DOING RESEARCH IN MAE
PROPOSAL SUBMISSION:
GRANT MANAGEMENT:
EXPORT CONTROLS:
- Export License
Calls for Proposal / Solicitation
As soon as you are aware of a submission, please send the RFP/solicitation to your Grants Manager, who will guide you through the submission process. Allow plenty of time to prepare the proposal, taking into consideration the guidelines below.
*New Guidance* effective December 9, 2020
- MAE staff should be notified of your intent to submit a proposal a minimum of 10 working days (two weeks) prior to the deadline. More than two weeks of notice is always preferred. We will provide ORPA with a weekly update of upcoming proposal submissions, which will then help everyone involved.
- To meet ORPA’s recommendation to submit proposals five business days in advance of the deadline, proposal budgets should be finalized at least seven working days prior to the proposal deadline. (this step enables MAE staff to have time to meet all the internal processing requirements).
- Please note: It is important that the budget be finalized early on so that all the necessary documentation can be completed and entered into appropriate systems. Last minute budget changes often lead to rushing, which leads to errors that we are trying to avoid.
- ORPA expects to receive the administrative sections of the proposal via ERA at least five working days prior to the proposal deadline. This includes the final budget.
- Technical sections of the proposal should be submitted via ERA to ORPA at least two working days prior to the deadline.
As a reminder, some proposals require extra time such as those to new sponsors, to international agencies, those with subawards, or proposals with multi-PIs/institutions. To allow sufficient time for MAE staff and ORPA to complete their required reviews, please add extra time to the above guidelines for these types of proposals.
We understand that last minute proposal requests do happen occasionally. To assist with MAE and ORPA workload planning, notices that do not meet the above guidelines on giving ORPA five working days (item 3) will require a written exception by the Department Chair. In these rare instances, you will write to your grant manager and to the chair so that a determination about department support for submitting a last-minute proposal can be made.
Personnel
Your Grants Manager will work with you to budget for personnel and include effort and calculcate the appropriate amount of fringe benefits - which will fluctuate based on the current negiated rate agreement and varies depending on the type of personnel. Current rates will provide the breakdown of costs per personnel type. Graduate students stipends must be charged to the same location as the tuition. Graduate students charged supported on projects with less than the negotiated indirect cost rate will require you to pay FULL tuition costs, so keep this in mind when planning your budget. If you are charged the full indirect costs, you will budget 50% of the full tuition cost.
Tuition
The full rate of tuition is matched by the Graduate School on grants paying the full indirect cost rate. If the indirect cost rate paid by the sponsor is less than the full rate, the grant must support 100% tuition costs. See current rate sheet for current tuition charges.
Sub Awards
If another institution is needed to provide project support, expertise, or student effort on your proposal, we will need to set up a subaward with that institution. We require a Statement of Work, budget, budget justification and subward commitment form from your sub awardee. The PI must complete the Sub Classification Form for each subaward. Grants Managers will coordinate documents with your subaward institution(s) for you.
See checklist (http://mae.princeton.edu/sites/default/files/subaward-checklist.pdf)
Travel
Both foreign and domestic travel must be identified and estimated as closely as possible. Specify who will be traveling, where, when, duration of travel, and for what purpose. Verify as to whether your sponsor considers travel to Canada and Mexico as foreign or domestic. All federal sponsors require compliance with the Fly America Act, whereby US air carriers must be used for all flights covered by federal funds, with few exceptions. See the following flowchart for federally funded flights to foreign countries. https://finance.princeton.edu/how-to/sponsored-research/compliance/fly-america-act/Flowchart-FAA-and-Open-Skies-Final-Draft.pdf
International travelers should review OIT’s International Travel Guidelines for recommendations to minimize risks to University and personal devices, as well as ORPA’s Foreign Travel Issues webpage.
Scientific Supplies and Services
Estimate what you may need to purchase in the way of scientific lab supplies and services. Note that general supplies or office supplies are not appropriate for research funds. Identify if you are building/fabricating anything on your project. A fabrication project may be setup. No maintenance, upgrades, labor, travel costs or consumable supplies may be charged to a fabrication project.
Computing devices under $5K per unit may be direct charged to the project if they:
- are essential, reasonable and allocable to the project in that they are necessary to acquire, store, analyze, process, and publish data and other information electronically including accessories (or “peripherals”) for printing, transmitting and receiving, or storing electronic information,
- are not purchased for convenience or preference.
Note that computers costing over $5K are considered equipment and need prior approval from the sponsor so be sure to include details in your budget justification. Documentation should be kept that describes how the proposed computing device meets the above requirements.
Visa costs for short-term travel can be included on proposal budgets if they can be clearly identified as relating directly to the project. Long term visa costs (such as H1B or J1) are not allowable on research projects.
Participant Support
Participant support costs are allowable on research projects if they are budgeted at the time of proposal submission and are included in your original budget request. This includes stipends or subsistence allowances, travel allowances, and registration fees paid on behalf of trainees or participants (not employees) in connection with conferences or training events. If the project contains an educational or outreach component and the agency approves, then these costs are permissible. Such costs must be included in the proposal budget, and do not calculate indirect costs. Personnel at Princeton are not considered participants.
Equipment
Obtain current quotes for each item >$5K that you’ll require to do the work on the project. At the time of obtaining the quote, you need to also ask the vendor for the ECCN (Export Control Classification Number) for each item, as well as whether it is ITAR-controlled (International Trafficking in Arms Regulations). If it is ITAR-controlled, it will not be allowed to be purchased at Princeton. Each piece of equipment must be sponsor-approved and should include all equipment that is required to do the work on the project, throughout the entire period of the proposal. However, if you elect to purchase a piece of equipment after the award begins, you must request sponsor approval.
F&A Costs (Indirect Costs)
Facilities and Administrative costs (indirect costs) are costs that are general and cannot be directly allocated to the research project. Such costs are administrative salaries, building maintenance, utilities, etc. In the unusual event that the sponsor of your proposal pays indirect costs on Total Direct Costs (TDC), the F&A rate applies to all budget items and should be used when the sponsor does not allow the federally negotiated rate.
When Princeton University is the sub recipient, the organization that receives a federal award directly is obligated to honor Princeton’s negotiated F&A rate. By the same token, Princeton PI’s may not negotiate rates with their sub recipients.
If a sponsor publishes a maximum F&A rate that it will pay on a specific proposal and is less than the federally negotiated rate, Princeton’s Office of Research and Sponsored Projects (ORPA) may or may not accept the proposal. A copy of the page describing this rate must be attached to your proposal in Coeus.
Budget Justification
After you have decided on the various components of your budget and have arrived at a total, you will then need to write a budget justification which explains each component of the budget. Work with your Grants Manager on this document as there is specific language that must be included in each and every justification.
COMPLIANCE
Aside from export control issues, you must also determine whether your project will involve live animals, human subjects, biohazards, or conflict of interest. See the Research Integrity and Assurance web site: (https://www.princeton.edu/ria/). Notify your Grants Manager of your intended involvement in any of the above as soon as you notify them of the proposal as it may take time to route for proper approvals and protocols.
PI CERTIFICATION
This form is required to be signed by the PI, and attached to each proposal. (https://deptbedit.princeton.edu/orpa/policies-and-forms/forms/Coeus-PI-Certification-Form.pdf)
Answers to the questions are required before submission of each proposal and must be completed by the PI. Please see link to the questionnaire. https://deptbedit.princeton.edu/orpa/policies-and-forms/forms/Coeus-PI-YNQ.pdf
GRANT MANAGEMENT
You will be notified by email if your proposal has been awarded and assigned a chartstring by ORPA on your Notice of Award (NOA). MAE Grants Managers and Business Manager are also notified. Your assigned Grants Manager will add personnel to your new project and monitor expenses. They will send monthly status and projection statements, showing expenses that occurred during the past month. They are here to help you manage your project’s future outcomes. They will also request no-cost extensions, coordinate capital equipment purchases, request pre-award spending, and review and approve expenses on your projects.
The grant managers assist you in preparing and submitting your proposals. Please allow plenty of time to work on the proposal pre the guidelines above. As soon as you are aware of a submission, please contact your Grants Manager and send them a copy of the solicitation/RFP with a title (if known) as well as a start date and any collaborators/co-PI's.
DEFINITIONS
The first step in determining if export controls apply to a particular activity is to determine if an export is occurring. The Export Administration Regulations define an export as:
- “An actual shipment or transmission out of the United States, including the sending or taking of an item out of the United States, in any manner;
- Releasing or otherwise transferring “technology” or source code (but not object code) to a foreign person in the United States (a “deemed export”)…”
Export Administration Regulations (15 CFR 734.13)
An exporter is also responsible if they know that an item or technical data being exported is intended for a third country. This is known as a re-export, and the US exporter remains responsible for the ultimate destination of the item/data.
EXPORT CONTROL REGULATIONS
If an export is occurring, the next step is to determine if the item is subject to export control regulations. There are three types of information that are excluded from export controls:
- Information that is in the public domain. Information that has been published and is widely available in libraries, through distribution at public conferences, open patent applications, etc. is excluded from export controls.
- Information commonly taught in academic catalog courses is not subject to export control regulations.
- Research results arising from the conduct of fundamental research activities:
- Research in science, engineering, or mathematics;
- Where research results are ordinarily published (there are no restrictions or approvals on the publication of the research results); and
- There are no restrictions on access to the research results (for proprietary or national security reasons).
NOTE: Equipment being exported from the US never qualifies for the fundamental research exclusion. The fundamental research exclusion applies only to research results, not physical items.
The three primary sets of export control regulations:
- Export Administration Regulations (EAR)
- International Traffic Arms Regulations (ITAR)
- Office of Foreign Assets Control Regulations (OFAC)
EXPORT LICENSE
Assuming that an export (or re-export) is occurring, and that the item/data is subject to export control regulations, an export license may be required. In order to make this determination, four primary questions must be answered:
- What is the item/data that is to be exported?
- Where is the item going?
- Who is the recipient of the item?
- What is the end-use of the exported item/data?
By providing the Princeton Export Control office with this information, an export license determination can be made. The contact information is: jj21@princeton.edu or (609) 258-3819.
The amount of time required to obtain export licenses varies by US government agency. For this reason, it is imperative to identify exports well in advance so that the requirement to obtain export licenses does not delay research activities.
LINKS TO ADDITIONAL INFORMATION
Additional Information Related to Export Controls at Princeton may be found on the ORPA Export Controls webpage, including:
Issues Related to International Travel
What types of technology are export controlled?
How to determine if equipment/technical data is export controlled.
COST SHARING
Cost sharing is typically only permitted for projects is when required by the sponsor. You must decide cost sharing commitments at the time the proposal is being prepared which require obtaining department and SEAS approval. Please see your Grants Manager to discuss the type and sources of cost sharing. You will then need to discuss proposed cost sharing with the MAE Chair.