Guidelines for Proposal Development & Administration

The title of a proposal often provides reviewers' first impression of a proposal. A title should be self-explanatory, describe the proposed project, express the end result of the project, and be easy to remember.

• Name and address of sponsor
• Name of the applicant or organization - University of Wisconsin-La Crosse
• Place of performance
• Title of proposed project
• Total funds requested
• Name and title of the PI/PD and co-investigators
• Name and title of authorizing UWL official - Director of Research & Sponsored Programs

While an abstract is not required by all funding agencies, it is a highly effective means of presenting a project to reviewers. Typically, an abstract is no longer than 200 to 250 words. It is a brief exposition that summarizes the objectives and significance of the project, the procedures to be followed in carrying it out, and the plans for evaluating the results.

If extensive introductory remarks are appropriate to "set the stage" for the specific proposal, you should devote a separate section to them. However, if only a brief introduction is necessary, it should be included as an introductory paragraph.

The description of the proposed project is an expansion of the abstract and constitutes the heart and soul of the proposal. It is a full and detailed explanation of the PI's proposed research plan and should include:

• A detailed description of the work to be undertaken;
• Its relation to both the present state of knowledge in the field and to comparable work known to be in progress elsewhere; and
• Justification that the proposed research is timely and critical. This section should include a clearly stated, detailed discussion of the methodology, goals, and objectives of the research.

References should be selected carefully, and generally only those that are discussed in the proposal should be included. Reviewers may be interested in assessing the relevance of the listed references to the proposed project. Carefully selected references can also help to establish the theoretical and/or practical foundation for the proposed project.

List professional personnel first, staff second, and part-time or student workers third. Professional and staff salary figures should include the percentage of effort or number of person months (per sponsor guidelines) reflecting the amount of time each person will devote to the proposed project. An individual's gross, full-time base salary should be used to calculate salary requested from the grant; refer to your monthly pay statement or contract. In the case of part-time or hourly personnel (such as students), the number of hours and hourly wage should be used instead. Annual merit and promotional rate increases should be included. Additionally, it is recommended that budgets include a 2%-3% salary/wage increase per year to cover cost of living increases. Refer to the Effort & Salary Calculator and Budget Guidance: Effort & Course Release for Extramural Projects for more information.

If support personnel and students who will work on the project are already employed by UWL, they may be listed by name. If not, the positions to be filled should be described along with an indication of the academic level or job classification desired. Naming a person in a proposal does not commit the institution to employment of that person and does not satisfy the requirements of open recruitment.

The following categories of personnel generally may be included:

• Principal investigator (PI)/program director (PD) (and, in some cases, co-PI/PDs)
• Other senior/key personnel
• Research or project assistants (e.g., undergraduate or graduate students engaged in research training under the proposed grant)
• Academic staff
• University staff (e.g., administrative support staff)
• Student employees

Only individuals employed by UWL should be listed in the personnel section of the budget for a UWL budget. External collaborators should be included as consultants or subrecipients as applicable (see separate sections of this guide for more information).

Consultants should not be included in this section but should instead be listed under "Consultant Services." UWL personnel, regardless of their project role, should not be listed as consultants but rather in the personnel section.

Generally, costs related to administrative support personnel should not be requested from a sponsor, but any individual specifically and significantly assigned to a project should be listed at the appropriate level of participation. Consult with ORSP to determine if a particular support position may be eligible to include in a budget request according to applicable policies and regulations.

Depending on the nature of an individual's proposed work, and a sponsor's guidelines, it may be appropriate to request summer salary support, partial release from university duties, or overload payment to complete the work. Any compensation for UWL personnel paid by grants or contracts is subject to the applicable sponsor regulations, State of Wisconsin and UW System policies, and UWL policies (e.g., UWL Policy on Overload Payments). Consult with ORSP for guidance on allowable project effort and compensation.

Fringe benefits, expressed as a percentage of salary, include items such as, but not limited to, Social Security, state retirement programs, health insurance, life insurance, and disability insurance. Per UW System policy, fringe benefits must be included in all budgets for extramural funding unless such costs are specifically excluded or restricted by the sponsor, in which case they must be covered by an alternate source (typically a PI's college/division). Fringe benefit rates are prescribed by personnel classification. Refer to UWL's current extramural fringe benefit rates. Multiple year proposals must include an estimated increase of 5% per year. New fringe rates are established and approved by UW System at the beginning of each fiscal year. Rates for other UW campuses can be found on the UW fringe benefits webpage.

Generally, equipment is defined as tangible, nonexpendable property having a useful life of more than one year and an acquisition cost of $5,000 or more per unit. (Note: Federal regulatory changes have redefined this threshold at $10,000 or more per unit; however the $5,000 threshold is used to determine the indirect cost base per UWL's current federal negotiated indirect cost rate agreement.) A “unit” may comprise multiple components that collectively function as a system. The best source of estimated equipment cost is a vendor quote. The cost of shipping, installation, and fabrication should be included in the cost of the equipment. Whenever possible, the PI/PD should specify the name, model number, and manufacturer of the equipment.

Permanent equipment is broken into two categories: special purpose and general purpose. The type of equipment most often purchased under grants or contracts is designated special purpose equipment because it is necessary to the research and is generally not available within or of general use to UWL. Justification for such equipment should be provided in the proposal.

General purpose equipment includes items such as office furniture, dictation/transcription machines, personal computers, etc. The purchase of general purpose equipment is allowed by some federal sponsors when it is primarily or exclusively used in the conduct of scientific research. However, it is heavily scrutinized, and requests should include extensive justification as to why the items are integral to the project objectives.

Generally, title to equipment purchased with grant funds is allowed to remain at UWL. However, the specific conditions of each grant or contract will govern.

Use the UWs Lodging & Meal Per Diem Calculator and Concur to estimate travel costs. Examples of travel support include conducting research at off-campus locations, meeting with collaborators, disseminating project results at academic conferences, and supporting travel costs for program participants. Domestic and international travel costs should be separately itemized. Rates in the UWs Lodging & Meal Per Diem Calculator represent maximum rates; lower rates can be requested if there is a reasonable basis for those estimates (e.g., lower lodging rates for extended stay accommodations).

Justification for travel costs should specify the purpose (e.g., conducting research, attending a meeting) and provide information such as:

• Name of traveler(s), destination , and reason for trip (including conference name, if applicable)
• Round-trip commercial coach airfare and booking fees (allowances for air travel will not normally exceed round-trip economy airfare)
• Number of days, meal per diem rate, and lodging costs
• Other expenses, such as ground transportation or conference registration fees

The purpose of each trip should be discussed in the proposal narrative and budget justification. Expenditures for travel must follow university and State of Wisconsin travel regulations.

If international travel is anticipated, additional justification may be needed, as such travel is typically more closely scrutinized by sponsors. If no provision for international travel was included in the original proposal, approval must be obtained from the sponsor and/or UWL (as appropriate) prior to the commitment of grant funds. Well in advance of undertaking international travel, individuals should complete the UWL Export Controls Survey and be aware of export controls requirements.

Participant support costs include items like stipends, subsistence or travel allowances, and registration fees paid to or on behalf of participants or trainees (but not employees) participating in conferences, workshops, seminars, symposia, or other training projects/activities. Participants do not include individuals who perform work or services for a project unless it is for their own educational benefit/professional development. Participant support stipends should not describe employment arrangements (e.g., required number of hours, hourly rate of pay).

There are multiple federal regulations, sponsor policies, and university requirements related to this cost category. Consult with ORSP for assistance. Also refer to the ORSP Payment of Incentives to Research Participants webpage and related Business Services policy.

Research participant incentives are not participant support costs and should be budgeted under supplies.

Any equipment or supplies needed for your project that costs less than $5,000 per unit should be listed under materials and supplies. This category may also include consumable items (e.g., office supplies, glassware, electronic supplies, laboratory supplies, chemicals). Identify as specifically as possible the types of equipment or supplies needed.

Publication costs are the expenses of preparing and publishing the results of the research conducted under the grant, including costs of reports, reprints, page charges, or other journal costs and necessary illustrations. Such costs do not normally include support of book or monograph publication.

Consultants are defined as external experts (not employed by the UW System) who work on a project for a limited duration and scope while providing a specific service (e.g., data processing, sample analysis, marketing services, website development, program evaluation) but do not exercise control over the achievement of any project objectives. The FDP provides checklists that support the determination of whether a collaboration meets the definition of a consultant (i.e., contractor) or subrecipient per federal guidelines.

A consultant should be identified by name and/or by their specialty; the number of person-days and/or hours of consulting and their daily rate should also be specified. Federal sponsors generally ask that PI/PDs:

• Hire consultants only when the services are necessary and cannot be provided by paying direct salaries to a current employee of the proposed project;
• Engage in an objective selection process designed to secure the most qualified individual; and
• Ensure these persons provide a "necessary and unique contribution" to the project.

Eligibility of individuals holding local, state, or federal positions to serve as paid consultants must be determined in advance. Employees within the UW System cannot serve within the system as paid consultants nor can employees of a federal agency unless they are on leave status. UW System employees can, however, serve as staff members on a project, in which case the appropriate fringe benefit rates must be included in the budget. Each UW campus has its own prescribed fringe benefit rates. Project personnel should work with their respective campus's sponsored programs office for budget and proposal development.

Where the costs of consultants are borne in whole or in part as direct costs by federal projects, the consultation must be documented by an invoice from the consultant. Any of the following information not shown on the invoice must be shown in a memorandum or other document signed by an organizational official: the name of the consulting firm or individual; social security number and home address of individual consultant; the nature of the services rendered and their relevance to the grant supported activities, if not otherwise apparent from the nature of the services; the period of the service; the basis for calculating the fee paid (e.g., rate per day, hours worked, or rate per unit of service rendered); and the amount paid.

Subawards are funds distributed to outside institutions/individuals that exercise control over the achievement of one or more project objectives. The FDP provides checklists that support the determination of whether a collaboration meets the definition of a consultant (i.e., contractor) or subrecipient per federal guidelines.

Subawards should appear as a line item reflecting the total subaward amount in the proposal budget with reference to an attached subrecipient's formal, detailed budget. PIs should document the reasons for choosing a particular subrecipient over others. For each subaward, a separate, itemized budget and budget justification must be provided to ORSP and the sponsor. Consult with ORSP on the additional documentation requirements for subrecipients. Sponsor-specific proposal development checklists, accessible via the How to Apply for Grants webpage, provide guidance on the documentation requirements for agencies UWL commonly applies to.

Some grants will allow for the payment of participating student trainees' tuition, segregated fees, and/or institutional allowances. Account for anticipated increases in these costs. Under UW System policies, training grants must equal or exceed tuition and fee costs per student; if a given grant or contract fails to do so, the difference will be charged to the individual students.

Where supporting sponsor guidelines and regulations permit, a budget may include appropriate amounts for costs such as freight charges, equipment maintenance and rental, reference books, and other costs specifically related to the project that may not fit within other budget categories. Generally, sponsors do not allow for costs categorized as "miscellaneous" without an itemized justification and description of estimated expenses.

Expenditures necessary for construction, remodeling, or rental of space and facilities should be explained in detail. The basis for this should be the estimates you receive from UWL's space management, remodeling, or planning and construction representative. If off-campus rental facilities are approved by UWL, the budget should include rent, utilities, custodial care, and other costs which may be incurred.

For rental of on-campus facilities, during budget planning, PIs should reach out to Reservations for facility and cost information. A facility rate sheet is also available.

Per UW System policy, indirect costs (a.k.a. overhead, facilities & administrative costs, F&A) are required for all extramural funding at the university prescribed rates. Indirect costs are real costs associated with the completion of a funded project. Extramural proposals must request indirect costs from the sponsor to cover expenditures such as administrative costs, maintenance of physical facilities, and utilities that are not readily identified with a specific project. In undertaking any funded project, whether or not it is sponsored by the federal government, UWL must recover two components of costs--those directly attributable to the specific project and those incurred for the general support and management of the project. Indirect costs are real costs. They provide reimbursements for expenses incurred in conducting or supporting the project. Funds paid to UWL for indirect costs of a sponsored project are reimbursement for expenditures actually incurred.

For non-federal grants/contracts, the PI/PD should include the applicable non-federal indirect cost rate unless the sponsor has specific, published, universally applied policies restricting indirect costs. Documentation of the sponsor's policy is required to request approval for the use of an alternate rate. Consult ORSP for further information.

For federal grants/contracts, the basic regulations for ascertaining the costs of federally sponsored projects at educational institutions are set forth in federal regulations. Annually, the UW System presents its expenditures in these categories and evidence regarding the proportion of these costs incurred as a result of its total research effort. This information is audited by representatives of the US Department of Health & Human Services (HHS) Audit Agency (the cognizant audit agency for the UW System), and the allowable rates of reimbursement are then established. Rates are calculated as a percentage of a project's modified total direct costs (MTDC). Refer to UWL's federal negotiated indirect cost rate agreement for more information.

If it is included, cost sharing is complex and requires proactive planning with project collaborators, department chairs/unit directors, deans/division heads, and ORSP well in advance of submission. Note federal sponsors generally do not allow cost sharing. All cost sharing requires written confirmation by an authorized representative, including an itemized list of commitments and estimated values, be submitted to ORSP prior to application submission. Consult with ORSP regarding cost sharing requirements and allowability. The UWL cost sharing template can be used to help plan and document commitments. Generally, cost share:

• Must be verifiable by UWL’s records post award
• Must come from non-federal sources 
• Can only be cited as cost share for one award
• Must be necessary and reasonable for the accomplishment of program objectives
• Must be an otherwise allowable cost per the sponsor guidelines

Sponsors may or may not require UWL to demonstrate its participation in the total costs of any project supported by a grant. In determining how or if UWL will share in the cost of a project, specific sponsor guidelines should be followed, as allowable types and requirements vary widely. Contingent upon sponsor guidelines and UWL approval, cost sharing may include cash and/or in-kind contributions.

Brief biographical sketches, including publications, of the PI/PD and the senior/key personnel involved are typically required. Sponsors generally have specific requirements for the content and format of key personnel's biographical sketches (e.g., NSF and NIH require biosketches to be generated using prescribed templates in SciENcv). A general template is available on ORSP's Federal Proposal Development webpage. Bio sketches are typically limited to 2-5 pages. In addition to addressing the individual's education, appointments, and other credentials, the document should generally note publications, products, presentations, inventions, collaborations, projects, grants, fellowships, and/or other work that is most relevant to the proposed project and highlights the individual's related expertise. Sponsors typically have required information that must be disclosed in bio sketches; review the solicitation and sponsor guidelines closely. The UWL Disclosures of Other Support policy provides additional guidance.

Some sponsors require all senior/key personnel to submit information related to their current and pending funding and other commitments to assess individuals' capacity for the proposed project, conflicts of commitment, and potential scientific and budgetary overlap/duplication with the proposed project. Each sponsor has their own required format and content for this information (e.g., NSF requires it be generated using SciENcv). Some sponsors require this document to be included with the initial proposal (e.g., NSF), and others will not require it be submitted unless a proposal is likely to be funded (e.g., NIH). The document typically summarizes all current extramural and internal support and other pending applications of the senior/key personnel, including the application under development, consulting activities, in-kind contributions, and contracts and funding with international entities. For each item listed, the following information is generally required: project title, status (e.g., current, pending), proposal/award number, source of support, primary place of performance, project start and end dates, total award amount, person months per year devoted to project, overall objectives, and statement of potential overlap. The NSPM-33 Implementation Guidance provides an overview of items that must be disclosed for some federal sponsors (e.g., NSF). The UWL Disclosures of Other Support policy provides additional guidance.

A Data Management Plan (DMP) generally should describe how a proposed project will manage related data, share research results, and conform to a sponsor's policies on the dissemination and sharing of research results. Typical sections in a DMP include research products, data format, data archiving, data access and sharing practices and policies, and policies for re-use, re-distribution, and production of derivatives. The DMPTool provides a wide variety of publicly available templates based on various sponsor requirements. In considering where research data may be shared, refer to the Registry of Research Data Repositories. See the sponsor-specific guidance for full requirements (e.g., NSF Preparing Your Data Management & Sharing Plan, NIH Scientific Data Sharing).

Some sponsors ask for a document summarizing the existing institutional facilities, equipment, and other resources (such as personnel and expertise) available to support the proposed project. Several templates for this document are available on ORSP's "How to Apply for Grants" webpage.

Sponsors generally do not require a specific citation format (e.g., APA, MLA, Chicago) and allow the references cited/bibliography section of a proposal to follow disciplinary standards. This section should not include materials that attempt to circumvent page limits for other proposal sections. For example, do not include hyperlinks to other supplementary materials required for reviewers to understand information contained in the proposal narrative. Reviewers are not required to read such supplementary information included in this section.

Sponsors may or may not allow additional information to be submitted as one or several appendices to the application. Follow sponsor guidelines. Generally, you should be mindful that reviewers are often not required to review information submitted in an appendix. Appendices should not be used to circumvent an application's page limits.

Before a grant application can be submitted to a sponsor, all materials must be reviewed and approved by the applicable department chair(s)/unit director(s), college dean(s)/division director(s), and ORSP. Federal proposals additionally require Provost/Vice Chancellor approval and potential prior review by UW Office of General Counsel (refer to UWL federal review requirements). The PI/PD needs to allow sufficient time for on-campus review, processing, and approval of proposals. At minimum, application components should be routed for review according to the proposal review & approval timeline outlined on the How to Apply for Grants webpage. Adequate time for institutional review and approval is not guaranteed for materials received after these deadlines. Contact ORSP to determine whether an application can be accommodated. 

Applications submitted prior to full institutional approval may be withdrawn. If funded, award acceptance for such applications will be contingent upon institutional review and approval. If award conditions or aspects of the proposed project do not meet institutional requirements, the award will be declined. Individual PIs/co-PIs are not authorized to sign off on application components on behalf of the university; applications must be reviewed by appropriate personnel and approved by signatories designated by UWL leadership.

Each proposal for extramural or UW System/WiSys funding must be approved by the PI's/PD's department chair or unit director, the college dean or division director, and ORSP before it is submitted to the funding agency. Federal proposals additionally require approval by the Provost/Vice Chancellor and potential prior review by the UW Office of General Counsel. Proposals that involve more than one department/unit, school, or college/division must be reviewed and approved by each respective UWL personnel's chair/director and dean/division director. These approvals are documented via the Research Administration Management Portal (RAMP). Applications must at minimum be routed with a final budget and budget justification (i.e., approved beforehand by ORSP) and a reasonably complete draft narrative. The approval process assures that appropriate university officials have reviewed and approved each proposal in accordance with university, sponsor, and other applicable policies and regulations. It also provides the basic UWL record of the processing transaction. Additional details on the review and approval process can be found on the How to Apply for Grants webpage.

The terms "Principal Investigator" (PI) and "Project Director" (PD) are often used interchangeably to designate an individual who has the responsibility for seeing that proposals are submitted and that sponsored projects are carried out in compliance with the terms, conditions, and policies of both the funding agency and UWL, including the submission of all required narrative and technical reports.

A project is generally conceived of and carried out by the PI/PD, who manages the funds entrusted to them to meet the project goals. As the person primarily responsible for the day-to-day management of a project, the PI/PD must be alert to both university and funding agency requirements. Prior to proposal submission, the PI/PD certifies agreement with all applicable university, state, federal, and sponsor regulations and policies via the PI/PD certification in RAMP. Co-investigators are also required to complete the certification.

Additional information about the PI/PD's responsibilities for post award administration can be found in this section of the External Award Management webpage.

The PI's/PD's department chairperson or unit director shall:

• review the proposal to assure that faculty and staff time commitments are reasonable and compatible with department workloads, present and planned;
• determine that the percentages of time and the salaries are accurate; and
• agree that the space, facility, and service requirements are within the department's present capability if not specifically provided for in the proposal.

The department chair's/unit director's certification of the items above is designated by their certification in RAMP.

The PI's/PD's college dean or division director shall review the proposal for completeness and to confirm that:

• space, services, and support requirements have been adequately provided for;
• responsibility will be accepted for assuring the availability of cost sharing promised in the proposal; and
• the project budget, salary rates, job titles, classifications, and committed effort are reasonable and appropriate.

In addition, it should be ascertained to what degree this proposal will commit the college or school to long-term support of project personnel or to a program which may evolve from the project.

The dean's/division director's certification of the items above is designated by their certification in RAMP.

Per the policy of the Universities of Wisconsin Board of Regents, the chancellor or their designee(s) can enter into grant and contract arrangements on behalf of the institution (refer to the contract administration website for more information on authorized contracting personnel). As the chancellor's designated representative for extramural funding arrangements, the Director of Research & Sponsored Programs shall review the proposal for compatibility with the appropriate university plans, policies, and regulations as well as for conformity with agency requirements and policies. Their approval is documented via the final review certification in RAMP.

A chemical is defined as any element, chemical compound or mixture of elements and/or compounds. These materials can pose a variety of hazards, including but not limited to: toxic to humans and/or environment, fire and explosion. PIs/PDs should be prepared to identify all chemicals that will be used. The chemical identity can be completed through provision of a Material Safety Data Sheet (MSDS).

Physical hazards are defined as excessive levels of electromagnetic and ionizing radiations, noise, vibration, and extremes of temperature and pressure.

Research and instruction which require the purchase, possessions, or production of radioactive materials are subject to the provisions of the UWL license under the State of Wisconsin Department of Health and Family Services as an agreement State. All investigators are responsible for adhering to the requirements for training, sign posting, reporting and good laboratory practice as specified in the license.

UWL must additionally adhere to US Environmental Protection Agency (EPA) regulations which establish minimum requirements for documentation, storage, and shipment of hazardous waste. 

PIs/PDs involved in research or use of chemicals or physical hazards should contact Environmental Health & Safety to assist in obtaining all required reviews and approvals. These approvals must be obtained before project work can begin but do not necessarily need to be completed before an application is submitted to a sponsor. See Chemical & Physical Safety and Environmental Health & Safety for more information.

Export controls are federal laws that govern the export of certain items and information out of, into, and within the US in the interests of US national security, economic competitiveness, international treaties, and foreign policy. An export is the transfer/disclosure of items, materials, information, software, technology, or other unclassified but restricted data to any person outside the US, including a US citizen abroad. (OFAC also includes any services in its export definition, and ITAR includes defense services.) “Export” means not only the physical shipment of items from the US to a foreign country but also the release of controlled technology to foreign persons within the US by way of visual inspection, oral transmission, or training (“deemed export”). For the purposes of export control laws, a foreign person/organization is any person/entity who is not a: 

• US citizen 
• US permanent resident alien (“green card” holder)
• Protected political asylee/refugee 
• US government agency or state/local government 
• US business 
• US university 

UWL faculty, staff, and students planning to carry out activities that involve any of the following should fill out the UWL Export Controls Screening Survey well in advance of planned activities:

• International travel
• Work with foreign collaborators (faculty, staff, students, or others) or organizations (domestically or abroad)
• Sharing, exchanging, transporting, or shipping information, supplies, research materials, or equipment with foreign individuals or organizations (domestically or abroad, virtually or in person)

The survey provides an initial screening of activities to help assess potential risks and compliance requirements that may apply.

Export controls screening must be completed well in advance of when the activities will take place, but it is not necessarily required before a proposal is submitted. Consult with ORSP on specific requirements.

For additional considerations for international collaborations and programs, refer to ORSP's guidance and the Business Services Export Controls & Foreign Countries of Concern FAQs.

To ensure compliance with federal regulations, before submission, all applications for federal funding, including subawards and federal flow-through funding, require all UWL investigators to complete a significant financial interest (SFI) disclosure form. The policy also applies to non-federal sponsors with FCOI requirements and research contracts with non-federal entities. The policy applies to all types of extramural funding mechanisms, including but not limited to grants, cooperative agreements, and sponsored research contracts. See the FCOI webpage for a summary of the requirements and items that need to be disclosed. The policy also applies to non-federal sponsors with FCOI requirements (e.g., Alliance for Lupus Research, American Cancer Society, American Heart Association, Arthritis Foundation, Juvenile Diabetes Research Foundation, Lupus Foundation of America, Susan G. Komen for the Cure).

If applying to a Public Health Service (PHS) agency (e.g., NIH) or a non-federal sponsor that follows the PHS FCOI regulation, there is an additional FCOI training and assessment requirement for all investigators. As defined by PHS, investigators may extend beyond a project's PIs and co-PIs to include students, subrecipients, consultants, and/or other collaborators. Refer to the UWL Identifying Investigators resource for help determining who may constitute an investigator on a particular project. There are also FCOI requirements for external collaborators named in PHS agency applications. Refer to the UWL FCOI webpage for further information. 

The Harassment & Assault Reporting policy aims to promote safe, productive research and education environments for all individuals. It further assures compliance with related federal award terms and conditions. The policy applies to all federally funded awards, subawards, and funding amendments to existing awards administered by UWL that are received on or after October 21, 2018; the policy additionally applies to non-federal awards with related requirements incorporated in award terms and conditions. UWL, in solidarity with federal sponsors, will not tolerate sexual harassment, other forms of harassment, or sexual assault anywhere research or education is conducted. To support this, UWL has established the reporting requirements below. These requirements are established in addition to UWL’s institutional policies and procedures prohibiting and addressing discrimination, harassment, sexual misconduct, and retaliation (please refer to the UWL Office of Civil Rights & Compliance website for further information). This policy is distinct from Title IX regulations.

Projects involving vertebrate animal subjects are subject to IACUC requirements. Protocols must be approved before project work can begin but not necessarily before an application is submitted to a sponsor. See the IACUC website for more information.

Additionally, some federal sponsors (e.g., NIH, NSF) require IACUC congruency review before award issuance and before project work begins, which is completed by the UWL IACUC Coordinator and recorded by ORSP. This ensures the approved protocol(s) aligns with the research outlined in the application. The PI/PD is responsible for initiating the review. To allow for potentially required protocol revisions, it is strongly recommended a PI initiate the process after application scores are received if a high score indicates funding is likely. Contact ORSP for further guidance.

Projects involving biological materials that entail a potential risk to humans, animals, or the environment are subject to IBC requirements. The IBC reviews and monitors activities involving materials such as recombinant or synthetic nucleic acid molecules; microorganisms and viruses; infectious agents or pathogens; biological toxins; human-derived tissues, fluids, and cells; non-human animal-derived tissues, fluids, and cells that are infectious, potentially infectious, or recombinant; genetically modified live animals; or other biological materials that may be toxic to living organisms. The IBC ensures compliance with the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules and other biosafety requirements, such as the CDC Biosafety in Microbiological and Biomedical Laboratories (BMBL). Roles and responsibilities, biosafety requirements and best practices, and general biosafety information can be found in the UWL Biosafety Manual. Protocols must be approved before project work can begin but not necessarily before an application is submitted to a sponsor. See the IBC website for more information.

Projects that involve human subjects, data, or specimens are subject to IRB requirements and must have approval from the IRB committee before project work can begin. While an IRB protocol does not need to be approved before an application is submitted to a sponsor, it is strongly recommended PIs/PDs begin the process as soon as possible to ensure adequate time for review. See the IRB website for more information.

Additionally, some federal sponsors (e.g., NIH, NSF) require IRB congruency review before award issuance and before project work begins, which is completed by the UWL IRB Coordinator and recorded by ORSP. This ensures the approved protocol(s) aligns with the research outlined in the application. The PI/PD is responsible for initiating the review. To allow for potentially required protocol revisions, it is strongly recommended a PI initiate the process after application scores are received if a high score indicates funding is likely. Contact ORSP for further guidance.

Extramurally funded scholarly projects are subject to UW System Administrative (UWSA) Policy 346: Patents and Inventions. UWL faculty, staff, and students are subject to the policy. For more information on requirements, see the Intellectual Property, Inventions, and Patents website.

UWSA Policy 1310: Copyrightable Instructions Materials Ownership, Use, and Control additionally outlines the conditions for ownership, use, and control of copyrightable instructional materials for faculty, staff, and students.

Special cases may occur where a project proposed for extramural funding requires the PI/PD to create a team with special skills to fulfill the work of the award, and the best qualified personnel may be a close relative with specific professional expertise (e.g., credentials, knowledge, or skills) that is not readily available. In such cases, with advance campus review and approval prior to submitting the extramural proposal, terms and conditions may be outlined that would allow a short-term employment or project commitment of a close relative with campus oversight. It is expected that these cases would be rare and determined on a case-by-case review. To initiate review of such a request, the PI/PD is responsible for completing the steps prescribed in the Nepotism Policy for Extramural Grants & Contracts prior to proposal submission, and in accordance with the UWL grant submission timeline requirements.

The following federal agencies have set forth RECR requirements for all institutions receiving agency funding:  

• National Institutes of Health (NIH) (only some funding mechanisms, such as R25 and R36) 
• National Science Foundation (NSF) 
• United States Department of Agriculture (USDA) 

Each agency defines training expectations for undergraduate students, graduate students, postdoctoral researchers, faculty, and other senior personnel participating in projects funded by the above agencies, whether they are paid or unpaid.

For applications subject to RECR requirements, all PIs must complete an RECR Training Plan Form before submission. The form outlines the PI's plan for fulfilling personnel training obligations. The UWL RECR Policy for Federal Agencies details the specific training requirements for each agency and provides information on how to access online RECR training modules. 

It is the policy of UWL that the results of research shall be fully communicated; accordingly, UWL does not engage in classified research and will not agree to grant or contract provisions that restrict the right of a UWL employee to publish, release, or otherwise share findings derived from the sponsored activities. UWL does recognize that some research may require access to proprietary data. As a consequence, it will permit the sponsor of the research an opportunity to review materials prior to publication and to request changes in order to protect proprietary data. The final decision on whether to publish, however, remains with the researcher; the right of review by the sponsor does not contain a corresponding right of approval. In addition, this review period is not to exceed 90 days.

Although UWL will agree to receive proprietary information and will exercise best efforts to maintain the confidentiality of this information, it insists such proprietary information be restricted to that which is absolutely necessary for the research. It must be clearly marked as "proprietary" at the time it is received by UWL. Proposed exceptions to this policy, including the negotiation of contracts or agreements covering classified research in the national interest, must be approved by the cognizant dean or director and the chancellor or their designee.

Recognizing that honesty in the conduct of academic research is fundamental to its integrity, credibility, and maintenance of public trust, UWL Research Misconduct outlines the policy and procedures for reviewing and investigating allegations of scientific misconduct in research. For purposes of this policy, "research misconduct" means fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Research misconduct does not include honest error or differences of opinion. Additionally, National Science Foundation (NSF) regulations define misconduct as retaliation of any kind against a person who reported or provided information about suspected or alleged misconduct and who has not acted in bad faith. NSF-funded science education activity is included within this misconduct in science policy.

Research security refers to national security concerns surrounding research involving types of sensitive data, intellectual property, export-controlled information, and other risks. Research security is important to protect public investment in research, prevent the misuse of research data and advanced technology generated at universities by malign actors, and to protect the safety and security of employees and students traveling abroad. The federal government is focusing on areas critical to protecting the security of US research such as the disclosure of conflicts of interest and commitment, including relationships or affiliations with foreign entities, and research support provided by those entities. Federal agency partners have indicated that failure to disclose foreign relationships and activities may jeopardize eligibility for future funding. 

This policy applies to all UW-La Crosse personnel identified as senior/key personnel, or individuals who are otherwise identified as "covered individuals" by an applicable federal agency, who engage in or propose to engage in federal sponsored projects with the National Aeronautics & Space Administration (NASA); National Science Foundation (NSF); US Health & Human Services (HHS), including the National Institutes of Health (NIH); US Department of Agriculture (USDA); US Department of Defense (DoD) as specified for particular programs; or US Department of Energy (DOE). The policy scope may extend to include additional federal agencies as implementation plans are announced. 

In accordance with federal regulations and agency requirements, prior to submitting a proposal to a covered federal agency, all UW-La Crosse personnel identified as senior/key personnel, or individuals who are otherwise identified as "covered individuals" by an applicable federal agency, must complete research security training within the 12 months preceding the proposal submission deadline. 

During the course of an active, covered federal award, all individuals identified as senior/key personnel must complete research security training annually.

Covered individuals added to an existing award after the award start date must complete research security training prior to beginning work on the sponsored project.

The UWL principal investigator (PI)/project director (PD) is responsible for accurately identifying all senior/key personnel prior to proposal submission as well as those added to a project during the course of an active award. The PI is additionally responsible for communicating research security training requirements to all senior/key personnel and for maintaining an updated list of senior/key personnel with the UWL Office of Research & Sponsored Programs in a timely manner to enable federal research security requirements to be fulfilled.

Applications involving subawards to external collaborators are subject to additional requirements before an application is submitted and, for federal awards, before project work begins.

Before an application is submitted, subrecipient institutions must confirm their role in the proposed project and their requested budget. Before submission, an authorized organizational representative from the subrecipient (e.g., ORSP administrator) must provide the following documents to the lead institution:

• Scope of work
• Subaward budget and budget justification
• Subrecipient commitment form or written confirmation of the intent to collaborate (e.g., memorandum of understanding)

Templates for the above documents are available from ORSP. There may be additional compliance requirements contingent upon lead institution and sponsor requirements (e.g., FCOI training, SFI disclosures, other certifications).

Before project work begins for a federal award, subawards must undergo the processes outlined on the Subaward Risk Assessment & Monitoring website.

If a component of a proposal involves the participation of minors, the PI/PD is responsible for contacting UWL Youth Protection & Compliance to complete additional requirements. Some requirements will apply if a proposal is funded, and there may be associated costs that should be included in the proposal budget.

After a proposal has been approved for support and an award is granted, official notification is usually sent by the sponsor to the PI/PD and/or ORSP. Official acceptance of funds is required, although the form of institutional verification/acceptance varies. For example, some sponsors will issue an award agreement requiring signature while others (particularly federal sponsors) consider the first drawdown of funds as official institutional acceptance of the award and its related terms & conditions. To ensure all university, sponsor, and applicable regulatory requirements are in place to fulfill award terms & conditions before an award is officially accepted, an account will not be set-up until ORSP verifies all compliance requirements have been fulfilled. A PI/PD may not sign award related agreements; agreements may only be signed by authorized contracting personnel. For extramural funding, this is typically the ORSP Director. 

Refer to the External Award Management webpage for the university procedures for award acceptance and account set-up. Once all required activities and compliance requirements have been met by the PI/PD and project team, ORSP initiates account set-up in RAMP. The Grant Accountant then reviews and approved award information in RAMP, creating an account in Workday. The Grant Accountant administers post award financial activities.

The PI/PD, operating within the policies of UWL and assisted by appropriate university administrative offices and officials, is responsible for the day-to-day administration and direction of an approved project. The PI/PD will be furnished a copy of the grant or contract document for reference. In order to effectively discharge their primary responsibility, the PI/PD should be cognizant of all contract or grant provisions and give special attention to those pertaining to budget limitations, patents/inventions and copyrights, safety and security, research compliance, and required reports.

It is expected that the PI/PD will maintain close liaison with the cognizant dean/division director, ORSP, and grant accountant in order to apprise them of developments requiring deviation from the initial budget or from other terms and conditions of the approved grant or contract. ORSP must be furnished copies of all administrative correspondence between the PI/PD and the sponsor. For federal sponsors, all submissions and correspondence must be reviewed beforehand by ORSP and may additionally require prior review and approval by the Provost/Vice Chancellor and UW Office of General Counsel.

It is the responsibility of the Principal Investigator (PI)/Project Director (PD) to follow the scientific/programmatic and financial reporting requirements outlined in the terms & conditions upon award acceptance. Below is a general guide for how to work with various campus partners to manage and support the funded project.

** PIs/PDs should consult with their ADA and/or Business Manager when completing administrative requirements in Workday and Shop UW+.

A separate account is established for each UWL extramural award, and all financial transactions, such as budget receipts, encumbrances, payments, and balances, will be recorded on this ledger. The PI/PD is expected to keep sufficient records in their own department to control all expenditures, including budget items (e.g., travel) that may not be exceeded without sponsor approval. Some grants require supplementary records, and these are defined in the grant or contract document or in published agency regulations. The grant accountant should be consulted to determine current and accurate funds remaining for budget line items.

Sponsors, federal regulations, and UWs policy require award recipients to maintain financial and programmatic records for several years following the award end date. UWL follows the Universities of Wisconsin (UWs) record retention schedule requirements.

ORSP is the office of record for submitted extramural proposals, accepted extramural awards, and most areas of research compliance (e.g., IRB, IACUC, IBC, Scientific Misconduct). Business Services is the office of record for financial records and contracts. PIs/PDs are responsible for maintaining scientific/programmatic/research records in accordance with applicable sponsor policies and regulations, the UWs record retention schedule, and research compliance requirements. For example, UWs expects PIs to maintain a copy of the grant final report for four years after the report submission date.

Record retention guidance from some common federal sponsors:

• National Science Foundation (NSF) Record Retention & Audit
• National Institutes of Health (NIH) Record Retention
• US Department of Agriculture (USDA) NIFA Close-Out Phase
• US Department of Education (ED) Grant Application, Management & Closeout

Cost sharing committed in a proposal must be documented and verified during the post award phase so that the university can demonstrate those commitments have been fulfilled in financial reporting for the sponsor. This includes cash and in-kind contributions. Once an award is accepted, cost sharing becomes a contractual obligation. Generally, cost share:

• Must be verifiable by UWL’s records post award
• Must come from non-federal sources 
• Can only be cited as cost share for one award
• Must be necessary and reasonable for the accomplishment of program objectives
• Must be an otherwise allowable cost per the sponsor guidelines

PIs/PDs are responsible for providing required cost sharing documentation/verification to the Grant Accountant to support the tracking and reporting process.

During account set-up, a separate cost sharing account is established in Workday for projects that include cost share, which is used to track cost sharing that occurs throughout the project period. The cost sharing account will have a Grant Driver prefix (GR) like the primary grant account but will be titled to indicate it is for cost sharing.

The rate at which cost sharing must occur depends on specific sponsor guidance. However, most sponsors generally require that cost sharing occur at the same rate as award expenditures. For example, for a grant that requires 1:1 cost share (e.g., half of project costs are covered by the grant, half are covered by the institution), the sponsor may expect the expenses billed to the grant during the first year to equal the value of cost sharing expended on the project for the same period.

Contact the Grant Accountant with questions on how cost sharing is reflected in Workday and for information on documentation requirements.

Supporting agencies have specific requirements for and restrictions on deviation from the approved project budget. The PI/PD is responsible for complying with such regulations. See UWL's Post Award Modifications guidelines for the types of budget modifications requiring prior university and agency approval, and for the required on-campus documentation, review, and approval processes.

Sponsoring agencies and organizations have different rules regarding funds that are unspent at the end of a budget period in a multi-year grant. PIs/PDs should find out what their sponsor requires so as not to jeopardize the use of these funds. Generally, a formal request must be submitted to the sponsor, via ORSP, with an explanation of why the residual exists and how it will be used during the next budget period.

Requests to extend the award termination date without additional funds (no-cost extension) should be sent to the sponsor through ORSP. See UWL's Post Award Modifications guidelines for the required on-campus documentation, review, and approval processes. Note that sponsors have deadlines required for submitting no-cost extension requests; PIs/PDs are responsible for following those requirements and UWL's required timeline.

Requests for supplemental funds require the same university review and approval process prior to submission to a sponsor as a full proposal. Required documentation at minimum will include an itemized budget, budget justification, and scope of work. Before the request can be submitted to the sponsor, review and approval by the PI/PD's chair/unit director, dean/division director, and ORSP must be documented via RAMP.

All regular university purchasing policies must be followed when purchasing with grant funding. If you are unaware of purchasing procedures, check with your department chair/unit director, college dean/division director, purchasing department, your Academic Department Associate (ADA), or the grant accountant.

For additional information, refer to the Procurement website and the Purchasing & Invoices section of the External Award Management webpage.

Salaries and wages must be administered in accordance with state and university personnel and compensation rules and regulations. PI/PDs should be familiar with the faculty, academic staff, and university staff rules and regulations, current policies for employees-in-training and student hourly help, and federal work study procedures. Contact Human Resources for details on personnel policies and hiring. Hiring practices require compliance with federal anti-discrimination statutes.

For additional information on procedures for hiring student employees, paying current UWL employees, or paying external collaborators, refer to the Personnel section of the External Award Management webpage.

Under federal guidelines, appointment letters, payroll records, etc., are not sufficient documentation to certify expended effort on an externally funded project. Typically a separate certification, approved by an individual having first-hand knowledge of 100% of the employee's activities, both sponsored and non-sponsored, is required. Business Services administers the time & effort certification process monthly for federal funding, which is documented via Workday. Typically, the individual's supervisor completes the certification and will receive a prompt to do so in Workday.

The state and UW System travel regulations govern reimbursement for travel supported with extramural funds. The UW Lodging & Meal Per Diem Calculator  should be consulted for current rates for lodging and meal per diem costs by destination. Reservations for airfare, car rental, and lodging are required to be made with Fox World Travel, either online in Concur, or with a Fox World Travel agent. The use of online brokers or search sites such as Expedia, Travelocity, Kayak, etc. are prohibited and will not be reimbursed by the University. PIs/PDs should work with their department/unit administrative support staff to make travel arrangements and submit travel expense reimbursements via Workday.

For activities involving international travel, faculty, staff, and students must complete a UWL Export Controls Screening Surveywell in advance of the planned travel. Additional prior screening, permits, or processes may be required by the UWL Export Controls Officer (Assistant Controller) to assure compliance with federal export control regulations. For more information, see Export Controls Overview & FAQs. 

Traveling with Technology: Using laptops, email, and other technology outside the US can entail elevated risks of data compromise or loss. For best practices to mitigate these risks, refer to the International Cybersecurity KB article for guidance on securing your data and devices while traveling abroad.

Refer to the Travel section of the External Award Management webpage for more information on travel and expense reimbursement procedures.

Federal regulations (2 CFR 200.33) define equipment as tangible property (including information technology systems) that has a useful life of more than one year and a per-unit acquisition cost of $5,000 or more. The acquisition cost of equipment includes modifications, attachments, and accessories necessary to make the equipment usable for the purpose for which it will be purchased.

Contact Purchasing for assistance with the procurement process. Refer to the Purchasing website for guidance.

Equipment purchased with extramural funding belongs to either the sponsor or the university (not an individual faculty/staff member). Ownership is dictated by the terms & conditions of the award, sponsor policies, and related regulations. For example, a federal agency may retain ownership (title) of the equipment or may transfer the title to the university. In any case, the PI/PD is responsible for such equipment and must account for all items periodically and at the close of the project. Equipment purchased with extramural funds must be entered into the UWL inventory system. Disposal of equipment purchased with extramural funding must also follow relevant sponsor terms & conditions, regulations, and reporting requirements.

Sponsors require periodic programmatic/technical and financial reports throughout the course of a project/program to assess progress being made toward objectives and the alignment of expenditures with the proposed budget.

Financial reports are compiled by the Grant Accountant in consultation with the PI/PD. Depending on sponsor requirements, the report may need to be submitted by the Grant Accountant, ORSP, or the PI via email or an online system. The PI should work with the Grant Accountant through the project to ensure all expenses have been appropriately posted to the award account.

Programmatic/technical reports are the responsibility of the PI to complete, as well as to coordinate required review, signatures, and submission. Frequency is determined by the sponsor and are often annual but may be more frequent (e.g., quarterly). Review sponsor terms and conditions, policies, and award documentation closely to ensure required reporting timeframes are followed. Follow the format specified in the award documentation, sponsor policies, or sponsor online system. Federal reports often must be submitted by the PI or ORSP via an online system (e.g., eRA Commons for NIH awards, Research.gov for NSF awards). Non-federal reports are typically submitted by the PI via email to a designated sponsor contact. Many final reports require the signature of an Authorized Organization Representative (AOR), which is the ORSP Director. Final reports for non-federal sponsors that require an AOR should be submitted for ORSP at least 10 business days before the submission deadline. Final reports for federal sponsors must follow the university's federal review requirements and timeline.

Final programmatic/technical and financial reports are due to the sponsor before the end of the award closeout period. Review the award letter and terms & conditions to determine the required final report content, deadline, and submission logistics for your award.

Reporting guidance from some common federal sponsors:

• National Science Foundation (NSF) Reporting Requirements
• National Institutes of Health (NIH) Reporting Requirements
• US Department of Agriculture (USDA) NIFA Monitoring & Reporting
• US Department of Education (ED) Grant Application, Management, & Closeout

Federal regulations require that UWL report to the sponsor any program income related to projects funded in whole or in part with federal funds. It is therefore important that income generated from the sale of goods and/or services be re-deposited to the source of funds paying the costs of the sale. These regulations also require prior sponsor approval before expending income generated from grant/contract activities. Award terms and conditions typically indicate how program income must be handled - e.g., deducted from the total allowable costs and reducing the overall total award amount, added to total allowable costs and increasing the overall total award amount, or to meet cost sharing requirements.

Sales and income is a complex area that should be discussed with ORSP and Business Services if extramural funds are involved.

Post award modifications may be needed for a variety of reasons: 

• Budget modifications when total funding previously awarded is reduced or increased, significant revisions are needed (i.e., those requiring a sponsor's prior approval), or funds are reallocated from participant support
• No-cost extensions when additional time is needed to meet a project’s objectives with no additional funding 
• Award transfers from or to another institution
• Changes to a project’s PI, scope, objectives, or personnel effort 
• Other modifications requiring a sponsor’s prior approval

Certain changes require sponsor prior approval, while others may only require university approval. Consult with ORSP and the Grant Accountant to determine applicable university and sponsor requirements.

Refer to the UWL Post Award Modifications guidelines for information about the required documentation, timelines, and review & approval processes for each modification type. To initiate a post award modification, the PI should complete the INTAKE Questionnaire. The INTAKE form and required documentation is due to ORSP at least 10 business days prior to a non-federal sponsor's submission deadline and earlier for federal awards (see the Federal Review Requirements & Timeline). Please allow sufficient time for prior review and revisions in order to meet the required submission deadline.

Prior to requesting any budget modifications or no-cost extensions, the PI/PD is responsible for ensuring the extramural award has been charged for all approved expenses incurred. The fact that this may require additional paperwork (e.g., a separate order to Central Stores or a vendor) is no reason to avoid the practice and thus load the regular department budget or other extramural projects with inappropriate or unnecessary charges. The PI/PD is responsible for monitoring expenditures, ensuring expenses are posted to the appropriate account, and working with their ADA, Business Manager, and Grant Accountant to transfer expenses if needed.

Major changes in the research plan that constitute a redirection of the statement of work included in the original proposal must be discussed in advance with and approved beforehand by the sponsor. Before submission of such a proposal to the sponsor, refer to the UWL Post Award Modifications guidelines for information about the required documentation, timelines, and review & approval processes. 

To initiate a post award modification, the PI should complete the INTAKE Questionnaire. The INTAKE form and required documentation is due to ORSP at least 10 business days prior to a non-federal sponsor's submission deadline and earlier for federal awards (see the Federal Review Requirements & Timeline). Please allow sufficient time for prior review and revisions in order to meet the required submission deadline.

Extramural awards are made to the university rather than to an individual PI/PD. Whenever an individual is unable to continue serving as a PI/PD on an extramural project, university and sponsor approval is required before a new PI/PD can be designated. Refer to the UWL Post Award Modifications guidelines for the required timeline, documentation, and processes.

To initiate a post award modification, the PI should complete the INTAKE Questionnaire. The INTAKE form and required documentation is due to ORSP at least 10 business days prior to a non-federal sponsor's submission deadline and earlier for federal awards (see the Federal Review Requirements & Timeline). Please allow sufficient time for prior review and revisions in order to meet the required submission deadline.

Extramural awards are made to the university rather than to an individual PI/PD. When a PI/PD is terminating their association with UWL and requests a transfer of their extramural support to another university, specific prior approval must be obtained from both UWL administration and the sponsor. The university may choose to make alternate arrangements rather than transfer the award to another institution (e.g., assign a different PI, set up a subaward with the current PI at their new institution). In short, an award transfer is not guaranteed when a PI moves to a new institution. Thus, it is strongly recommended that PIs initiate communication with all stakeholders as early as possible in the process, particularly with the sponsored programs offices at both institutions. Refer to the Award Transfers section of the UWL Post Award Modifications guidelines for the required timeline, documentation, and processes.