Policies and Procedures
Grant Submission Deadline Policy
The SOM enforces a “5 and 2” policy for grant application submissions. The final Administrative Components of a grant application are due to SOM OGC no less than five business days prior to the sponsor’s deadline. The final Technical Components of the application are then due no less than two business days prior to the sponsor’s deadline. As defined in the policy, these Components include:
|Administrative Components||Technical Components|
|Completed UVA Proposal Routing Form (ePRF) |
[with all necessary approvals]
|Completed, signed sponsor application package/forms|
[excluding Technical Components]
|Abstract (draft)||Abstract (final)|
|Detailed budget and justification||References|
|Regulatory approvals |
|Consortia/third party documentation |
|Institutional Letters of Support|
|Confirmation of sponsor's indirect cost policy|
Applications that fail to meet these requirements will require written permission from the Senior Associate Dean for Research or his/her designee for the proposal to be reviewed and submitted by the Office of Grants and Contracts.
Related Documents (defined as “Documentation requested by a funding agency in support of a Proposal or an award, including non-competing continuation proposals and progress reports”) will be submitted to the Office of Grants and Contracts no less than five business days prior to the deadline. Although no exception approval is required for late submission of these documents, the Office of Grants and Contracts cannot assure compliance with the deadline in the event they are submitted with less than five business days notice.
Please review the SOPs and FAQs for further information.
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Minimum Effort Policy
Principal Investigators/Project Directors must include some level of committed effort on most Federal and Federal flow-through sponsored research activities, unless specifically exempted by the sponsor. The minimum amount of effort committed to a specific Federally-sponsored research activity is at least 1% of the employee’s “University effort.” [http://www.virginia.edu/uvapolicies/Policies/FIN-028v2.html]
The School of Medicine enforces an unofficial policy of “reasonableness” regarding a PI/PD’s effort on all other non-Federally sponsored activities. While no minimum level of effort is required, a PI/PD is expected to budget a reasonable amount of effort commensurate with the requirements of the project on his/her time.
Conflict Of Interest Policy **UNDER CONSTRUCTION**
Conflict of Interest (COI) regulations govern situations in which financial considerations may compromise an investigator’s conduct or reporting of research or his or her procurement decisions made on behalf of the University. Federal and state regulations and University policies recognize that faculty may have financial interests in corporate or other sponsors whose business interests relate to their research. The Public Health Service (PHS) Objectivity in Research Policy uses the following thresholds to define Significant Financial Interests (SFIs): combined income/equity greater than $5,000, any ownership interest in a non-publicly traded company, and/or travel reimbursed or sponsored by an external entity other than academic institutions or government agencies. PHS policy requires that institutions assess the “relatedness” of SFIs to PHS-funded research in deciding
whether a financial conflict of interests exists that would require institutional review and management.
SOM requires that all Investigators annually disclose Significant Financial Interests or confirm the absence of any SFIs in the University’s online Financial Interest Reporting System (FIRS). The system is used to disclose all SFIs related to an Investigator’s institutional responsibilities for externally-funded projects.
The Public Health Service Policy on Objectivity in Research also requires that all investigators on PHS awards (defined as the principal director/project director and any other person who is responsible for the design, conduct, or reporting of research, including collaborators or consultants) must complete training in COI before expending any funds on such awards. The University using the COI training module in the CITI training system to satisfy this requirement. Investigators must be re-trained at least every four years to remain in compliance with the PHS policy.
Graduate Medical Education – Industry Funding Policy **UNDER CONSTRUCTION**
GMEC Policy No. 30 – Industry Funding – This policy applies both to Graduate Medical Education Trainees and Members of the Clinical Staff, within or for the benefit of the Medical Center, regardless of employer. Employees of the Medical Center and of the University are subject to the State and Local Governmental Conflict of Interests Act and the Ethics in Public Contracting Section of the Virginia Public Procurement Act of the Code of Virginia. The GMEC Policy on Industry Funding incorporates the requirements of these acts and applies standards to ensure that financial support from industry vendors or representatives to GME trainees or their supervising faculty members does not influence patient care decisions. The Policy restricts GME trainees from directly accepting from an industry vendor, sales or service representative any of the following items: food or beverage, funds to support travel to and registration for an educational activity, or educational material in the form of textbooks, electronic devises and their applications, or material or devices for simulated training of medical care.
The GMEC Committee would prefer that industry representatives and vendors provide funding for these items in the form of an unrestricted gift to the UVa Health Foundation Development Office. However, industry representatives and vendors may provide support to the Department Chair of the trainee’s program for stipend/benefits and/or travel registration to attend an educational conference under the following conditions: (1) The funding cannot be linked to the training of an individual trainee and the trainee should have no knowledge that funding is being accepted on his or her behalf; (2) Applications for the funding by industry of educational activities must be reviewed and approved in advance by the GMEC Subcommittee on Stipends and Benefits; (3) Applications for the funding by industry for stipends and benefits must be approved in advance by the Graduate Medical Education Committee in addition to following all necessary requirements of the SOM Office of Grants and Contracts; (4) Any application for funding by industry for either stipend and benefits or educational activities my name the Department Chair as the recipient and the Chair must acknowledge that receipt of these funds may be publicly reported under the “Sunshine Act”; and (5) All programs should participate in educational activities pertaining to conflict of interest and relationships with industry.
Additionally, in accepting this funding the Department, Division, or Program must select the training, determine that the funded conference/program has educational merit, and verify that the recipient is not subject to any implicit or explicit expectation of providing something in return for the support.