Chapter 2: Pre-Award

Developing an application or proposal is a shared responsibility between PIs and research administrators. The University employs a decentralized model for administering sponsored awards, so pre-award responsibilities may vary across administrative units. The following outlines common responsibilities,

Typically, a PI is responsible for:

• Identifying funding opportunities
• Developing the technical or scientific section of the proposal
• Securing necessary internal approvals, such as cost share
• Selecting subrecipients (if applicable) and ensuring their statements of work, budgets, and budget justifications are submitted on time

A research administrator typically handles the following tasks:

• Managing the proposal development and submission process
• Collaborating with the PI to prepare the project budget
• Ensuring the proposal complies with sponsor requirements
• Assembling the proposal in InfoED or sponsor-specific system
• Responding to sponsor inquiries and post-submission requests
• Routing the proposal.
  

OGC Pre-Award is responsible for:

• Reviewing and approving the proposal during the routing phase
• Verifying PIs have a financial conflict of interest disclosure on file
• Submitting proposals to most sponsors
• Submitting Just-in-Time requests to NIH
• Maintaining relevant sponsor system credentials and logins.

OGC Pre-Award assigns a Pre-Award Analyst to each administrative unit. Specific questions regarding a proposal should be directed to the assigned Pre-Award Analyst. General inquiries regarding the pre-award process can be emailed to [email protected].

Each college and school within the University sets its own eligibility criteria for a faculty member to serve as a PI on a sponsored project. PI eligibility requirements are found on the Principal Investigator Eligibility website.

PIs are responsible for finding funding opportunities to support their research activities. The University offers two offices dedicated to assisting PIs in locating funding opportunities:

• Office of Research Services – Assists CU Denver faculty
• Office of Research Development and Strategy – Assists CU Anschutz Medical Campus faculty

Additional resources to help PIs find funding opportunities include:

• RP-Pivot - A database available to both campuses, RP-Pivot contains funding opportunities from the federal government, associations, foundations, and international organizations.
• SPIN - A database accessible through InfoED, SPIN includes funding opportunities from the federal government, non-federal sponsors (such as associations and foundations), and international organizations.
• Grants.gov – The federal repository for all competitive federal grant opportunities.
• SAM.gov Contract Opportunities is the federal repository for federal contract request for proposals.
• Federal agency websites, such as NIH, NSF, NASA, and DOE.
• Proposal Central – A resource for non-federal opportunities..

Limited Submissions

Some funding opportunities limit the number of proposals that the University may submit. For these limited submissions, PIs must first complete an internal competition at the University and be selected before developing and submitting a proposal to the sponsor. The University’s Limited Submission Funding Opportunities website lists these restricted opportunities and provides instructions for completing the internal selection process.

The funding opportunity should be thoroughly reviewed before deciding to submit a proposal. The announcement will provide important details, including instructions on how to apply, submission deadlines, funding restrictions, application requirements, selection criteria, and post-award requirements.

 Key sponsor information to note includes:

• Formatting requirements (e.g., font type and size, paper margins, page length)
• Deadlines and other key dates
• Purpose of the funding opportunity and the sponsor’s funding priorities
• Funding availability and restrictions on specific items of cost
• Budget limitations, including any restrictions on indirect cost rates
• Start date and duration of the award
• Application instructions
• Eligibility criteria, including whether subrecipients are allowed
• Cost share requirements
• Application and submission guidelines
• Review criteria
• Post-award requirements
• Program-specific terms and conditions

OGC Pre-Award is responsible for submitting all proposals that require Authorized Organizational Representative (AOR) submission, which includes nearly all federal awards. If AOR submission is not required, the PI or their respective administrative unit will submit the proposal to the sponsor according to the internal procedures of the administrative unit.

Internal deadlines for routing may vary depending on who is responsible for submission. PIs and their respective administrative units are accountable for meeting all University and sponsor routing and submission deadlines and assume full responsibility for any late proposal submissions.

When reviewing a funding opportunity announcement, it is important to identify the sponsor's requirements for how the proposal should be developed and submitted. For federal awards, the funding opportunity should be reviewed to determine if Grants.gov or a System-to-System (S2S) application can be used. When S2S can be used, the proposal must be developed and submitted through InfoED. For all other proposal development and submission requirements, the proposal will need to be created in the sponsor-specified portal and routed internally using the manual routing procedures for InfoED.

 Examples of sponsor-specific portals include, but are not limited to:

• ProposalCentral
• Research.gov
• NIH Assist

Administrative units must complete the manual routing requirements for InfoED when a proposal is developed in a sponsor-specific portal.

PIs applying for an NIH account are required to have an NIH eRA Commons account. The Commons account must be associated with the University. To establish or update an eRA Commons account, PIs must complete the eRA Commons Access Request Form and submit the form to OGC Pre-Award at [email protected].

ORCiD (Open Researcher and Contributor Identification) is a unique identifier used to distinguish individual authors and contributors. Many federal research agencies require PIs and other senior or key personnel to provide their ORCiD in proposals and other required documents.

Additional information about ORCiD, including how to create an account, is available on the University’s ORCiD website.

The format and contents of a proposal depend upon the sponsor’s requirements. The following list identifies and explains common proposal elements.

• Cover page or proposal form: Most proposals include a form requiring institutional information and relevant project data. Federal agencies often require the use of the SF-424 for non-research awards or SF-424 (R&R) for research awards. Commonly requested information for the proposal form includes:
  • Institutional information
  • Identification of the sponsor’s program, such as funding opportunity announcement and, for federal awards, the Assistance Listing (CFDA) number
  • Project title
  • Project start and end dates
  • PI information
  • Amount of requested project funding
  • Authorized Organization Representative (AOR) contact information and signature.
• Abstract or proposal summary. The abstract summarizes the major aspects of the proposed project, including the proposed project’s hypothesis, specific aims, objectives, significance, and expected results. Most sponsors limit the length of the abstract.
• Project Narrative. The project description outlines the project, its purpose, relevance, and implementation. Each sponsor has specific guidelines for this portion of the proposal, including page limitations and formatting requirements. Common sections in the project narrative include:
  • Introduction
  • Specific aims or objectives
  • Background
  • Research strategy and description
  • Plan of work
  • Timeline
• Bibliography or references cited. This section lists all references cited in the proposal, including the PI’s own publications. The required format may vary by sponsor.
• Biographical Sketch (BioSketch). Many sponsors require biographical sketches for all senior and key personnel, including PIs, co-investigators, and other significant contributors. Sponsors may have different format, naming conventions, and content requirements, but they typically request education background, appointments, research experience, and publications for each key individual.Budget and budget justification. Sponsors typically request a detailed budget that identifies cost categories and an accompanying justification for each cost.
• Budget and budget justification. Sponsors typically request a detailed budget identifying cost categories, along with a justification for each cost.
• Facilities and other resources. This section provides information on the available facilities and other resources for the project, such as lab or office space, library resources, equipment, or unpaid personnel. Sponsors use this information to assess the university’s resources for carrying out the proposed project.
• Data Management. This section details how the PI will share their research data, including primary data, samples, physical collections, and other supporting materials created or gathered. Additional information, resources, and templates can be found on the Research Informatics Projects website.
• Current and pending support. PIs may need to identify all current funding and submitted proposals. This section ensures the sponsor that the researcher is not overcommitted and helps identify potential overlaps with other projects. Failing to disclose duplicative proposals on federal awards may lead to administrative, civil, or criminal sanctions.
• Compliance documents. Depending on the sponsor and the type of proposed project, the PI may need to submit various compliance documents. Sponsors may require this information at the time of the proposal or as a condition of funding. Compliance documents may include:
  • Institutional Review Board (IRB) approval for human subject research
  • Verification of Human Subjects Training
  • Institutional Animal Care and Use Committee (IACUC) approval
  • Institutional Biosafety Committee approval for recombinant DNA research
  • Conflict of Interest documentation
  • Compliance with federal disability laws
  • Sponsor and program-specific requirements
• Attachments and appendices. Some sponsors may allow appendices to be included with the proposal. PIs may add figures, charts, protocols, representations, certifications, letters of support, or other supplemental materials. However, appendices cannot be used to bypass page limitations in the project description. Sponsors may limit what can be included in the appendices.

Institutional information and other commonly requested data elements can be found on the University’s FDP Clearinghouse profile.

Cost share refers to the portion of a project's costs not covered by the funding agency, but instead paid by the University or other sources. This may include both cash contributions and in-kind contributions, such as donated services. Cost share obligations cannot be met through a salary differential with the PHS Salary Cap and usually cannot be met by using sponsored funds from another project.

There are two types of cost sharing in the pre-award phase:

• Mandatory Cost Sharing: Required by the sponsor as a condition for receiving the award.
• Voluntary Committed Cost Sharing: Offered by the University, even though it is not required by the sponsor.

Cost sharing is generally not appropriate on projects sponsored by for-profit entities. For federal research awards, 2 CFR 200.306 prohibits the use of voluntary committed cost sharing as a factor during the merit review process, unless otherwise required in the funding opportunity announcement.

Cost sharing may be funded by:

• Unrestricted General Fund programs,
• Auxiliary and Self-Funded Activity Fund programs, and
• Gift Fund programs.

The University discourages the use of voluntary committed cost sharing, as it strains University resources and imposes additional administrative burdens

The Cost Share Request Form must be included in the routing when cost share is included in a proposal.

Additional information on post award cost sharing requirements can be found on the OGC Cost Sharing website and in Chapter 4 of this Handbook.

A budget reflects the costs necessary for the successful completion of the project. Failure to include all relevant costs in a proposal budget during the pre-award phase can lead to delays, cost overruns, and other significant issues during the post-award phase.

Any cost included in a proposal must comply with sponsor requirements, the funding opportunity announcement, and University policies and procedures.

The total costs of sponsored research include both direct costs and indirect costs, also known as facilities and administration costs. Both types of costs are essential for a project’s success.

• Direct Costs: Costs directly associated with a project and necessary to meet the project’s objectives.
• Indirect Costs: Costs that benefit research in general but cannot be directly attributed to a specific project, such as utility and infrastructure costs, administrative salaries, and office supplies.

Direct costs are included in a proposal budget as estimates and are charged to the sponsor based on actual costs incurred during the post-award phase. Sponsors reimburse the University for indirect costs through an agreed-upon rate. For federal awards, the University negotiates an indirect cost rate agreement with the federal government every five years. This agreement, known as the Negotiated Indirect Cost Rate Agreement (NICRA), is published on the OGC website.

Additional information regarding the University’s indirect cost rates is found in 2.13 Indirect Costs.

 

The University has two policies governing faculty compensation:

• Faculty Compensation – Anschutz Medical Campus
• Faculty Compensation – University of Colorado Denver

2.13.1 Salaries and Wages

Each employee who will directly work on a project must be included in the proposal. All personnel should be listed, and the amount of effort for each employee needs to be identified. Effort should be shown as a percentage of full-time effort or in person-months, depending on sponsor requirements. For person-month requirements:

• Employees on an annual contract must have their effort reflected in calendar months.
• Employees on a 9-month contract must have their effort reflected in academic months and summer months.

The salary request is based on an employee’s institutional base salary (IBS) as reflected in HCM.

Some sponsors impose a salary cap, which limits the amount of funding provided for salaries and wages. There is a Congressional imposed salary cap for awards made by Public Health Service agencies, including NIH. Current PHS and NIH salary cap requirements are found on the NIH Salary Cap, Stipends, and Training Funds website.

Time and effort commitments in proposals need to be carefully scrutinized. Reductions in time and effort commitments during the post-award phase generally require prior sponsor approval. No employee may be committed to more than 100% effort, which encompasses all University activities. It is typically expected that a PI will commit at least 1% of effort to a sponsored project. In total, PIs should commit no more than 90-95% effort to all sponsored project activities to meet other University responsibilities. This specific requirement may vary across administrative units.

Employees on a sponsored project generally need to be classified as either Senior/Key Personnel or Other Personnel. Special consideration should be given when classifying an employee as senior/key personnel, as prior approval may be required to replace those employees during the post-award phase.

Some sponsors will allow for salary escalation to be included in the proposal. If permitted by the sponsor and administrative unit, salary escalation should generally be budgeted at 3% for each budget year. Any salary escalation of 5% or more will require documented approval from the appropriate dean, supervisor, or appointing authority at the time of routing.

2.13.2 Fringe Benefits

Fringe benefits are the cost of benefits paid to personnel working on the grant and are based on the employee’s job code and work location, as listed in HCM. The University requires proposals to include an estimated fringe benefit rate and to charge each employee’s actual fringe benefit during the post-award phase.

The University’s Budget Office releases the fringe benefit estimates annually, which are found on the Fringe Benefit page.

The University’s Employee Fringe Benefit Pools policy provides the guidelines used by the Budget Office in developing fringe benefit rates and the costs included in the rates.

2.13.3 Consultants

A consultant, also known as an independent contractor, is an individual or organization capable of providing a service not readily available at the University. Consultants are typically engaged for short periods to provide services within the project’s scope of work. A consultant is usually paid an hourly rate that incorporates all costs. The consultant’s hourly rate must be reasonable, and sponsors may impose limits on a consultant’s pay.

Any University of Colorado employee, regardless of campus, must be listed as an employee on a proposal and not as a consultant. Consultants do not have intellectual property rights under a sponsored project. Additionally, a consultant may not have any conflict of interest with the PI. For example, a PI should not hire their spouse to be a consultant on a project.

Additional information regarding consultants can be found on the University of Colorado website.

 2.13.4 Equipment and Supplies

Equipment and supplies included in a proposal must be itemized and adequately justified. For federal proposals, equipment is defined as tangible property with a per-unit acquisition cost of $5,000 or more and a useful life of at least one year. Any property that does not meet this definition of equipment must be classified as a supply for federal proposals. The costs of equipment and supplies should be based on catalog prices, quotes, or bids. All associated costs, such as shipping and installation, should also be included.

Computing devices, such as laptops and desktops, included in a proposal must be essential for the project and sufficiently justified. Failure to include the costs of essential computing devices in the proposal can make it difficult to justify charging these costs during the post-award phase.

Costs that are typically classified as indirect costs may be included in a proposal as a direct cost only when adequately justified and when the cost exceeds what the University or administrative unit would typically provide. For example, postal costs should generally not be included in a proposal as a direct cost, but they could be allowed when the project requires the mass mailing of project-related surveys.

2.13.5 Travel

All travel costs included in a proposal must be directly tied to that proposal’s objectives. Travel costs must comply with the University’s travel policy, found at PSC Procedural Statement: Travel and the sponsor’s policies. Funds can be requested for travel to scientific meetings, to conduct fieldwork, to collaborating laboratories, and for consultation with the funding agency or with colleagues concerning project research. Travel must be classified as either “domestic travel” or “foreign travel” in accordance with sponsor definitions.

Travel costs include expenses for transportation, lodging, subsistence, and related items incurred by employees in travel status on official business related to a sponsored project. Such costs may be charged on an actual basis or on a per diem or mileage basis in lieu of actual costs. If per diem is used for budgeting purposes, the first and last day of travel can only be charged at 75% of the allowable per diem rate.

2.13.6 Subagreements

Subagreements are agreements by which some scientific or programmatic aspects of a grant made to the University are contracted out to another organization or institution under the direction of a non-University investigator. Before including a subagreement in a proposal, the PI must fully understand and accept all responsibilities and administrative burdens associated with subrecipient monitoring, as well as the potential audit risks related to subagreements.

The proposal submitted to the sponsor must include evidence of commitment from the subrecipient, a scope of work, a proposed subrecipient budget, and any other forms required by the sponsor. Most sponsors do not allow adding a subrecipient during the post-award phase without prior approval.

For federal awards, the University must accept a subrecipient’s negotiated indirect cost rate unless the funding opportunity announcement specifies a different indirect cost rate. Additionally, the proposal budget must include the first $25,000 of each subagreement’s total budget as part of the indirect cost rate pool. This requirement does not apply to subagreements made from the University to other University of Colorado campuses, as outlined in the AB Nexus agreement.  

The University prohibits the use of fixed-amount subagreements for all federal awards. All subagreements included in a federal proposal must be cost-reimbursable subagreements.

 2.13.7 Research Patient Care Costs

Research patient care costs may only be included in a budget when allowed by the funding opportunity announcement. Research patient care costs include the costs of routine and ancillary services provided by hospitals to individuals participating in research programs.

Research patient care costs do not include:

• The otherwise allowable items of personal expense reimbursement, such as patient travel or subsistence, consulting physician fees, or any other direct payments related to all classes of individuals, including inpatients, outpatients, subjects, volunteers, and donors.
• Costs of ancillary tests performed in facilities outside the hospital on a fee-for-service basis (e.g., in an independent, privately owned laboratory) or laboratory tests performed at a medical school/university not associated with a hospital routine or ancillary service.
• Recruitment or retention fees.
• Data management or statistical analysis of clinical research results.

2.13.8 Participant Support Costs

Participant support costs are direct costs that support participants and their involvement in a sponsored project. Participants are individuals who engage in or attend program activities under a sponsored project, such as training or conferences, but who are not responsible for implementing the project. Individuals, including University employees, committing effort to the development or delivery of program activities under a sponsored project are not considered participants. Participants may include U.S. citizens, permanent residents, or foreign nationals. A participant must have a social security number (SSN) or an individual taxpayer identification number (ITIN).

Participant support costs may include the following:

• Event registration fees
• Stipend for housing and subsistence allowance
• Travel costs when the sole purpose of the trip is to participate in the project activity
• Event support costs for lodging and food expenses paid directly to the event facility, only if the payment is made on behalf of, or reimbursed directly to, the participant
• Meals and incidentals when on travel status
• Per diem paid directly to or on behalf of participants
• Training materials

 Study subject payments are not considered participant support costs.

Careful consideration must be given when including participant support costs in a proposal. Most federal sponsors require prior approval before rebudgeting participant support costs during the post-award phase.

Inclusion of participant support costs in a proposal must adhere to sponsor requirements and the notice of funding opportunity. Some sponsors, such as NIH, have specific definitions for “participant support costs.” The sponsor’s definition will govern their awards.

2.13.9 Trainee Costs and Student Tuition

Costs associated with trainees and fellows must adhere to the sponsor requirements. Tuition costs for student workers may be included in the budget when allowed by the sponsor.

Additional information about the allowability for graduate student costs for CU Anschutz Medical Campus can be found in the University’s Graduate Student Assistantships and Tuition Remission Policy.

CU Denver permits student tuition to be included in sponsored budgets in accordance with 2 CFR 200.430, 2 CFR 200.466, and sponsor policy. Tuition is considered a fringe benefit and should not be paid in lieu of salary. The inclusion of tuition in sponsored projects varies by school/college. In general, student tuition may be included in sponsored budgets when the student’s activity for the sponsored project is tied to their degree program. This typically limits tuition coverage to graduate students conducting thesis-related research. Undergraduate tuition may be budgeted when the sponsor permits and when the student’s activity for the sponsored project and their degree program align with the sponsored project. Tuition rates also vary by school/college and can be found at the CU Denver Tuition & Fees website.

2.13.10 Internal Service Centers and Core Laboratories

Costs related to internal service centers and core laboratories must be based on a fixed rate established by the center or laboratory through a cost study.

The University’s Internal Service Centers and Core Laboratories Policy provides guidelines for establishing, budgeting, costing, administering, and accounting for internal service centers and core laboratories. 

2.13.11 Study Subject Payments

Study subjects may be compensated for their involvement in a clinical trial, protocol, or survey. The University’s Study Subject Payments Policy establishes the procedures and methods of payments to study subjects. These procedures and methods of payment will also need to be detailed in the IRB approved consent forms.

2.13.12 Other Direct Costs

Other direct costs necessary for a project can include, but are not limited to: publication costs, animal costs, equipment maintenance, and rental fees. All other direct costs must conform to sponsor requirements and be classified according to sponsor and University requirements.  

Indirect costs are facility and administrative (F&A) costs that support research and are necessary for University operations but are not readily identifiable with a specific project. Indirect costs include, but are not limited to:

• Building bond costs
• Utility costs
• Equipment depreciation
• Operations and maintenance, such as custodial and police services
• Departmental administration
• Sponsored project administration

Proposal budgets must apply the appropriate indirect cost rate, as identified on the University’s Facilities and Administrative Cost Grid, which is reproduced below.   

Primary Fund Source	Project Type	On-Campus	Off-Campus	Cost Base Type
Sponsors including but not limited to Federal, Federal Flow-Through, State, State Flowthrough	Organized Research	56%	26%	MTDC
Instruction	42%	26%	MTDC
Other Sponsored Projects	30%	26%	MTDC
Clinical Trials	56%	26%	MTDC
Private Industry	Organized Research	56%	26%	MTDC
Instruction	42%	26%	MTDC
Other Sponsored Projects	30%	26%	MTDC
Clinical Trials	28%	28%	TDC
Proof of Concept Awards (POCg)	All Types	8%	8%	MTDC
Non-profit Associations and Foundations (Sponsor Policy or 10% if no Policy)	All Types	10%	10%	TDC

Complete the following process to determine the correct indirect cost rate to use on sponsored projects:

• Step 1 – Identify the sponsor
  • When the university is the recipient of a subagreement, use the indirect rate for the prime sponsor type.
  • Proof of Concept awards are used in the commercialization of an invention.  The use of this rate is specific to certain CU Innovations/state partnership programs such as Colorado Office of Economic Development and International Trade (OEDIT) Advanced Industries Proof-of-Concept program.
  • Other non-federal and non-profit sponsored projects must have a published, consistently applied policy that establishes a specific indirect cost rate for the project for that rate to be honored by the university. For sponsors that do not have an established policy, the proposal must initially use an indirect cost rate of 10% TDC.
• Step 2 – Identify the project type
  • The federal definitions of organized research, instruction, and other sponsored projects are found in Appendix III of 2 CFR 200.
• Step 3 – Identify if the project will be conducted on or off campus
  • This determination is based on where the majority of the work will be conducted
  • Verify if any CU buildings physically located on the campus use the off-campus rate or the on-campus rate.
• Step 4 – Apply the indirect rate against the appropriate cost base

Applying the correct indirect (F&A) rate to the appropriate cost base is essential. The two cost bases are:

• Total Direct Costs (TDC). TDC is the sum of all direct costs charged to a sponsored project.
• Modified Total Direct Costs (MTDC). 
  • The following costs are included in the MTDC cost base:
    • Salaries and wages
    • Fringe benefits
    • Materials and supplies
    • Animal resource center costs
    • Services
    • Travel
    • Subagreements and subcontracts up to the first $25,000 of each subagreement or contract
    • Genomic Arrays subject to NIH Policy (NOT-OD-10-097) effective 5/13/2010
  • The following costs are excluded from the MTDC cost base:
    • Equipment
    • Capital Expenditures
    • Patient Care Costs (when provided by external entities)
    • Tuition Remission
    • Rental Costs (Building Rental Costs)
    • Scholarships
    • Fellowships
    • IRB Fees
    • Portion of subagreements and contracts in excess of the first $25,000

The University’s indirect cost rate must be applied unless a sponsor requires the use of a lower indirect cost rate, as indicated in the funding opportunity notice or other guidance. For example, NIH only allows an 8% indirect cost rate for Training (T) awards and does not allow for indirect costs for conference grants or fellowships.

A PI may submit a waiver to request the use of a lower indirect cost rate. The waiver request must be submitted during proposal development. Please note the following regarding the use of a lower rate:

• A PI may not negotiate an indirect cost rate with the sponsor.
• A waiver should only be requested in rare, exceptional circumstances
• The University HIGHLY DISCOURAGES the use of a lower indirect cost rate
• A private sponsor should be charged the same rate as federal government
• The PI must submit a request through the F&A Waiver Process
• The University must approve the request before a lower rate can be used in the proposal
• The University will reject all waivers that are associated with a for-profit entity
• For federal research awards, the use of a lower rate in a proposal cannot be used in the decision-making of the federal sponsor

Additional information about the waiver process is found on the OGC website.

The University’s Fiscal Policy for Facilities and Administrative Costs details the distribution of indirect cost recovery to administrative units.

 

For certain NIH activity codes, a modular budget may be submitted instead of a detailed budget. While the use of a modular budget does not require the submission of a detailed budget to NIH, a detailed budget and budget justification must be included in the routing to OGC.

Additional information about NIH modular budgets is found on the NIH Develop Your Budget website.

Federal research proposals generally require PIs and senior/key personnel to report other active and pending support to ensure there is no scientific, budgetary, or commitment overlap. “Other Support” is sometimes referred to as “current and pending support” or “active and pending support.”

 Other Support includes all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether or not they have monetary value and regardless of whether they are based at the University. This includes but is not limited to:

• Grants, Cooperative Agreements, and Contracts from the following sponsor types:
  • Federal (e.g., NIH, Department of Defense)
  • State (e.g., Colorado state agencies, other state funding entities)
  • Non-federal (e.g., professional societies, disease foundations)
  • Foundations (e.g., American Heart Association, Susan G. Komen Foundation)
• Sponsored Research Agreements (SRAs) from industry sponsors
• Clinical Trial Agreements (CTAs)
• Internal Awards made through competitive institutional processes (e.g., CU Anschutz or CU Denver pilot grant awards)
• Any funding or resources provided with expectations of time, services, or deliverables in return (Note: NIH does not require reporting of “gifts,” which are defined as resources provided with no expectation of return. Similarly, training awards, prizes, and gifts are not required to be reported.)
• Support for Non-Employee Scientists (NES) or Visiting Scholars working in a PI’s laboratory when funded by an external source (domestic or foreign, including self-funding).
• Resource support from external organizations, including in-kind contributions (e.g., laboratory space, equipment, supplies, personnel).
  • For foreign resources, NIH requires supporting documentation (contracts, grants, agreements, or appointment/employment documents). If these documents are not in English, the PI and their respective administrative unit are responsible for providing accurate translations.
• High-value in-kind resources not freely available (e.g., unique animal models, cell lines).
• Consulting arrangements involving research activities.

Responsibilities of PIs and senior/key personnel include:

• Disclosing new sources of Other Support as soon as they become aware of them
• Working with their respective administrative unit, OGC, and/or the Office of Regulatory Compliance to determine when disclosures to sponsors are required
• Participating in the preparation of Other Support documentation and providing their signature attesting to its accuracy
• Complying with all applicable sponsor requirements

2.16.1 NIH Requirements

Effective October 1, 2025, NIH requires recipient institutions to provide training and to implement a written and enforced policy for PIs and senior/key personnel on the requirements on the disclosure of Other Support.

 

In addition to the responsibilities described in section 2.16, for NIH proposals and awards, PIs and senior/key personnel are also required to:

• Complete required training on Other Support
• Submit accurate Other Support documentation to NIH:
• At Just-in-Time, when requested by NIH
• With the annual RPPR
• As necessary, when new support arises during the project period of active NIH awards

 Failure to comply with University and NIH requirements may result in proposal rejection, delays in project set-up, disallowed costs, or suspension or termination of the award.

Compliance will be effective for applications submitted on or after January 25, 2026.

Additional information and University-specific resources are available on the Office of Regulatory Compliance’s NIH Training Requirements website.

2.16.2 NSF Requirements

Information for NSF reporting requirements for Current and Pending (Other Support) are found on the NSF Documents Requirements for Senior/Key Personnel website.

2.16.3 Department of Defense (DoD)

Disclosure requirements for DOD proposals vary by agency. PIs and their respective administrative units should carefully review and follow disclosure guidance in the specific DoD proposal solicitation.

 

All extramural requests for program funding and sponsorship, including grant applications, contract proposals, or other proposals for research, training, or service support, must obtain institutional authorization prior to being submitted to the sponsor or pass-through entity. Routing is completed via InfoED. It is the PI and administrative unit’s responsibility to meet all routing deadlines and requirements. Routing deadlines are dependent upon who is responsible for submitting a proposal.  

 The following table identifies routing deadlines. 

The following documents must be routed:

• Routing form (i.e., Approval of Application for Grant or Contract) electronically signed by PI, Department Chairperson, and applicable Dean or Administrator via InfoEd eRA.
• Clinical Trials Supplemental Budget and Certification​ (CU Denver Fiscal Policy 4-01) industry-sponsored contracts only
• Sponsor's instructions (for non-NIH sponsors only)
• All forms required by the sponsor. The information should be complete, and all signatures (except institutional endorsement supplied by Grants and Contracts) should be obtained, prior to routing.
• Budget pages. Regardless of the sponsor’s budget requirements, routings for competing grants should include detailed budget pages or spreadsheet for the entire project period. Routings for non-competing years of a project should include budget information on the Routing form, but additional detailed budget information is not necessary unless the sponsor requires it.
• Salary increase verification. If the PI’s salary in the proposal is above UCD allowable proposal inflationary increases (5%), documentation of the approved salary increase from the appropriate dean, supervisor or appointing authority must be included as an internal document with the routing.
• VA MOU. For any person who is listed in the proposal budget who has a dual appointment with the VA, their current fully executed VA MOU must be included with the proposal routing as a required internal document.​ All other documents (e.g., biographical sketches, other support pages, letters of support) to be submitted to the sponsor.
• If any of the funds will be contracted to other organizations, please include the following from the subrecipient organizations:
• All forms the sponsor requires for subrecipients. The information should be complete and must bear institutional endorsement from the subrecipient organization.
• Budget pages. Budget figures should always be supplied by the subrecipient in order to insure the proposed subrecipient budget is in line with the subrecipient's institutional policies.
• Budget justification
• Scope of work
• Any and all other documents that will be submitted on behalf of the subrecipient (e.g., biographical sketches, other support pages)  

All applications and proposals route to OGC must be in a complete and final format upon receipt and include the Routing Form, other required internal forms, approval signatures, a print-out of all parts of the grant application, including attachments, and a print-out of instruction materials (non-NIH Sponsors only).

Additional information about routing requirements is found on the OGC website.

Many sponsors will request additional information regarding a proposal after the initial sponsor review. These requests are frequently time-sensitive, and failure to provide the requested information by the sponsor’s deadline will generally result in proposal rejection. OGC must submit all required documents when AOR submission or signature is required by the sponsor.

NIH uses Just-in-Time (JIT) procedures to request certain proposal documents that were not due at submission. A JIT could request Other Support, certification of IRB approval, or verification of IACUC approval, among other documentation.

PIs may receive JIT requests from NIH after it has completed its initial review of the proposal. A JIT does not constitute funding. All requested materials must be uploaded into eRA Commons, and OGC is required to submit the requested documents to NIH.

Additional information about JITs is found on the OGC website.