal submission and the deadline date and time the submission is due.
4. Certifications and assurances◉◉ OSP reviews the certifications and assurances required by the sponsor and assesses Cornell's ability to accept and comply with these requirements.
  
D. Research Administration Support Services (RASS) entry
The Research Administration Support Systems (RASS) facilitates creation of project records and internal approvals for sponsored programs. A new RASS project should be created and completed for all new proposals. 
 
The RASS proposal record serves multiple functions. First, it provides OSP with information on when and where to submit the proposal and key information about the proposed project (duration, amount requested, the inclusion of subrecipients, etc.). Second, it provides the university's compliance units with research compliances required for the project (e.g., animal use, conflict of interest, foreign activities, etc.). Many of the unviersity's compliance modules are integrated with the RASS record. RASS also serves as a repository for documents associated with the proposal. And lastly, it allows Departments and Colleges to review and approve commitments of resources made by their investigators.  
 
In the event that a proposal is awarded by the sponsor, RASS will also serve as the official record for the award and its associated supporting documents.
1. RASS proposal record complete◉◉◉OSP reviews each proposal record submitted via RASS to determine if all required fields and questions have been completed. Required data includes but is not limited to project title; proposal type; submission method; sponsor & funding opportunity information (including deadline date and time); key personnel; budget (direct & indirect costs broken down by year); uploaded budget justification; cost share information (if applicable); project function; F&A rate; complete subaward proposal records (if applicable); responses to project income, screening questions and compliance questions; uploaded proposal document or eRA system location.
2.  Attestations and approvals are present and correct◉◉◉OSP reviews each proposal record in RASS to ensure the Principal Investigator(s) and co-Principal Investigator(s) attestations are complete, and their  Department Chair(s)/Unit Director(s) and/or his/her designee have completed the review and approval process in the system.
3. Data consistent with the proposal◉◉ OSP reviews each RASS project record and compares the data there with the associated proposal to ensure consistency between the two documents.
 
E. PI Eligibility
1. Approvals for non-eligible PIs◉◉◉OSP determines if the PI is elgible to serve as a PI on a sponsored project, in accordance with Cornell policy. If the PI is a full time member of the Faculty, he/she may serve as PI/Project Director on sponsored programs. Individuals with certain other titles may serve under special circumstances with the approval of the Vice President for Research and Innovation. A requirement will be added to the RASS record for any PI(s) whose position/title requires additional approvals to serve in this capacity. For details on the policy please see this webpage: https://researchservices.cornell.edu/policies/pi-eligibility&nbsp;
 
F. Institutional, Federal, and State Compliances
1. Conflict of Interest/Conflict of Commitment◉◉◉OSP determines if the PI, and other key personnel named on the proposed project, have completed their annual conflict of interest disclosure in accordance with the Cornell University Conflicts of Interest Policy and University By-laws.  
2. Human Participants◉  OSP determines if human participants will be used in the conduct of the sponsored project, and records the information in its system.  If an award is made, OSP cannot accept the award until an IRB approval has been granted to the PI for the conduct of the research. 
3. Animals◉  OSP determines if vertebrate animals will be used in the conduct of the sponsored project, and records the information in its system.  If an award is made, OSP cannot accept the award until an IACUC approval has been granted to the PI. 
4. Genetically Modified Organisms◉  OSP determines if the field-release of genetically modified organisms will be conducted as part of the sponsored project, and records the information in its system.  If an award is made, OSP cannot accept the award until the IBC has approved the field-release.
5. Radiation◉  OSP determines if radioactive materials or devices will be used in the conduct of the sponsored project, and records the information in its system.  If an award is made, OSP cannot accept the award until the Environmental, Health and Safety Office has approved the use.
6. Biological Agents and Toxins◉  OSP determines if biological agents of toxins will be used in the conduct of the sponsored project, and records the information in its system.  If an award is made, OSP cannot accept the award until the IBC has approved the use of these agents or toxins. 
7. Hazardous Materials◉  OSP determines if hazardous materials will be used in the conduct of the sponsored project, and records the information in its system.  If an award is made, OSP cannot accept the award until the Environmental, Health and Safety Office has approved the use of these materials. 
8. Foreign Activities◉  A series of questions are included in the RASS project record to document the inclusion of Foreign Activities (FA) on the project. When FA are included on the project additional approvals may be sought from the Global Operations and/or the Export Control Office.
9. Board of Trustees◉◉◉

OSP determines if Board of Trustee (BOT) approval is required. OSP is required to seek BOT approval for the following, and initiates the approval process immediately after a qualifying proposal is submitted:  

  1. New grants and contracts involving expenditure in excess of $10 million annually, prior to acceptance of the grant or contract.
  2. New or renewed grants and contracts when the project:
    • involves an annual allocation of University General Purpose funds of $250,000 or more.
    • involves a capital construction project of $500,000 or more.
10. Renovation/Facilities◉  OSP determines if renovation or construction of facilities are planned as part of the proposed sponsored project.  Consultation with Cornell's Facilities Services Capitol Projects and Planning division occurs when such projects are proposed.  
11. Stem Cells◉  If human embryonic stem cells will be used in the conduct of the sponsored project, such use is documented in RASS.  If an award is made, OSP cannot accept the award until the ESCRO Committee has approved the use of stem cells.   
12. Export Controls◉  OSP determines if the proposed sponsored project involves the transfer or disclosure of goods, technology, software, services, and funds originating from the United States to persons or entities in foreign countries OR to non-U.S. persons anywhere.  If the proposed project does involve one or more of the above export control issues, permits may need to be obtained from the federal government.
13. Background Intellectual Property◉◉ If required by the sponsor, OSP determines, in consultation with the PI, if the proposed sponsored project commits background intellectual property (IP). If the proposed project does involve background IP, OSP needs to assess its availability for use in any fore-ground and/or project IP developed as part of the proposed sponsored project. 
 
G. Proposal
1. Application package/form is correct◉  OSP checks the application package/forms used to ensure the correct version has been used and the forms have been completed accurately. 
2. Cover/Face Page◉  OSP reviews the cover/face page for accuracy and consistency with sponsor guidelines.
3. Abstract or Project Summary◉  OSP reviews the Abstract or Project Summary for consistency with sponsor guidelines.
4. Narrative/Research Plan/Scope of Work◉  OSP reviews the narrative/research plan/scope of work for consistency with sponsor guidelines and to identify risk, background IP, cost sharing, and instiutional, federal and state compliances relevant to the project.
5. Bibliography/References◉  OSP reviews the bibliography/references for consistency with sponsor guidelines.
6. Curriculum Vitae/Biosketch◉  OSP reviews the CV/Biosketch for consistency with sponsor guidelines.
7. Budget◉◉ OSP reviews the budget to determine consistency with 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards), specifically to assess if the proposed direct costs to be charged to the sponsor are allowable, allocable and reasonable.  OSP also reviews the budget to determine that the indirect costs charged to the sponsor have been calculated correctly and that the budget format is consistent with sponsor guidelines.
8. Budget Narrative/Justification◉◉ OSP conducts a side-by-side review of the budget justification and the budget to ensure that all direct and indirect costs identified in the budget have been sufficiently and appropriately justified in the budget justification.
9. Inclusion of appropriate F&A and fringe benefits rates◉◉◉ 
10. Resources & Facilities◉  OSP reviews the Resources & Facilities section consistency with sponsor guidelines.
11. Other Support/Current and Pending Support◉  OSP reviews the Current and Pending Support section and compares it to proposal and award data in RASS.
12. Appendices/Supplemental Documents◉  OSP reviews the Appendices/Supplemental documents for consistency with sponsor guidelines.
13. Subcontract Pan/MBE/WBE◉  OSP reviews the Small Business/MBE/WBE Subcontract Plan for consistency with sponsor guidelines.
  
H. Subaward Proposal
When a portion of the required effort of the proposed project is to be provided by one or more external institutions or companies (third party(ies)) who are made responsible for a discrete part of the project, a subaward proposal is required from the third party(ies) for inclusion in the Cornell proposal submitted to the sponsor. Subaward proposal record in RASS should be completed by Unit RA for review by GCO. Fields to be included are: Primary Info, Key Personnel, Budget (including budget periods, budget documents, justfication, F&A rate etc); Compliances, and Subaward Proposal Documents.
1. Letter of Commitment/Commitment Form◉◉◉OSP reviews the Letter of Commitment to ensure that the contribution of the third party is authorized by an instituitional or company official.
2. Scope of Work◉◉ 

OSP reviews the scope of work of the subrecipient to determine if the information provided sufficiently describes the proposed work, and corresponds with the proposal narrative. 

  • **LIMiTED REVIEW**: OSP will check for inclusion of scope of work at the limited review stage. No review of scope of work unless time permits.
3. Subaward Budget◉  OSP reviews the subrecipient's budget to determine if the direct costs are consistent with 2 CFR Part 200 (Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards), specifically if the proposed costs are allowbale, allocable and reasonable.  OSP also reviews the indirect costs requested and compares it to the subrecipient's federally negotiated indirect cost rate agreement.
4. Negotiated Rate Agreement◉  OSP reviews the subrecipient's federally negotiated indirect cost rate agreement if applicable. If the subrecipient does not have a negotiated rate, OSP reviews the indirect costs requested.
5. Subrecipient/Contractor Determination◉◉ 

Characteristics of a subrecipient include when the entity:

  1. Determines who is eligible to receive what Federal assistance
  2. Has its performance measured in relation to whether objectives of a Federal program were met
  3. Has responsibility for programmatic decision making
  4. Is responsible for adherence to applicable Federal program requriements specified in the Federal award
  5. In accordance with its agreement, uses the Federal funds to carry out a program for a public purpose specified in an authorizing statute, as opposed to providing goods or services for the benefit of the pass-through entity


Characteristics indicative of a contractor are when the entity:

  1. Provides the goods and services within normal business operations
  2. Provides similar goods or services to many different purchasers
  3. Normally operates in a competitive environment
  4. Provides goods or services that are ancillary to the operation of the Federal program
  5. Is not subject to compliance requirements of the Federal program as a result of the agreement, though similar requirements may apply for other reasons


All of the characteristics listed above may not be present in all cases, and OSP must use judgment in classifying each agreement as a subaward or a procurement contract.

6. Subaward Attestation (PI or RA)◉◉  
  
I. Data Security Plan (if applicable)
◉  If a sponsor requires an applicant to document how data used or generated by the proposed project will be protected and/or stored, OSP reviews the plan in accordance with sponsor guidelines, and often in consultation with assistance from Cornell Information Technologies (CIT).
J. Intellectual Property Management Plan (if applicable)
◉  Some sponsors require IP management plans when multiple parties collaborate and IP will result from the proposed project. OSP reviews the IP management plan in accordance with sponsor's guidelines and often consults with the Cornell Center for Technology Licensing.
K. Technology Control Plan (if applicable)
◉  The purpose of a Technology Control Plan (TCP) is to protect technical information which is specifically not identified as fundamental research or as educational information.  A TCP provides guidelines to ensure that the information is not transferred to a foreign person or persons unless approved by license with the Department of State, Office of Defense Controls (ODTC) or Department of Commerce as applicable.  OSP reviews the TCP in collaboration with the Export Control Office to ensure consistency with federal guidelines.
L. Related Agreements Review (if applicable)
◉  OSP reviews exisiting agreements related to a proposed sponsored project, such as non-disclosure agreements, material transfer agreements and research agreements, to identify and manage back-ground IP issues and potential conflicts of interest.

 

**Adherence to Sponsor Guidelines includes; among other things, length, margins, line spacing, font size, file name and type, required information provided (e.g., Broader Impacts Statement); eligibility criteria; etc.

 

Risk Assessment

# of Business Days Before Proposal Deadline
 		FULL REVIEW
If provided to OSP > 5 full business days* before the proposal submission deadline:		LIMITED REVIEW
If provided to OSP 3 or 4 full business days* before the proposal submission deadline:		NO REVIEW
If provided to OSP < 2 full business days* before the proposal submission deadline:
1. Risk of proposal rejection due to non-compliance w/ sponsor guidelinesLowMediumHigh
2. Risk of proposal rejection due to system failureLowMediumHigh
3. Risk of department/unit incurring financial burden due to budget errors or omissionsLowHighHigh
4. Risk of withdrawal of the proposal by OSP after submission and/or rejection of the awardLowMediumHigh