Routing,
Approval and Certification
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Even
prior to submitting a proposal for sponsored funding,
the PI has defined responsibilities during the University
"sign-off" process. While the sign-off (i.e.,
routing) process may be viewed as cumbersome, especially
during that 11th hour when a deadline looms, it is a critical
and necessary step. It is during this process that the
University and PI are assured that:
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The proposal is in line with the University's mission
and objectives;
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Appropriate personnel and facilities are available
to carry out the project;
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All reasonable and allowable costs have been included,
and the proposal adheres to sponsor proposal guidelines;
- All
policy and compliance issues have been addressed.
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The
Proposal Sign-Off Form is the University's internal review
form that authorizes proposal submission. Specific signatures
on this form signify that the proposal has been reviewed
for certain considerations, such as obligations of space
and/or personnel. Sign-off requirements vary with each
School/College; consult the ORPA Guide on Submission of
Sponsored Project Proposals at http://www.rochester.edu/ORPA/OGUIDES/
or the relevant Dean's Office.
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Regardless
of the School/College requirements, the PI's responsibilities
during the sign-off process remain constant. It goes without
saying that the PI maintains the responsibility for preparing
the scientific proposal and budget, and obtaining the
required and appropriate approvals as dictated by department,
School and University policy. What is often not recognized
is the responsibility of assuring and certifying to various
conditions on the Sign-Off Form. Some of the certifications
on the Sign-Off Form are required by law; falsely certifying
may invoke civil or criminal penalties. The Sign-Off Form
can be accessed at http://www.rochester.edu/ORPA/Forms/
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Of
particular note:
- Conflict
of Interest: All investigators (key individuals responsible
for the administration, design, conduct and reporting)
are required to make an annual disclosure to their
supervisors of outside remunerative and other activities
related to their teaching, research and administrative
responsibilities. When submitting NIH or NSF proposals,
this disclosure is required when a significant financial
interest related to that proposal exist. It is a federal
requirement that such disclosures are submitted in
advance of proposal submission to these agencies.
This form can be found at
http://www.rochester.edu/ORPA/Forms/
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- Debarment
and Suspension: This regulation requires that
applicants for federal funds certify that neither
they nor their researchers are debarred, suspended,
proposed for debarment, declared ineligible
or voluntarily excluded from covered transactions
(e.g., grants and contracts) by any federal
agency.
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WHAT IS DEBARMENT? |
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| There
are other
certifications on the Sign-Off Form such as the adherence
to federal obbying requirements. A full description
of the meaning
and significance of these certifications can be found
in the ORPA Manual at
http://www.rochester.edu/ORPA/manual/
Falsely certifying may invoke action against the PI and
key personnel not only by the involved federal agency,
but by the University. PI's are to take sign-off requirements
seriously. |
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