PROPOSAL APPROVAL AND SUBMISSION
This chapter describes the steps to completing and submitting a proposal through the following tasks:
- Limitations on number of proposals to one sponsor
- Timely submission
- Proposal brief
- Required signatures
- Smithsonian statement of organizational status
- Approvals, clearances, and compliance requirements
- Proposal transmittal
LIMITATIONS ON NUMBER OF PROPOSALS
A proposal may be submitted to one or more sponsors at the discretion of the Principal Investigator. Each proposal, however, must proceed through an internal process of review and signature by the unit director and the OSP Director before being submitted to a sponsor.
The following contains guidelines on submitting a proposal to more than one sponsor for:
- Federal agencies
- Private foundations
Federal Agency applications may ask if a given proposal has been submitted to more than one sponsor; this does not generally affect the proposal's chances for acceptance. However, some Federal agencies have imposed restrictions on accepting a proposal that has been submitted to other agencies. A Great and Contract Administrator in OSP will provide guidance on this matter.
Occasionally, program announcements or requests for proposals from private foundations contain a stipulation limiting the number of proposals that may be submitted by one institution to the sponsor. Either the Principal Investigator or OSP will coordinate the clearance process with the Office of the Provost for the optimum satisfaction of all parties.
To ensure timely submission the Principal Investigator and OSP work together during the proposal development, preparation, and approval phases, accomplished through:
- Avoiding administrative delays
- Planning time
Avoiding Administrative Delays
Before developing a proposal the Principal Investigator contacts his or her supervisor to obtain informal approval and unit/office support for the project. Issues of staff time commitments, space, and facilities are resolved at this time. If these issues are not resolved prior to the approval process, significant delays may occur.
If the project is complicated, involving hiring of additional staff or consultants, leasing of space, or entering into subcontract agreements, OSP staff should be consulted at an early stage from budgetary and administrative guidance and support. Some of these issues require liaison among OSP and other Smithsonian offices.
Start dates for a project may be determined by sponsor guidelines; however, Principal Investigators should plan for an average of six to nine months between the date of submission and the anticipated starting date for the project.
If a proposal is in response to an RFP, it is important that a copy of the RFP be provided to OSP for review prior to receipt of the proposal.
TIMELY SUBMISSION OF PROPOSALS
Responses to RFPS or special program notices must be sent to the address indicated in the RFP and must be received by the sponsor by the time and date indicated on the RFP. Sponsors have the option of rejecting late proposals. Because OSP reviews and approves many proposals each week and because revisions are frequently needed, Principal Investigators are encouraged to submit the final draft proposal to OSP at least one week in advance of the deadline for submission.
THE PROPOSAL BRIEF
Prior to submission, the technical and financial aspects of a proposal are subject to internal Smithsonian approval. The Proposal Brief Form, generated by OSP, secures these approvals.
The Proposal brief:
• Summarizes key information about the proposal
• Establishes that the proposal has been reviewed and approved
• Provides sponsor deadline dates
• Indicates direct and indirect costs
A copy of the Proposal Brief Form is provided in Appendix L.
One to two weeks prior to submission, the final copy of the proposal along with any forms and appendices is assembled for review and approval. Principal Investigators contact a Grant and Contract Administrator at OSP, who completes the Proposal Brief Form and assists the Principal Investigator in routing the completed proposal package through the internal review and approval process. When submitting the final proposal to OSP, Principal Investigators prepare the number of copies required by the sponsor plus one for OSP files.
PROPOSAL BRIEF ACCURACY
Principal Investigators should verify the accuracy of the Proposal Brief. OSP will enter the data from the Proposal Brief into the Grants Management Database. These data provide the basis for many internal Smithsonian reports.
Certain offices or committees within the Smithsonian must be notified of the proposed project. The Grant and Contract Administrator in OSP works with the Pricipal Investigator to ensure that all clearances have been obtained and that the proposal is complaint with all sponsor and Smithsonian requirements.
Once the Proposal Brief has been signed by all authorizing officials (discussed in the following section), OSP distributes a copy of the signed Proposal Brief to the Principal Investigator and any offices or committees that should be aware of the proposed submission.
As previously mentioned, the Proposal Brief must be signed by the following individuals:
- Principal Investigator
- Supervisor and Unit Director
- OSP Director
When a Principal Investigator signs the Proposal Brief Form, he or she approves the entire proposal and assumes responsibility for:
- The scope of scientific, technical, or programmatic effort
- Preparation of the required scientific, technical, or programmatic reports, if an award is made
- Management of the resulting award within the budget and time constraints provided in the proposal
- Documentation and certification to OSP of all mandatory cost sharing requirements
- Compliance with sponsor regulations and Smithsonian policies
Supervisor and Unit Director
The Principal Investigator must consult with the department head regarding the merits of the proposed project and the use of space and personnel. In signing the proposal, supervisors and unit directors certify that the research/academic scope of the project is sound, personnel and space are available, any cost sharing is appropriate, and the project’s goals are compatible with the policies and objectives of the Smithsonian.
All units involved must sign a project involving staff from more than one unit.
The Office of Sponsored Projects performs the final institutional reviews, ensuring that proposals conform both to Smithsonian policies and sponsor requirements, and that the business plan is sound. The proposal must always be approved and signed by the Director of OSP (or designee). The Director of OSP has been designated as Contracting Officer for sponsored projects by the Secretary of the Smithsonian Institution with delegated authority to submit proposals to external sponsors on behalf of the Smithsonian.
SMITHSONIAN STATEMENT OF ORGANIZATIONAL STATUS
The Smithsonian Statement of Organizational Status (see Appendix M) provides paragraphs that are included in all proposals submitted by the Smithsonian. This attachment describes the appropriateness of the Smithsonian to conduct sponsored projects in is capacity as a non-profit institution.
APPROVALS, CLEARANCES, AND COMPLIANCE REQUIREMENTS
As indicated on the Proposal Brief, some special approvals and notifications are needed before a proposal can be submitted. Sponsored projects involving such must adhere to Federal and Smithsonian policies and, in some cases, to the policies of the local jurisdiction where a Smithsonian unit is located. A complete listing of regulation and compliance issues are provided in Appendix N while the following most common issues are described in detail:
- Animal welfare
- Major wildlife laws
- Protected species and other regulations
- Bio-hazardous materials or radioactive materials
- Recombinant DNA
- Debarment and suspension
- Drug-free workplace
- Fellowships and stipends
- Human subjects
- Insurance issues
- International proposals
- Proposals to private foundations and corporations
- Scuba diving
- Standards of conduct
Proposals involving the use or study of vertebrate animals may require approval by the Institutional Animal Care and Use Committee (IACUC). Policy and procedures for protocol submission are detailed at Appendix O. Contact an OSP Grant and Contract Administrator for information on obtaining this approval. Note that several Smithsonian research units have established IACUCs: National Museum of Natural History, Smithsonian Environmental research Center, Smithsonian Tropical Research Institute and the National Zoological Park.
Some sponsors will accept proposals while the Smithsonian IACUC approval is pending. Such sponsors will require notification of IACUC approval before they will either review the proposal or make an award.. When a proposal is submitted with the IACUC approval pending, it is the responsibility of the Principal Investigator to ensure that, once written IACUC approval is received, a copy is forwarded to the OSP Grant and Contract Administrator. The OSP Grant and Contract Administrator will then notify the sponsor of the Smithsonian IACUC decision. The Principal Investigator should seek and obtain IACUC approval expeditiously so that the potential award is not jeopardized.
Major Wildlife Laws
The major wildlife laws regulating protected animals and plants include:
- Endangered Species Act
- Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES)
- Marine Mammal Protection Act
- Migratory Bird Treaty Act
- African Elephant Conservation Act
- Lacey Act (Injurious Wildlife)
The Principal Investigator should contact his/her unit registrar’s office for more information and guidance on the laws listed above.
Protected Species and Other Regulations
The U.S. and other nations have entered into international treaties and have passed domestic laws designed to preserve and conserve “an irreplaceable part of the natural systems of the earth that must be protected for this and the generations to come.” These laws limit, and often ban, commercial and certain scientific activities involving species in need of protection. Under certain conditions, exceptions to prohibited activities are allowed via Federal and/or state permits for scientific research, public display, enhancement of species propagation, or survival of the affected species. The wildlife permit system helps control illegal trafficking in wildlife and plants.
There are also regulations on wildlife and plants designed to protect human health and domestic animals and crops.
Wildlife laws cover animals and plants, live or dead, and parts and products made of, or derived from, the protected species. No matter how small the article or protected specimen may be, a valid permit may be required, and it must be obtained before beginning any regulated activity concerning a listed species.
Persons who have authority to collect or acquire specimens of behalf of the Smithsonian carry the responsibility of complying with all applicable domestic and foreign laws and regulations. Some examples of protected wildlife, and wildlife parts and products, include marine mammals, migratory birds, orchids, certain ethnographic objects such as drums made with certain animal skins, corsets with whalebone stays, picture frames inlaid with certain protected ivory, DNA and animal tissues. Some examples of other regulated wildlife include live bats and plant pests.
Permits may be required when:
- Lending or borrowing
- Arranging collections exchanges
- Accepting donations
- Collecting on public lands, in foreign countries or in international water
- Transporting objects across U.S. state boundaries, across any foreign borders, or on the high seas
The recipient also may need to see previous owner/lender’s permits if objects are being offered (cf: Lacey Act).
PERMITS AND REGULATIONS
For the most current information on permits and regulations, please reference the following websites:
U.S. Fish and Wildlife Service
National Marine Fisheries Service
Animal and Plant Health Inspection Service, U.S. Department of Agriculture
Centers for Disease Control, Public Health Service
Bio-hazardous Materials or Radioactive Materials
Proposals involving bio-hazards or radioactive materials require notification to the Office of Safety and Environmental Management(OSEM). OSP Grant and Contract Administrators provide guidance on proper notification to this office.
Proposals that involve the use of recombinant DNA require prior notification to an rDNA committee. An OSP Grant and Contract Administrator provides guidance in this process.
Debarment and Suspension
Before an award is made by the Federal government, the Smithsonian certifies that neither it nor its Principal Investigators are presently debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from covered transactions by any Federal department or agency. If a Principal Investigator is debarred or subject to any of the above, the Principal Investigator must inform the OSP Director.
When the Smithsonian receives Federal grants and contracts, OSP must certify implementation of the Drug-Free Workplace Act of 1988. Principal Investigators must comply with the terms of Smithsonian Announcement 89-95, which outlines the Smithsonian Drug-Free Workplace Policy.
Fellowships and Stipends
If a proposed budget involves a fellowship or stipend, OSP coordinates with the Office of Fellowships (OF) to budget the appropriate stipend amount. OSP notifies the Office of Fellowships about the submitted proposal by sending the OF a copy of the Proposal Brief and proposal.
Any proposal that involves human subjects may pose some inherent risks, including physical, psychological, or environmental harm. Examples of environmental harm include social, economic, and other consequences that result from breach of confidentiality. Adequate precautions must be taken to eliminate or drastically reduce these risks.
Proposals include a description of safeguards incorporated into the project that will minimize all such risks. Development on an informed consent form may be necessary.
Federal regulations in 45 CFR 46, Protection of Human Subjects, require the Smithsonian to submit to the sponsor a statement of specific assurance for each sponsored project involving human subjects. Therefore, each proposed project that is to be funded from sources outside the Smithsonian and that involves research on human subjects must be brought to the attention of the director of OSP.
If a proposals includes insurance costs, the PI must seek consultation from the Office of the Treasurer-Risk Management Division. OSP assists in the coordination with the Office of the Treasurer.
Proposals to foreign governments and institutions or proposals that contain an international component are brought to the attention on the Office of International Relations (OIR) and Office of the General Counsel (OGC). OSP Grant and Contract Administrators notify OIR by forwarding a copy of the signed Proposal Brief Form.
A project agreement (award) with foreign entity must be reviewed with both the Office of International Relations and the Office of the General Counsel before submission to OSP. See SD 804 for further discussion.
Proposals to Private Foundations and Corporations
Principal Investigators may not approach a potential private sponsor before contacting their unit development office of the Office of Membership and Development of clearance. This facilitates coordination of funding efforts throughout the Smithsonian, and expedites the award process should a project receive funding.
The Smithsonian Scientific Diving Office must be notified of any project that involves scuba diving activities. OSP sends a copy of the Proposal Brief to the Scientific Diving Office. Further information is available in Smithsonian Announcement 91-43.
Standards of Conduct
Principal Investigators have the primary responsibility of familiarizing themselves with the Smithsonian “Standards of Conduct” SD 103. They must act in accordance with these standards and seek guidance prior to engaging in any activity that may not be consonant with the principles or specific provisions set forth in this document. Such guidance is provided by unit directors and other supervisors and professional staff as well as the Ethics Counselors. Members of the Office of General counsel staff are Ethics Counselors for the Smithsonian.
OSP facilitates delivery of the proposal to the sponsor, including arrangements with personal courier or express mail service, when necessary. The final transmittal of the proposal normally includes:
- A cover letter with contact information and phone numbers (OSP for business questions and the Principal Investigator for technical or programmatic questions)
- The original signed proposal (including budget and appendices)
- Any additional required copies