Approver(s):

Academic Council

Authorizes Release:

Chief of Staff for the President

Responsible Area:

Office of Sponsored Projects, Academic Research and Compliance (SPARC)

Review Cycle:

Annually or as required

Last Review:

April 2026

Related Policies and Additional References:

None

Scope

Potential principal investigators (PIs) seeking to develop a proposal for a sponsored project must adhere to this policy, which provides directives for proposal approval, submission, and the completion of the Notice of Intent (NOI) form. Those interested in pursuing funding must contact the Office of Sponsored Projects, Academic Research, and Compliance (SPARC) for assistance before beginning the submission process. SPARC is the central administrative office responsible for sponsored projects, supporting pre-award development and post-award management and compliance with all federal, state, sponsor, and institutional policies and regulations. All sponsored projects must have a completed NOI before proposals can be submitted to a funding agency.  

Exceptions

Faculty and staff who are applying for financial assistance that will be awarded outside their period of appointment and that will not be managed by the university, who are applying for internal faculty research grants, or who will not be using any University resources to accomplish the project activities, are not subject to this policy. President and Provost sponsored project initiatives, such as pursuing federal appropriations, are not subject to this policy.

Policy Outline

  • A. Notice of Intent
  • B. PI Eligibility and Approval Requirements
    • a. Eligibility
    • b. Institutional Approvals
    • c. Exceptions
  • C. Proposal Development
    • a. Limited Submission Opportunities
    • b. Stakeholders and Resources
  • D. Budget Development
    • a. Budget Principles
    • b. Budget Periods
    • c. Personnel Compensation
      • i. Faculty
      • ii. Staff
      • iii. Student
    • d. Fringe Benefits
    • e. Indirect Rate
    • f. Cost Share
  • E. Proposal Submission
  • F. Compliance: University Policies, Federal Regulations, and Sponsor Requirements

A. Notice of Intent

The Notice of Intent (NOI) is a document that (i) communicates to appropriate institutional stakeholders the intention to develop and submit a proposal for a sponsored project, (ii) facilitates the internal review process of proposal content and activities, including budget, resource, space, and/or facilities requirements, and (iii) serves to formalize institutional approvals during proposal development. The NOI can be accessed through SPARC’s Award Processes webpage on Gateway. PIs are responsible for contacting a research administrator from SPARC for support in completing and routing the NOI. PIs may be required to submit additional information along with the NOI form as determined by SPARC before it can be submitted for the approval process. In terms of timetable, the NOI should be completed and submitted at least six weeks in advance of a proposal submission deadline to ensure time for adequate review and institutional approval to submit.  Should significant changes to the proposal emerge after the NOI has been fully executed, SPARC will either reroute the NOI for approval or ensure approval through appropriate consultation. 

B. PI Eligibility and Approval Requirements

a. Eligibility

To be eligible to serve as a principal investigator (PI) or project director (PD) must have the skills, knowledge, and resources necessary to carry out the proposed activity. Serving in this role requires an individual effectively to represent the University to the project sponsor(s), comply with existing federal, state, and local laws, following University policies, fulfill the expectations of award agreements, and supervise project staff. The PI must be a full-time faculty or staff member with the support of their department chair and dean/divisional supervisor. A visiting or adjunct faculty member or staff can serve as co-principal investigator or key personnel on a project. The SPARC Director and Provost need to approve any other special circumstances. 

b. Institutional Approvals

All sponsored projects at St. Mary’s University must be consistent with the mission, strategic goals, and capabilities of the University. The components of the proposed project must comply with University policies and sponsor, federal, state or local government regulations. Individuals contemplating the development of proposals for external funding must seek and obtain approval from relevant parties within the University early in the development process by completing and routing of the Notice of Intent(NOI) form. For faculty PIs, approvals are required from the department chair, academic dean, SPARC, and the Provost and Executive Vice President for Academic Affairs (VPAA). For staff, approvals are required from the department supervisor, division vice president, SPARC, and Provost and Executive Vice President for Academic Affairs.

c. Exceptions

Additional approvals may be required from other University offices depending on the scope of the project as determined through the NOI process and confirmed by SPARC. Documentation of these approvals is required before a submission to the funding agency.  For example, proposals including campus renovations require approval by Facilities Services.

C. Proposal Development

a. Limited Submission Opportunities (LSO)

An LSO is an external funding program that is open to all applicants but for which the sponsor or funder restricts the number of applications per institution. In some instances, the number of individuals from St. Mary’s wishing to respond to an LSO may exceed the limitation imposed by the funding agency. In these instances, SPARC will facilitate review of pre-application proposal materials to make a determination regarding which proposal(s) will be sponsored by the University for submission. The determination will be based on the following criteria: consistency, fundability, contribution and impact, and institutional commitment.

  1. Consistency refers to how well a proposal’s goals align with and advance the University’s goals, values, and mission.
  2. Fundability refers to the likelihood that a proposed activity will be successful in receiving funding from the program; guidance may be sought regarding fundability from the funder’s program officers; additional guidance may be sought from external subject matter experts and/or internal stakeholders.
  3. Contribution and impact refer to the contribution to institutional or individual goals.
  4. Institutional commitment refers to the financial and/or non-financial burden placed upon the institution in implementing proposal activities.

Consistency refers to how well a proposal’s goals align with and advance University goals, values, and mission; Fundabilityrefers the likelihood that a proposed activity will be successful in receiving funding from the program; guidance may be sought regarding fundability from the funder’s program officers; additional guidance may be sought from external subject matter experts and/or internal stakeholders; Contribution and impactrefer to the contribution to institutional or individual goals; Institutional commitmentrefers to the financial and/or non-financial burden placed upon the institution in implementing proposal activities.

b. Stakeholders and Resources

PI must contact SPARC and key stakeholders early in the development process to ensure compliance with university policies, sponsor guidelines, and the availability of institutional resources, including space and facilities. Stakeholders need to understand their role and contribution to the project. These commitments should be conveyed in the Notice of Intent Form.

D. Budget Development

a. Budget Principles

Budgets must comply with funding agency requirements and university policies. Project costs must be allowable, allocable, reasonable, and consistent with both the sponsoring agency and university policies. PI must clearly explain the resources needed, including institutional commitments, to complete the project objectives. The university is not responsible for grant activities once the project has ended or terminated with the funding agency unless there is a written agreement.

b. Budget Periods

It is important to establish budget periods in order to distinguish when faculty will be paid over the academic year. For grant purposes, the academic year will be from August 15 to May 15. The Fall semester will be from August 15 to December 31, and the spring semester will be from January 1 to May 15. The summer will be recognized from May 16 to August 14.

c. Personnel Compensation

All potential PIs, co-investigators, and other key personnel on proposed sponsored projects should:

  1. obtain appropriate approvals for commitments of time or effort in a sponsored project, doing so early in the process of proposal development and before proposal submission;
  2. honor the time commitments they propose, such as devoting a specified percentage of time to a sponsored project, regardless of whether any portion of their salary is charged to the project budget. All effort must be certified by the PI and project personnel. When effort is committed during the fiscal year, it must comply with the guidance outlined below.
  3. Adhere to the university’s compensation policies and sponsor regulations, including incremental pay increases.  Federal funding complies with the Uniform Guidance, 2 CFR 200.430 Compensation – Personal Services, unless grant-specific requirements exist.  

i. Faculty Compensation

Faculty members are generally appointed to 9-month contracts known as the “academic year,” leaving three summer months with no contractual obligations. All forms of compensation must adhere to the university’s policies and sponsor regulations.  Fringe benefits will be applied based on the time and effort allocated to the grant. Faculty can allocate time and effort in different ways on a grant:

  1. Course Release
    • Faculty can receive a course release during the academic year of August to May. Using their Institutional Base Salary (IBS), one three-credit course is equivalent to 12.5% effort over 9 months for either the fall or spring semester. When a faculty member estimates that this percentage of effort or greater is required to accomplish project activities, they may request course release. Any commitment less than 12.5% will not be considered for course release. Requests for a course release must be made to the supervising department chair and dean. Course releases must be approved by the supervising chair, dean, and provost, giving consideration to the teaching needs of the department or other considerations.
  2. Summer Pay
    • Faculty can receive up to the equivalent of 1/3 of their IBS as additional compensation over the three summer months. Compensation will be calculated using their IBS, # of summer months, and percent effort committed to the sponsored project
  3. Additional Duties
    • Faculty can receive compensation for additional duties outside their 9-month contractual obligations. Compensation is based on university standard practices, market value and in accordance with the faculty handbook and HR policy, but may not exceed IBS.
      • For example: Faculty can be also compensated for curriculum revisions that comply with grant objectives. The amount and type of compensation must be negotiated and agreed upon with the faculty member’s respective dean.

To ensure reasonableness and consistency with university policies and sponsor agency requirements, requests for compensation related to sponsored project activities that would result in a faculty member exceeding 100% total effort over a 12-month period will be reviewed and approved by SPARC, the department chair, dean, and Human Resources.

ii. Staff Compensation

Full-time staff members are generally employed on a 12-month appointment.  Staff salary and wages charged to a grant should reflect the time spent on the project and must conform to university policies and sponsor requirements. Staff compensation must be based on the staff member’s institutional base salary or hourly wage.

  1. Time Release
    • With the approval of the staff supervisor, staff can be released time from their regular duties to work on a grant using their institutional base salary to estimate time and effort. The designated time and effort will be charged to the grant. Additional compensation is not provided with time release. This is not overtime; this is work completed within your regular work schedule within the 40-hour workweek.
  2. Additional Duties
    • Staff must adhere to the university’s policy regarding Additional Pay for Additional Duties.  Additional pay must be for work performed outside the staff member’s regular duties.  Additional pay is generally intended for temporary assignments and above the 40-hour workweek.

iii. Student Compensation

Student compensation must be based on the scope of work and grant objectives.  All forms of compensation must adhere to university policies and sponsor requirements. Students can be compensated in the following ways:

  1. Hourly Wages
    • Students with an employer-employee relationship, who maintain a work schedule and are assigned job-specific duties must be compensated using an hourly wage and submitting timesheets in accordance with HR’s payroll schedule.
  2. Participant Support Stipends
    • Stipend compensation is a periodic payment other than wages paid to a student in connection with educationally related activities undertaken by a student.  Stipends can be issued as a scholarship, fellowship, financial assistance or related to other incidental expenses related to educational or research training expenses.  Stipends cannot be issued based on services rendered.
    • Research Training Stipends (RTS)
      • Research training stipends fall under the participant support stipends. This form of payment is specific to training grants with educational or research training expenses that would otherwise be uncompensated. Compensation is based on participation with no expectation of work effort or timesheets.   This form of payment is a fixed sum of money provided to individuals participating in a research training program, intended to cover their living expenses while they focus on their research studies that would otherwise be uncompensated.  RTS is not considered a salary for services rendered but rather a form of financial assistance to facilitate their research participation.

d. Fringe Benefits

University fringe benefit rates must be applied to personnel costs unless prohibited by the funding agency. Information regarding the fringe benefit rates is posted on the SPARC Gateway website, Fringe Benefits.

e. Indirect Rate

Indirect costs will be assessed using the negotiated indirect rate approved by the federal agency or sponsor, where applicable. The University recovers facilities and administrative costs through the indirect recovery of each sponsored project. Indirect costs are operating costs necessary to conduct sponsored activities that cannot be directly allocated to a single project. The University has a federally negotiated indirect cost rate with the Department of Health and Human Services (DHHS) and is used for all sponsored projects where allowed. Budgets must apply the appropriate indirect rate unless otherwise restricted by the funding agency. Indirect costs represent an allocation of the real costs of the facilities and infrastructure that house University research and programs. The failure to burden sponsored awards with their share of these costs forces the University to pay for them and diverts resources from other approved and budgeted University functions and priorities. See the indirect recovery distribution policy.
Appropriate application of the federally-negotiated F&A rate is described in GAP 200.330, Facilities and Administrative Costs on Sponsored Projects. The process for reviewing costs that in unlike circumstances may be billed directly to a sponsored project is described in GAP 200.360, Charging Clerical and/or Administrative Expenses to Federally Funded Projects.

f. Cost Sharing

Contributing resources not covered by the grant is considered cost sharing and is considered only in rare circumstances, such as when it is required by the sponsoring agency or in the best interests of the University. If the sponsor mandates cost sharing, the principal investigator must secure funding from the appropriate university resource prior to the proposal submission using the Notice of Intent form. If sponsor guidelines do not permit budgeting for course releases or the amount of the sponsor funding available is insufficient, a department chair may still grant release time. However, in those cases the onus is on the department chair and the PI to find resources internal to the department to cover the release time after undertaking a strategic assessment of the value of the project to the department and University.

E. Proposal Submission

SPARC Office is the authorized representative and has the authority to submit grants on behalf of the University. PIs will work with SPARC to provide the office with all application components needed for submission at least 3 business days prior to submission. SPARC will review the proposal documents prior to submission to ensure compliance with university policies and sponsor guidelines. PIs are not authorized to submit proposals on behalf of the University unless approved by the SPARC Director. 

F. Compliance: University Policies, Federal Regulations, and Sponsor Requirements

St. Mary’s University requires all individuals who receive sponsored funding to comply with University policies and sponsoring agency regulations regarding the proposing, charging, and reporting of effort on those awards. In cases where there is a difference between sponsor terms and conditions and University policy, the more restrictive policy will be followed.

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