Emory's Routing Process

Emory University requires its faculty, staff, and students to route all proposals for external funding, along with all related documents, through the following internal levels for review and approval prior to submission to an external sponsor:

• PI and all co-investigators
• Division, when applicable
• Department for each PI and co-Investigator
• School or unit for each PI and co-Investigator
• Office of Sponsored Programs (OSP)

This requirement applies to all new, continuation, renewal, revised, and supplemental grants whether for research, training, fellowships or other proposals:

• All types of proposals, whether a grant, cooperative agreement, or contract;
• All types of application systems, whether paper or electronic; and
• All types of external funding sources, whether governmental, nonprofit, or commercial

Applicants should review the policy information provided on OSP's website to ensure awareness of and adherence to Emory routing requirements.

The schools and units have specific responsibilities with regard to proposals submitted by their departments. These responsibilities include:

• Confirming the individual's eligibility to be a Principal Investigator
• Determining the consistency and compatibility of the proposed project with the objectives of the department and school or unit
• Determining the appropriateness and availability of staff time, space, equipment, and University financial resources committed in the proposal
• Approving any funds committed as cost sharing
• Ensuring the proposal conforms to School policies and sponsor guidelines
• Confirming budget accuracy—including salary, fringe benefits and F&A calculations—and adherence to University and sponsor guidelines

Proposals should be submitted to OSP in complete and final form no later than 5 working days prior to the agency deadline. This time allows OSP to conduct a full and thorough review and to address any potential problems with electronic submissions that could be beyond OSP control. Applications received after this time will be reviewed as completely and promptly as possible in the order received, given volume and time. Complex projects, such as program project grants, require a longer review period due to their nature and this should be taken into consideration when routing.

Complete proposal submission to OSP also includes EPEX routing. Individuals preparing proposals should allow sufficient time for reviews by the department and school or unit. Individual schools and units may have their own guidelines for submission timing. Please consult your school- or unit-level research office for further guidance.

If OSP receives a complete proposal 5 or more business days prior to the sponsor due date, OSP will provide a full review within two business days of OSP receipt. A complete proposal includes both a fully-routed EPEX record and fully finalized proposal in any electronic submission system or paper format.

If a proposal is received less than 5 business days prior to the sponsor's due date, OSP's priority is to get it submitted through the system and OSP will make every effort to do that.

A full review will include (but not be limited to):

• Review of proposal against guidelines for all required forms (as well as formatting requirements including margins, font, page size, etc);
• Review of proposal to ensure inclusion of all required materials;
• Review of proposal against guidelines for page limitations of various section;
• Review of budget for:
  • Spot check of calculations to ensure accuracy and appropriate methodology;
  • Review for selection of appropriate fringe rate and appropriate calculation of fringe costs;
  • Review for selection of appropriate FAC rate and appropriate calculation of FAC costs;
  • Review for unallowable costs;
  • Consistency between budget and budget justification;
  • Compliance with agency-stated budget limitations;

• Review of budget and proposal materials for committed cost-share (voluntary or mandatory)
• Inclusion of materials not allowed by sponsor guidelines;
• Consistency between EPEX record and agency submission documents;
• Correct representation of effort per sponsor rules, including conformance with agency requirements on effort;
• Compliance with Conflict of Interest (COI)
• Compliance with other regulatory matters, such as IRB, or IACUC policies;
• Presence of appropriate support letters, including consortium letters signed by an authorized official for every subcontract included;
• System validation rules which may prevent submission at any number of levels (such as either Grants.gov or Commons for NIH applications). These include, but may not be limited to validation rules such as:
  • File names which are too long;
  • File names which do not follow agency-required convention;
  • Incorrect eRA Commons user names (for NIH applications);
  • Application sections exceeding stated page limitation;
  • Required information which is missing;
  • Incorrect file types;

• Full substantive review of proposal to review for consistency within the proposal and appropriateness of proposal materials. (Please note that this is an administrative review; OSP does not provide recommendations with respect to the science.)

The Principal Investigator, school or unit, and OSP all have various responsibilities in proposal routing, review, and approval. Review and approval at all levels is managed through EPEX.

EPEX is an electronic proposal routing system. All necessary certifications and approvals, whether at the investigator, department, school or university level, are captured in the EPEX system. Such certification or approval indicates understanding and acceptance of the fiduciary and regulatory obligations pertaining to the proposed research.

All documents required for proposal review must be attached to the EPEX record. These include, but are, not limited to:

• All agency proposal or application forms
• Internal budgets, as necessary
• Investigator Financial Interest in Research Reports
• VA MOUs, if applicable
• IACUC and/or IRB approval letters, if applicable
• COI disclosure forms, as described below
• Internal documents required by the school or unit

The first level of approval on any proposal in EPEX is the certification statement made by the PI and all investigators on the project. The PI specifically certifies to the following statement:

My signature below certifies that:

1. the statements herein are true, complete, and accurate to the best of my knowledge;
2. I am aware that any false, fictitious, or fraudulent statements or claims may subject me to criminal, civil, or administrative penalties;
3. I agree to accept responsibility for the scientific conduct of the project and to provide the required progress reports if a grant is awarded as a result of this application.

The PI and all other investigators also certify to this additional statement:

My signature below certifies that:

1. I am not delinquent on any federal debt;
2. I am not presently debarred, suspended, proposed for debarment, declared ineligible, or voluntarily excluded from current transactions by a federal department or agency;
3. I have not and will not lobby any federal agency on behalf of this award;
4. I am aware and agree to abide with Emory's Drug Free Workplace;
5. I agree to abide with the University's research policies including Sponsored Research and Technology Transfer; and
6. I agree to be bound by the terms and conditions of the outside grant or contract which supports this proposed activity and, in consideration of the information and facilities made available to me by Emory or the outside sponsor, to assign copyright and patent rights to Emory in accordance with the terms and conditions of Emory's Intellectual Property Policy.

Each certification is personal in nature and cannot be provided by proxy or another staff member.

Department and school or unit approval in EPEX signifies review and approval of effort, resources, and financial commitments made in the proposal. It also signifies approval of the science and the project's consistency with department and/or school objectives.

The EPEX record is an internal electronic document and is not submitted to the sponsoring agency. Data from EPEX are managed in Compass for reporting and tracking purposes.

As the central office for the review, processing and administration of sponsored programs, the Emory University Office of Sponsored Programs (OSP) plays a critical role in helping to ensure objectivity in research by assisting researchers in complying with Emory University policies related to conflicts of interest. Toward this end, all investigators (per the definition below) must complete and submit a copy of The Emory University Investigator Report of Financial Interests in Research (PFIRR) form with any proposal being routed in EPEX. Investigator shall mean the principal investigator and any other person (including but not limited to any collaborator, co-investigator, staff member, student and visiting professor) who is responsible for the design, conduct, or reporting of the Research project or proposed Research project. For purposes of this Policy, Investigator shall include the Investigator's spouse or domestic partner and dependent children. At a minimum, per Emory policy, the PFIRR form must be completed for any person whose biographical sketch is included in the proposal; and/or any person whose name appears in the budget or budget/personnel justification. Emory investigators may complete these forms through the eCOI system.

All Investigators are required to report to Emory any Significant Financial Interests that affect, or may be affected by, research on which they are working, including reporting to Emory any known Significant Financial Interests in entities whose financial interests would reasonably appear to affect the Research. If an Investigator reports a Significant Financial Interest related to a Research project on which the Investigator is working, then Emory's OSP, in conjunction with the COI office, will work to ensure that a reported significant financial conflict of interest has been reviewed by the COI office before any funds are expended on an award.

For research that involves subcontractors, subgrantees, or subawardees (collectively "Subrecipients") at other institutions, Emory requires written assurance from Subrecipients that they and the individual Investigators who work for them have a conflict of interest policy that conforms to the requirements of all applicable regulations. If a significant financial interest is identified, Emory will require a specific assurance from the other institution that any such Financial Conflict of Interest has been reduced, managed, or eliminated. Emory, in turn, will report the Financial Conflict of Interest to any sponsor as required under applicable regulations or policies. Any external individual consultants or collaborators who are not working under the auspices of a Subrecipient institution must complete a paper disclosure form. This form must be included with the routed materials in EPEX.