Circular No. A-21 Cost Principles for Educational Institutions sets forth the government regulatory costing principles which must be followed by educational institutions conducting Government Sponsored Research. As of 12/26/2014 the Uniform Guidance will take the place of OMB Circular for all new awards and increments with effective dates on or after 12/26/2014.

An Award Approval Notification (AAN) is an email to the PI generated by the SeRA system. It indicates that an award has been approved by the sponsor.

An award is a unique source of funding to the University such as a sponsored award, gift, designated income, endowment, etc.

An early PTA allows you to open up a PTA prior to receipt of an award or while an award is being negotiated. This allows you to begin charging expenses to the project at the PIs risk.

When you request an early PTA, the PI must identify a guarantee PTA with unrestricted funds to cover the costs in the event that the award does not materialize. Once the award is received, an early PTA becomes the project PTA. The project is already setup in SeRA.

• If human, animal subjects or stem cells are involved, certification that protocols have been filed for review and that no expenses involving those activities will be incurred until the final protocol approval is granted. 

• An early PTAs can be requested in the SeRA system. For detailed instructions see the Sponsored PTA Manager - Dept. User Guide and the Sponsored PTA Manager - Early/Extend - Post Award User Guide here

What Not to Do

It is strongly recommended that spending in advance of a fully executed award is NOT charged to an unrestricted PTA because it is very difficult to separate costs that benefit a sponsored project from other costs in an unrestricted PTA.

• Any time charges are transferred onto a sponsored project PTA, as they would be when you have to “clear” early expenses and transfer them onto the proper PTA, careful documentation is required as to the benefit to the new project. Additionally, depending on how the expenses are incurred, the costs could be considered unallowable. The CAS language states: 

The costs of any work project not contractually authorized, whether or not related to performance of a proposed or existing contract, shall be accounted for, to the extent appropriate, in a manner which permits ready separation from the costs of authorized work projects.

Do not use another sponsored PTA to fund expenses that you intend to move later. The expenses would be considered both unallowable and unallocable. 

When it is necessary to request an early PTA for preaward spending or spending in advance of a fully executed award, the PI must identify a guarantee PTA with unrestricted funds to cover the costs in the event that the award does not materialize. 

It is strongly recommended that preaward or spending in advance of a fully executed award is NOT charged to an unrestricted PTA. It is very difficult to separate a cost that benefits a sponsored project from other costs in an unrestricted PTA.

eSubmit is Stanford's drop box for storing, routing and tracking electronic research proposals. It is primarily used in the School of Medicine.

eSubmit is Stanford's drop box for electronic research proposals and provides storage, routing, and tracking features. Potential users include faculty, departmental staff, and central office staff who participate in the creation, approval, and submission of these electronic proposals. Find more information here.

Federal agencies use different terms to describe the infrastructure costs needed to maintain a major research university. The terms Facilities and Administrative costs (F&A) and Indirect Costs (IDC) refer to the same thing.

Facilities & Administrative (F&A) Rates (also known as indirect cost rates) and fringe benefits rates are established in accordance with the federal government's Office of Management and Budget. These rates are negotiated between Stanford and the Office of Naval Research (ONR), the cognizant federal agency overseeing the administration of sponsored agreements at Stanford.

The Institutional Official (IO) is the individual named by Stanford, who is authorized to act for the institution, and to assume the obligations imposed by federal, state and local laws, regulations, requirements and conditions, as well as university policy that applies to a proposal and award.  In signing a proposal application and in accepting a corresponding award, this individual certifies that Stanford will comply with the assurances and certifications referenced in the application. 

This individual's signature further certifies that Stanford will be accountable both for appropriate use of funds awarded and performance of the sponsored project activities resulting from the application. 

The Notice of Award (NOA) is an email to the PI generated by the SeRA system. It indicates an award has been received for a proposal submitted, however it has not yet been accepted by Stanford University.

The Proposal Development and Routing Form (PDRF) is an electronic form that is accessed through the SeRA system. PIs and department administrators are required to use the PDRF to route a proposal for institutional review. 

It is possible to spend before the anticipated award start date if the sponsor authorizes it in writing. Check the terms and conditions of the specific award for restrictions on preaward spending. 

Most federal sponsors allow preaward spending for grants 90 calendar days prior to the anticipated award start date. Other sponsors limit the dollar amount or do not allow preaward spending. It is rare for contracts to include language allowing preaward spending. Special language must be negotiated. 

If the sponsor authorizes preaward spending, you must open an early PTA. If the research involves human or animal subjects or stem cells, a protocol must be submitted before an early PTA can be opened. Although you can receive an early PTA, work on animals and humans cannot begin until the protocol is approved.

Preaward spending is done at the PI’s risk.  The sponsor is not obligated to fund the pre-award costs if the project is not funded, and the sponsor's authorization of preaward spending does not guarantee that the PI will receive the award. If the award does not materialize, the PI must cover for the costs from his or her unrestricted funds.

Always open an early PTA for preaward spending.

A solicitation is a publicly available document by which a federal agency, corporation, foundation or other nonprofit agency make known its intentions to award discretionary grants, cooperative agreements, or contracts, usually as a result of competition for funds. The solicitation is the roadmap for putting together the proposal. 

Each agency may use a different term for a solicitation. Some common terms: Funding Opportunity Announcements (FOA), Requests for Applications (RFA), Broad Area Announcement (BAA), Notices of Funding Availability, or other names depending on the agency and type of program. For this class, we will use the term solicitation.

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A sponsored award notification is a communication (formal or informal) from an external sponsor to the University or to a Principal Investigator that their proposal has been selected to be awarded.

It may be an informal communication between an external sponsor and a principal investigator. Some agencies like NIH have a formal mechanism.

A proposal is a detailed request for funding usually prepared in accordance with the sponsor’s instructions. A Principal Investigator (PI) documents his/her research ideas and methodology to a potential sponsor in a detailed proposal to ask for the sponsor's financial support. The proposal is submitted by the Stanford Institutional Officer (not the PI) to the sponsor for competitive review.

Federal and most other sponsors require specific proposal components. The sponsor may reject the proposal if it does not contains all the information the sponsor needs to make a decision about the significance of the work. Stanford requires minimum proposal components which in rare cases may exceed what the sponsor requires. Minimum proposal components required by Stanford are: a statement of work, a budget and budget justification. This must be attached to a PDRF and routed for institutional review.

If accepted, a proposal becomes an official record. It documents what was promised to a sponsor and Stanford’s commitment. It is used by Stanford, the sponsor and auditors. Questions about commitments may be asked many years after a project is completed. A good proposal documents all the answers.

A sponsored project is an externally funded activity governed by terms and conditions specified in a written agreement between the sponsor and an entity such as Stanford University. The sponsored agreement is the legal instrument that binds the university to perform the statement of work under the direction of a principal investigator (PI) and further specifies the level of funding.

See a full description and comparison to other types of funding here.

A statement of work (SOW) describes the work to be performed and includes a timeframe necessary for the completion of the work. A well written SOW allows the subrecipient to provide a detailed response, with a realistic cost estimate. The goal is to allow the subrecipient to understand what is expected of them and what should be included in the finished product. A good statement of work contains the following elements.

1.  A detailed description of the work to be performed

2.  The period of performance - the start and end dates

3.  Deliverable requirements, including as applicable:

• A  timeline of the major deliverable due dates (both fixed and flexible; e.g. two weeks after some event occurs),

• Milestones as necessary so that the work can be monitored to ensure the quality of the work is as expected,

• A definition of completion 

• The criteria that constitute acceptance

• Special requirements such as travel, special skills or knowledge, special resources

Principal investigators' responsibilities include directing research and managing financial aspects of research in compliance with Stanford policy, federal and state laws, and sponsor requirements.Training to is available, and in some cases it is required. Principal investigators are responsible for ensuring they, their students, and staff meet compliance training requirements.

The Uniform Guidance issued by OMB, streamlines and supersedes guidance that was previously contained in eight different OMB Circulars for all new federal awards and increments with effective dates on or after 12/26/2014. Included in the new guidance are definitions, uniform administrative requirements (both pre- and post-award), cost principles, and audit requirements. From Stanford's perspective, the Uniform Guidance will supersede OMB Circulars A-110, A-21, and A-133.