Budget Justifications

What is the purpose of the budget justification?

The University has fiduciary responsibility as a steward of Federal and other sponsored funding that requires us to demonstrate on all proposals submitted and awards received that the costs budgeted are allocable, allowable, and reasonable. A Budget Justification:

  1. Provides details that demonstrate adherence to these critical qualifications and assures that, if awarded, a submitted budget will be charging against costs meeting those standards.
  2. May be required for prior approval of some costs, such as administrative salaries, as well as detailed justification for costs, including equipment, travel, participant support, materials and supplies, and the F&A rate.
  3. Is used at the end of a project for award closeout to confirm that all costs charged are allowable and, as needed, had prior approval from the sponsor. 

Instances where a sponsor does not require a Budget Justification at proposal phase are rare; however, beginning in April 2018, OCG and the Campus Controller’s Office will no longer require a Budget Justification if one is not required by the sponsor. In some cases, sponsors require additional budget information after the proposal has been submitted which could include a justification of costs.  In these instances the justification of applicable budget items will be requested from the PI, submitted to the sponsor as required, and will become a permanent part of the proposal record.

Even if a sponsor does not require a Budget Justification at proposal or award, costs supported by sponsored funding must still be allocable, allowable, reasonable, and abide by University policy. See the Cost Principles for more details.

Budgeting and NIH

The National Institutes of Health (NIH) has special budgeting guidelines for sponsored projects. OCG has official internal processes to ensure consistency as a University in budgeting for NIH proposals. See our current NIH Proposal Budgeting Processes for details on budgeting for NIH, including information on modular versus detailed budgets, and on salary caps for certain project personnel.

CU Boulder has a policy and additional guidance for Graduate Student Compensation on NIH-funded Projects.

We recommend developing a detailed budget for all NIH projects, but Principal Investigators (PIs) have the option to develop a basic modular budget at proposal stage using OCG’s Modular Budget Template. If awarded, a detailed budget will be needed for internal award processing and set up.

Change Org Code

You must complete the Reorg Request form found on the Sponsored Projects Accounting (SPA) webpages. Follow the instructions on the form when returning to SPA. SPA will enter the information in PeopleSoft. Once PeopleSoft is updated, the change is forwarded to ocg@colorado.edu to be updated in InfoEd.

ClinicalTrials.gov

ClinicalTrials.gov is a registry and results database of publicly and privately supported clinical studies of human participants conducted around the world.

If you have questions about reporting through ClinicalTrials.gov, contact Kathryn Snider, Senior Proposal Analyst, at kathryn.snider@colorado.edu.

Conflict of Interest and DEPA Reporting

According to University, NSF, and NIH policy, CU employees responsible for the design, conduct, or reporting of research must submit an online Disclosure of External Professional Activity (DEPA) on an annual basis. Employees must also update their DEPA within 30 days of any status change.

A current DEPA must be on file in order to submit a proposal through CU.

For more information, visit the Office of Research Integrity website

Cost Accounting Standards

Cost Accounting Standards (CAS) are Federally-mandated accounting standards intended to increase the uniformity and consistency of cost accounting practices among educational institutions. For more details, visit the Campus Controller’s Office website.

Cost Principles for Sponsored Agreements

There are four basic concepts that guide the process of developing sponsored project budgets as defined in 2 CFR 200, Uniform Guidance:

ALLOWABILITY

Costs charged to a sponsored research award must comply with any limitations or exclusions indicated in the sponsored agreement or in the Federal Cost Principles within the 2 CFR 200 (Uniform Guidance).

ALLOCABILITY

Once a cost has been determined to be allowable, the next question is whether it’s allocable, meaning that it provides direct benefit to the sponsored project. Expenses in a sponsored project budget should not be general expenses that support various activities of the principal investigator (PI) and/or University. They should be specific costs that can be reliably estimated that support or advance the work of the specific award and that award only. Items that benefit multiple projects are assigned to budgets in proportion to the benefit that they provide to each project.

REASONABLENESS

If a cost is deemed allowable and allocable, then the next question is whether or not it’s reasonable. The principle of reasonableness is basically how it sounds. The proposed costs must seem reasonable to the general public and able to withstand public scrutiny.

CONSISTENT TREATMENT

The final consideration is whether the costs are consistently treated by the University. It is essential that all expenses be treated in the same manner under similar circumstances.

In December 2013, the Office of Management and Budget (OMB) issued uniform administrative requirements, cost principles, and audit requirements for Federal awards in the Federal Register. As of December 26, 2014, 2 CFR 200 (Uniform Guidance) replaces the administrative, accounting, audit rules and principles currently included in the OMB Circulars, including A-21, A-110 and A-133.

Your Proposal Analyst will analyze the costs within your budget and help ensure that they conform to sponsor and other regulatory requirements. Your Budget Justification is another important document that provides additional details that help demonstrate adherence to the Cost Principles.

For more information, visit the Electronic Code of Federal Regulations and CU Boulder's Cost Principles policy and procedure statements.

Cost Share

Cost sharing essentially means that the University is “donating” money, employee effort, or tangible goods toward the direct costs of a sponsored research project. Such contributions may be made by the University, the Principal Investigator (PI), or by other third parties, but all are a form of cost share. According to the University's Cost Sharing Policy, cost share is generally prohibited unless it is specifically mandated by the sponsor or program guidelines and/or in the best interests of the University.

As soon as you identify a funding opportunity that requires cost share, please contact your Proposal Analyst. Your Proposal Analyst will guide you through all of the cost share requirements, including obtaining official University or other commitments, properly formatting your Excel budget to clearly show all cost share commitments, and completing the Cost Sharing Addendum.

You must involve your Proposal Analyst to ensure that all cost sharing requirements are met prior to proposal submission. Keep in mind that your proposal will not be submitted until your Proposal Analyst has official cost share documentation on file because cost share is a binding commitment made at the proposal stage.

Please review the Campus Controller’s Office webpage for further information and requirements.

Cost Transfers

It is critical that all sponsored projects be reviewed regularly on a monthly basis to ensure that expenditures are accurate and appropriate. Diligent review of financial reports and timely communication between Private Investigators (PIs) and Departmental Administrators should prevent the necessity for transfers. When errors are discovered, however, they must be corrected as quickly as possible.

Read the complete Cost Transfer policy and associated procedures on the Campus Controller's Office website.

Departmental Administration Indirect Cost Recovery (DA-ICR) Program

The Departmental Administration Indirect Cost Recovery (DA-ICR) program was designed to provide general fund support to units in proportion to the indirect cost recovery generated from a unit’s sponsored project activity. To find your unit’s DA-ICR allocation, visit the Campus Controller’s Office site.

Disclosure Statement, DS-2

Per Federal Public Law 100-679, the federal government requires institutions of higher education that receive more than $25 million in federal research contracts or grants to disclose their cost accounting practices for measuring, assigning, and allocating costs in disclosure statement DS-2. The disclosure statement clarifies the cost accounting practices that the institution follows, or proposes to follow, and provides the federal government with more fiscal controls to ensure greater efficiency, effectiveness, and accountability by institutions receiving federal grants or contracts.

View CU Boulder’s DS-2.

Environmental Health and Safety

CU Boulder’s Environmental Health and Safety (EH&S) works with the campus community as well as local, state and federal agencies to ensure that all environmental health and safety hazards are appropriately addressed. Visit the EH&S website for more information.

Equipment

Permanent (capital) equipment refers to items valued at $5,000 or more with a useful lifespan of at least one year. Equipment also includes individual items that cost less than $5,000 that are combined or fabricated in order to function as one piece of equipment with a total value of $5,000 or more.

If you are anticipating the purchase of permanent equipment for a sponsored project, be sure to include details in your budget and budget justification at proposal stage. Any unbudgeted equipment purchases will require sponsor pre-approval.

Visit our property page for additional information.

Export Controls

As a public institution located in the State of Colorado, the mission of the University of Colorado is to perform research with results that can be openly shared, known as the Fundamental Research provision. On occasion, research conducted at CU requires additional compliance with export control regulations, which is typically identified at the time of a proposal and finalized at the time the award is received and negotiated.

In order to comply with these restrictions, OCG reviews proposals prior to submission and confirms what Export Control restrictions are identified by the Principal Investigator (PI) on the Proposal Submission Request form. The PI is then directed to the Export Control Office for any export items identified on the form.

At the time an award is issued, OCG reviews award terms and conditions for restrictive export control terminology. To the full extent feasible, OCG negotiates terms acceptable to the University in coordination with the University’s Export Control office which may require licensure. Where restricted, proprietary, or classified restrictions remain, OCG supports PIs in preparation of a petition for review of awards by the Standing Committee for Restricted, Proprietary, and Classified Research. Please see the Export Control Office website for more details about this critical research issue. The “Guidance” section of that website includes particularly helpful information on such topics as: 

  • How to handle foreign visitors
  • Getting a license
  • Key things to consider with international travel
  • Publishing study results
  • Shipping and exporting

More information:

Export Control Office Website

Fundamental Research Definition

Restricted, Proprietary, and Classified Research Policy

Proposal Submission Request (PSR) Form

Office of International Student and Scholar Services (ISSS)

Visual Compliance Screening

Fellowship Proposals

The process for submitting fellowship proposals will vary depending on whether an institutional endorsement of the application is required by the funding source, as follows:

  • Submissions requiring an institutional endorsement are submitted through the Office of Contracts and Grants (OCG)
  • Submissions that do not require an institutional endorsement but for which the funding will go to the University and not directly to the student are submitted through OCG
  • Submissions that do not require an institutional endorsement may be submitted directly by the student per sponsor guidelines if the funding will go directly to the student

All fellowship submissions submitted through OCG are treated as a standard proposal and obtain the same documentation as other proposals.

As soon as you have identified a fellowship that you would like to apply to, contact your Proposal Analyst and include the Proposal Submission Request (PSR) form in your email. The advisor and student must sign the PSR form.

Your Proposal Analyst will direct you to the appropriate budget template for the fellowship, help you to comply with sponsor guidelines, and review your full proposal prior to submission.

For additional information, see Fellowships and Detailed Proposal Process.

Five Day Business Rule

OCG has a Five Business Day Rule for all proposal submissions. According to this rule, the PI must send a completed and signed Proposal Submission Request (PSR) form and budget to his/her assigned Proposal Analyst at least five business days prior to the sponsor deadline.

If you submit the PSR form and budget details to your Proposal Analyst without at least five business days’ lead time, there may or may not be sufficient time to thoroughly review your proposal. Your Proposal Analyst will handle such situations on a case-by-case basis.

If you’re submitting a proposal through Grants.gov, we highly recommend submitting at least two business days before the deadline. It can take several hours to several days for Grants.gov and the specific agency to process and approve your proposal. Any errors that occur after a deadline, regardless of when you receive notification of an error, will prevent submission and acceptance of your proposal.

Foreign Currency

The University is participating in an increasingly global world, which has many positive benefits but also creates some challenges. One of those challenges is accepting research paid in a foreign currency.

Accepting an agreement in a foreign currency creates Foreign Exchange Risk for the University. To address this risk, a foreign currency reserve will be required as a budget item (along with bank transaction fees) for all sponsored projects where payment is made in a foreign currency.

The Office of Contracts and Grants (OCG) Proposal Analyst will budget an estimated amount during the proposal stage. The OCG Grant or Contract Officer will attempt to negotiate favorable language during the agreement review. The Sponsored Projects Accounting (SPA) Cash Management Accountant will provide information about cash receipts compared with the budget.

While these actions are attempts to mitigate the risk, the Principal Investigator (PI) and the department are ultimately responsible for the project, and the decision to accept such an agreement will require an acknowledgement of the responsibility for this risk.

Read the full Foreign Currency Procedure Statement

Foreign Currency Risk Acceptance Form

Fringe Benefits

Fringe benefits are non-salary expenses, such as contributions to University health and retirement plans, which the University must pay on behalf of employees. We are required to charge fringe benefits for all CU employees listed on a sponsored project budget. Fringe benefits are charged as a direct cost and calculated as a percentage of the employee salary. The rates we use are based on our Federally-negotiated rate agreement with the Department of Health and Human Services.

The current fringe benefits rates can be viewed on the Campus Controller's website.

Your Proposal Analyst will help you determine the appropriate fringe benefit rate to charge for each of the project personnel on your budget.

Graduate Students Working on Sponsored Projects

Graduate Research Assistants (GRAs) working on a sponsored project are paid according to the University’s GRA Salary sheet found in our Frequently Needed Information. These are monthly rates based on full-time employment for a GRA, which is 50% time during the academic year. The salary rates are negotiated annually between departments and the Graduate School, and any deviation must be approved prior to proposal submission by the Graduate School.

All graduate students working during the academic year must receive tuition remission according to the University’s official Tuition Rates. The 9+ credit hour rate is used for graduate students working 50% time. A reduced rate will be applied for graduate students committing less time (e.g. the 5 credit hour rate for GRAs working 25% time) according to the Graduate Student Appointment Manual.

Your Proposal Analyst will help you determine the appropriate salary and tuition to charge for any graduate students included on your sponsored project budget. For additional information, view the Memorandum of Understanding with Regard to the Method Used to Budget Tuition on Sponsored Project Proposal Budgets.

Implementation of OMB Uniform Guidance

The Federal Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles, and Audit Requirements (“Uniform Guidance”), 2 CFR Chapter 1, Chapter II, Part 20 is effective as of December 26, 2014 for all federal proposals and awards made under the Uniform Guidance (UG). The UG consolidates and supersedes existing OMB Circulars, including A-21, A-110, and A-133.

For more information on CU Boulder's implementation of the Uniform Guidance, visit our Uniform Guidance page and the OCG Uniform Guidance Implementation Practices document.

Indirect Cost Addendum

Sponsors occasionally limit the amount of indirect costs, or Facilities and Administrative Costs (F&A), that we may charge to a sponsored project. Whenever a government or non-profit sponsor caps indirect costs at a level below our Federally-negotiated rate, or disallows the charging of indirect costs altogether, an Indirect Cost (IDC) Addendum is required in accordance with University policy.

Your Proposal Analyst will help you to complete the budget section of the IDC Addendum. The Principal Investigator (PI) will need to draft a justification, which should be a brief statement that explains how the proposed research would directly benefit the CU Boulder campus. A strong justification is essential given that the University will lose money if the project is funded. Either the Department Chair or Institute Director will be required to approve the IDC Addendum, and the PI’s justification will help the approver determine the potential value of the proposed project.

Sponsors occasionally specify a limit on indirect costs but do not clarify whether the indirect cost base should be Modified Total Direct Costs (MTDC) or Total Direct Costs (TDC). Whenever this occurs, OCG’s default is generally MTDC for Federal sponsors and TDC for non-Federal sponsors. If a sponsor does specify the base, OCG always follows sponsor guidelines. Your Proposal Analyst will help you choose the appropriate indirect cost base and calculate “computed loss” on your IDC Addendum.

Industry sponsors also occasionally limit the amount of indirect costs that may be charged on a project. If this rate is not due to federal flow through terms and conditions, your Proposal Analyst will guide you through the next steps of working with this sponsor and your budget, including consulting with the Office of Industry Collaboration and taking additional steps as needed depending on the circumstances.

Indirect Cost (F&A) Rates

Indirect Costs, also known as Facilities and Administrative Costs (F&A) or overhead, are institutional costs that are not directly connected to individual research projects but are real costs that institutions incur during day-to-day operations. The total cost of federally sponsored research includes a combination of both direct and indirect (F&A) costs. Some examples* of indirect (F&A) costs include:

  • Personnel in support of research, including security, financial, administrative, technical, maintenance and janitorial staff
  • Radiation and chemical safety
  • Secure data storage, telecommunications and high-speed data processing
  • Utilities - ventilation, heat, air conditioning, water and lighting
  • Library and research facilities
  • Advanced research lab equipment
  • Costs of federal, state, and local regulatory compliance including human and animal safety review boards

*Examples from the Council on Governmental Relations Costs of Research Infographic

CU’s indirect cost rate is negotiated with the Department of Health and Human Services (DHHS) and this is the rate we must use on sponsored project budgets. It is extremely important that CU Boulder receive full reimbursement for indirect costs whenever possible.

CU Boulder charges indirect costs on sponsored projects according to our Federally-negotiated Indirect Cost (F&A) Rate Agreement. Your Proposal Analyst will ensure that the appropriate indirect costs are charged on your sponsored project budget.

Additional Information and Resources

Current F&A rates, F&A rate history and the rate agreement on the Campus Controller's Office website

Understanding Facilities and Administrative (F&A) Costs handout for more information on what is included in F&A costs

Council on Governmental Relations F&A Resources

Indirect Cost Recovery (ICR) Split

An Indirect Cost Recovery (ICR) split means that, if awarded, a portion of the indirect costs will go to one department and the other portion will go to another or multiple departments. There are two main reasons why an ICR split may be needed:

  1. The Principal Investigator (PI) has a dual appointment (meaning s/he is employed at two CU departments or research institutes)
  2. Project personnel from multiple departments are involved

PIs must note any ICR splits on the Proposal Submission Request (PSR) form. Your Proposal Analyst will need a copy of the Memorandum of Understanding (MOU) for any standing split agreements. If the split is unique to the particular proposal, then Chair/Director email approval will be required from all Departments or Institutes affected by the proposed split.

If Post-Doctoral Research Associates, Graduate Research Assistants,or other CU employees are from units other than the primary unit, the ICR split must be negotiated on a case-by-case basis by the PI and department heads/institute directors. Email approvals from the Chair/Director must be sent to the Proposal Analyst.

The primary reason we collect ICR split information at proposal stage is to avoid project set-up delays if the proposal is awarded. If all of the ICR split information is in place at proposal stage, your Grant or Contract Officer can process the award more quickly, since it may take significant time for Chairs/Directors to determine the appropriate split.

Indirect Cost Waivers

Indirect Cost Waivers are required when, for any reason other than sponsor requirements, a Principal Investigator (PI) would like to request less than full indirect costs in the budget. See the University’s Waiver Policy for details.

Please be aware that Indirect Cost Waivers are very rarely granted given the importance of indirect costs to CU’s overall operations. Your Proposal Analyst can help answer any questions you may have on this topic.

If you will be requesting an Indirect Cost Waiver, the request must be submitted at least five business days before a deadline. Requests submitted after this deadline will not be considered.

Industry Proposals

The Office of Industry Collaboration (OIC) was formed in July 2013 in order to enhance partnerships between CU Boulder, industry and business. Visit the Office of Industry Collaboration website to learn more about how they can help you collaborate with local, state, national, and international industry and business partners.

If you plan to submit an industry proposal (i.e. the sponsor or funding agency is a private company), you will need to work with the Office of Industry Collaboration. It is important to involve the OIC as early as possible at proposal stage to help ensure that we are appropriately budgeting for the project and fulfilling any other special industry requirements. The OIC may also help you negotiate favorable terms and conditions in an award agreement. You may contact OIC directly or your Proposal Analyst will contact the Office on your behalf when notified of your proposal to a private sponsor.

Institutional Animal Care and Use Committee (IACUC) Approvals

If you plan to use animals in your research, you will need to involve CU Boulder’s Institutional Animal Care and Use Committee (IACUC). The primary function of the IACUC is ensure University compliance with all state and federal regulations surrounding the humane care and use of animals in research and teaching.

Sponsors do not normally request IACUC approval at time of proposal submission, but Prinicpal Investigators (PIs) should consult with IACUC and request approvals in a timely manner. Keep in mind that NIH requires IACUC approval at the just in time (JIT) stage, and, if awarded, a project SpeedType will not be setup until approval has been obtained.

If you are unsure whether or not your project requires IACUC review, visit the IACUC website. If you are a new researcher or need more guidance on animal research, see IACUC’s Getting Started page.

Institutional Review Board (IRB) Approvals

If you plan to conduct research on human subjects, you will need to work with CU Boulder’s Institutional Review Board (IRB). The purpose of the IRB is to help ensure that human subject research is conducted in an ethical manner and in compliance with all Federal and University guidelines.

Sponsors generally do not request IRB approval at proposal stage, but it is important to obtain any necessary approvals in a timely manner. Note that NIH requires IACUC approval at the JIT stage, and, if awarded, a project SpeedType will not be setup until approval has been obtained.

If you are a new researcher or a veteran looking for more information, please visit the IRB’s Getting Started page in order to understand all of the requirements surrounding research on human subjects. The IRB can also help you to determine whether or not your research requires IRB Review.

Visit IRB's Common Questions for more information.

Leave / Sabbaticals

Research faculty planning a leave of absence or sabbatical that is 90 days or more must contact your Contract or Grant Officer. When there is a reduction in personnel effort by the approved project director or Principal Investigator (PI) on an award, prior approval must be requested from the sponsor in advance for those budget deviations when there is disengagement from the project for more than three months, or a 25 percent reduction in time devoted to the project.

You will need to submit a brief written statement addressing your involvement and effort on each of your ongoing research awards and how these will be covered during your leave. OCG will supply a complete list of your ongoing research awards. The written statement(s) need to be submitted to OCG prior to the start of your leave.

Please note, you are still responsible for any reporting requirements that come due during your leave. Contact OCG Reports if you would like a complete list of reports that will be due during your leave.

Reference

Uniform Guidance 2 CFR 200 for Federal Awards §200.308 Revision of Budget and Program Plans states:

  1. Recipients are required to report deviations from budget or project scope in accordance with this section (b).
  2. Recipients must request prior approvals from Federal awarding agencies when there is disengagement frm the project for more than three months, or a 25 percent reduction in time devoted to the project, by the approved project director or principal investigator. (c)(3)

Limited Submission Proposals

Certain program guidelines may specify a limit on the number of proposals per institution that may be submitted. If you identify a funding opportunity that stipulates an institutional submission limit, contact your Proposal Analyst as soon as possible. There may already be an internal competition in place to determine which Principal Investigators may submit to that announcement. If a competition is not yet in place, your Proposal Analyst will work with the Research and Innovation Office to determine whether a competition is needed or if you may move forward with your application.

For more information about internal competitions, visit the Research and Innovation Office website.

No-Cost Extensions

A No-Cost Extension (NCE) extends the project end date without additional funding. If you would like to receive a No-Cost Extension, contact your Grant or Contract Officer with the following award and extension justification information:  

Request an NCE

Award Information

  • Project Number
  • Award Number
  • Current Period of Performance
  • Requested Extension End Date

Justification for Extension

  • Brief reason for the extension including the reason(s) the project was not completed within the original period of performance
  • Brief summary of work to be accomplished during the extension period 
  • Amount of funds expected to be available on the current end date and the intended use during the extension period
  • If applicable, any updated compliance documents (IRB/IACUC/IBC data)

The request will be submitted according to the procedures of the sponsoring agency. With some sponsors the request will be submitted through an online system, such as Fastlane, NSSC, or ERA Commons. In other situations a request will be submitted via email to the grants official. Please note that there are deadlines for submitting these requests, which will vary according to sponsor requirements.

If additional funding is required, this will still be prepared as an extension (ie. modification), but will not be No-Cost and will require your Proposal Analyst to review your budget.

NOTE: NSF now has a 1200 character limit on no cost extension justifications. OCG does not edit your justifications, it is important to stay within the limit to ensure the sponsor receives all of the information. A brief paragraph for the description of work to be accomplished and the work to date is sufficient.

Other Policy Resources

For other policy resources related to sponsored research, visit the Research and Innovation Office website. Here you will find information regarding Institutional Animal Care and Use (IACUC), Conflicts of Interest, Export Controls, Human Research and IRB, Responsible Research, Controlled Substances, and other relevant topics.

Pre-Award Spending

Generally, a fully executed award agreement is needed in order to set up a SpeedType.

Principal Investigators (PIs) do have the option to request a SpeedType prior to the award being fully issued by requesting to set up an at-risk account. The PI should complete the At-Risk Project Request Form and send it to your department’s Grant or Contract Officer to begin review.

The at-risk award process will vary somewhat depending upon whether the award will be issued as a federal grant or under another funding mechanism. Some examples include:

Federal grant: Under 2 CFR 200 Part 458 (Uniform Guidance) the recipient is allowed 90 day pre-award spending unless disallowed or restricted by the funding agency. The PI will need to complete an At-Risk Project Request Form and then contact your Grant or Contract Officer to request approval.

Contracts, federal grant flow-down, or non-federal grants: The award will require approval from the sponsor to ensure costs prior to the performance start date will be allowed. The PI will need to complete an At-Risk Project Request Form and then contact your Grant or Contract Officer to request approval.

Pre-award costs are limited to 25% of the anticipated award amount and for a period of 90 days. A non-Fund 30 Department SpeedType is required to determine which charges can be transferred in the event that the award is not issued.

Without setting up an at-risk award account, the PI will have to wait for the agreement to be reviewed, accepted, signed and sent through InfoEd and OCG to Sponsored Projects Accounting (SPA) in order for a SpeedType to be set up.

If the award has already been issued and does not explicitly call out Pre-Award spending as authorized, contact your Contract or Grant Officer to request pre-award spending authorization from the sponsor. The sponsor may or may not approve, but if so, it will be noted in the agreement.

Prinicipal Investigator Change on Award

Changing the Principal Investigator (PI) on an award will require sponsor approval. Send a request to your Grant or Contract Officer with the following information:

  • Names of both the current PI and the new PI
  • Project number(s) affected
  • Why the current PI is leaving the award
  • Why the new PI was chosen
  • Impact of this change on the project

Your Grant or Contract Officer will submit the request to the sponsor for approval.

Principal Investigator Eligibility

The University is responsible for complying with all the regulations and other requirements guiding sponsored projects. In order to ensure that such projects are conducted by those with the necessary skills, training, and University affiliations, only employees with a minimum .5 FTE appointment may serve as Principal Investigator in accordance with CU’s PI Eligibility Chart.

If you are not currently eligible to serve as PI on a sponsored project, you will need to obtain approval from your Department Chair, Institute Director, or from the Dean of your assigned College.  Your Proposal Analyst will need email approval on file prior to proposal submission.

Principal Investigator Institutional Transfer

There are multiple steps and approvals required in order to transfer an existing award to another institution when a Principal Investigator (PI) is leaving CU and wishes to transfer active awards.

How the transfer request is initiated is dependent on the sponsor. Some agencies such as NSF and NIH have an online process. In other cases, it may be handled through email correspondence with the sponsor.

Typically a transfer will involve relinquishing the unexpended balance on an award back to the sponsor, who will then reissue it to the new institution.

Required supporting documentation typically includes a budget, budget justification, and statement of work. There may be additional requirements depending on the sponsor. The PI/Department Administrator will need to work with the Grant Accountant to ensure there are no outstanding encumbrances and to determine the final transfer amount.

Your OCG Grant or Contract Officer will submit the transfer request. Prior to doing so, OCG will need a letter signed by the Department Chair, or Director, and the PI stating that the Department does not wish to nominate a substitute PI for the award, stating the effective date of the transfer and the transfer amount, whether there is equipment on the award, and agreeing that the Department will be responsible for any overexpenditures.

Proposals and OCG Involvement

You will generally need to involve your Proposal Analyst whenever you plan to submit a proposal through the University and/or you expect funding to go through the University.

According to OCG policy, you must send your Proposal Submission Request (PSR) formbudget, and budget justification to your Proposal Analyst at least five business days in advance of the sponsor deadline. It is important to contact your Proposal Analyst as early as possible in the process in order to ensure sufficient time to analyze sponsor and program guidelines, help develop your budget, and review your full proposal for compliance with agency and other guidelines.

Preliminary Proposals, also known as concept papers or white papers, do not require OCG involvement unless a budget is included, or if the sponsor requires that an Authorized Official (also called Authorized Organizational Representative, Signing Official, etc.) submit the pre-proposal through OCG. For example, certain pre-proposals must be submitted through NSF FastLane or grants.gov by your Proposal Analyst. If you are uncertain about whether or not to involve OCG, please contact your Proposal Analyst and s/he will help you to make the appropriate determination.

Proposal Submission Request (PSR) Form

All new proposals require a Proposal Submission Request (PSR) form, which must be completed and signed at least five business days prior to proposal submission. The primary purposes of the PSR is to collect important proposal-related information and review areas of compliance in one location. For detailed guidance on completing the PSR form, see the PSR User Guide.

Revised budgets do not require a PSR form. For most supplemental proposals as well as continuation, resubmission and renewal proposals with an original submission within the last 18 months, the Supplemental Certification PSR Form can be used if a PSR form was submitted with the original submission.

Typed signatures are not official. PIs will need to insert a digital signature, or alternatively, use DocuSign or physically sign and scan the form.

Revised budgets do not require a PSR form.

Revised Budgets

Sponsors sometimes request a revised budget after a proposal has been submitted. If an official award has already been issued, you will need to work with your assigned Grant or Contract Officer. If the award has not yet been issued, work with your Proposal Analyst to interpret sponsor requirements and draft a new budget accordingly. Once you have agreed upon a revised budget, your Proposal Analyst will submit the budget per the sponsor’s instructions.

Whenever possible, it is CU’s policy to update salary and fringe benefit rates if they have changed since the time of proposal submission. The indirect cost rates will generally not be updated; the rates used at time of proposal submission will generally be applied to all revised budgets.

Signature Authority

The Office of Contracts and Grants (OCG) is the University’s authorized representative to submit proposals, negotiate and accept sponsored research and service agreements, non-disclosure agreements and material transfer agreements on behalf of the Board of Regents. Sponsored projects proposals and awards go through OCG.

OCG is the University of Colorado Boulder's Authorized Organizational Representative (AOR) and is responsible as the Office of Record for the administration of sponsored research and service agreements and funding on the CU Boulder campus.

Subaward Addition

Adding a subaward that was not on the original proposal will need approval from the sponsor. Your Grant or Contract Officer can assist with this. 

The subcontract institution must provide:

  • Detailed budgets
  • Budget justification
  • Statement of work
  • Sub commitment form
  • IDC rate agreement

Subrecipients

Subrecipients, also known as subawardees or subcontractors, may be involved in certain proposal submissions. If you have any questions regarding whether or not collaborators should be designated as consultants versus subrecipients, contact your Proposal Analyst.

OCG requires the following documents of all subrecipients on a CU sponsored project budget:

  • Signed CU Subrecipient Commitment Form
  • Statement of Work
  • Detailed budget approved by the subcontractor’s grants or business office; a budget submitted on behalf of a subcontractor by our Principal Investigator (PI) is not acceptable
  • Budget Justification in narrative format that must justify all costs in the budget
  • IDC Rate Agreement or a similar document that states their Indirect Cost rate (overhead)
  • APPLICABLE ONLY FOR CERTAIN GRANTS.GOV SUBMISSIONS:
    • R&R Budget Form (Your Proposal Analyst can help determine whether or not an R&R Budget Form is required and share the appropriate form with the subrecipient’s grants or business office.)
  • Some proposals may require other supporting documents such as biographical sketches, current and pending support information, etc. Your Proposal Analyst will help you to determine if additional files are required.

For each subcontractor on a contract proposal or award, the PI must complete and sign a Sole Source Justification form, which should be returned to the Proposal Analyst for inclusion with the subcontractor documents above.  The sole source justification is only required from subawardees for contract proposals and awards and is not required for grant proposals and awards.

In addition to completing the Sole Source Justification and coordinating with subrecipient project members on the technical portions of the proposal, the PI is responsible for reviewing the subrecipient’s Statement of Work and Budget to ensure that they are accurate and reflect what they have agreed upon.