Frequently Asked Questions
Who in the Department of Internal Medicine reviews and approves sponsored programs proposals?
Individuals who review and approve sponsored program proposals on behalf of the Department of Internal Medicine are: Dr. John E. Nestler, Chair, Alfred Dunn, Department Administrator, and Elizabeth Fortune, Associate Administrator for Research.
Typically, proposals should be submitted directly to Rashmi Pershad for review and signature.
Who may submit sponsored programs proposals?
- Any faculty member in the Department of Internal Medicine
- Non–paid faculty who have signed a participation agreement.
- Graduate students, post-docs, residents and fellows may submit fellowship proposals with faculty sponsorship.
- Staff members who have the prior approval or sponsorship of his/her faculty supervisor
- Newly–hired faculty who have signed an employment contract but may not have officially started
Is it necessary to submit a complete, polished proposal?
You may begin routing your proposal for institutional review while still if a draft format if you require additional time to refine the contents of your research plan. However, it is necessary to submit enough of the application to judge what overall techniques are being proposed, what experimental subjects will be used and what general idea is being addressed.
At a minimum, the proposal should include the required “Sponsored Programs Internal Approval Form,” the sponsor’s “face page,” the complete budget for every year in the proposal, the proposal abstract, identification of the key personnel involved in the project, a calculation of the Facilities and Administrative Costs (F&A) and a description of the resources and environment available to the project.
What does the reviewer look for?
Primarily the reviewer is looking to see that you are proposing to do something that meets all ethical research standards and complies with VCU policies with regard to sponsored programs as well as sponsor requirements. The reviewer may make suggestions but will not make a judgment as to the scientific quality of the proposed research.
What is the definition of “COI Investigator”?
The term “investigator describes any individual, regardless of title, role or position, who is responsible for the design, conduct or reporting of research. Individuals with such research responsibilities may be, but are not limited to, senior/key personnel, sub/co-investigator or sub-recipient investigator, medical investigator, collaborator, consultant, student, trainee or research coordinator. Exceptions include those personnel whose research activities are directly supervised. By considering an individual’s degree of independence relative to the research, the Principal Investigator (PI) on the proposal or protocol designates the individuals who meet the definition of “Investigator” for the purposes of conflict of interest reporting.
How does VCU manage conflict of interest with sub-contracting personnel?
All organizations that receive PHS funding must have a financial conflict of interest policy that fully complies with the PHS Final Rule – Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought.
- If a collaborator’s organization can certify they have such a policy, VCU will accept that assurance.
- If a collaborator’s organization (e.g. US small business, foreign university) does not have a conflict of interest policy, the organization may contractually agree to abide by VCU’s policy.
- If the collaborator’s organization will not agree to follow the VCU Conflict of Interest policy, we have the option of pursuing an affiliate appointment for the collaborator through DOIM Human Resources. Such an appointment, if approved by DOIM HR, would be conditional upon the affiliate abiding by VCU policies and regulations, including filing the required Financial Interest Report through the VCU Activity and Interest Reporting System.
The Federal Demonstration Partnership’s Clearinghouse maintains a list of educational institutions and other entities to document that they are in compliance with the PHS Financial Conflict of Interest (FCOI) rules and regulations. This site is expected to be used by PHS recipients to verify the compliance of their potential sub-recipients with these regulations. As the regulation went into effect on August 24, 2012, some institutions may still be entering their certification data.
What does VCU require when submitting a grant that includes a sub-contract to another institution?
When including a sub-award, the following documents should be assembled, submitted as a package, and included as part of the primary grant application package:
- Sub-recipient Commitment Form, completed and signed by the recipient organization’s institutional representative
- Sub-recipient’s F&A Rate Agreement
- Statement of Work specific to the sub-recipient’s site
- Budget pages with justifications (direct and indirect costs)
- Biosketches for key personnel (NTE 4 pages each)
- Facilities/Resources statement (for NIH proposals)
- Any letters of support related to the sub-recipient’s site
- Any other documents as requested by the grant program’s guidelines.
Because of the information required before submitting a proposal for institutional review, PIs are advised to contact their sub-recipient collaborators well in advance of the proposal submission deadline.
How does one complete the Internal Approval Form (IAF)?
All sponsored programs proposals must be accompanied by a Sponsored Programs Internal Approval Form (PDF form or Word form), commonly referred to as the “green sheet.” This form and instructions are available from the VCU OSP website, under “Forms.”