Charlie, I'll try again.

Some people at a university are authorized by some process to approve
proposals on behalf of that institution.  These people are the ones
whose name should appear in section 19 of the 424.
Grants.gov tells universities to delegate some people to be allowed
to send proposals to Grants.gov.  These people are AOR's.
NIH tells universities to delegate some people to be SO's.  These
people have certain rights within the eRA Commons including receiving
notification that an electronic application has been accepted into
the Commons and rejecting accepted applications at the request of the
PI.  SO's can also see the status of a proposal.

These are all roles within the grants world, typically in a
University Grants Office.  The roles are application approver, SO and
AOR. Each role has certain rights. It is possible for various people
in the Grants Office to have all or only some of these roles or rights.

The application approver must approve the application but need not be
the person to send it to Grants.gov.  Yet the application approver
should be the person named in section 19, "Authorized
Representative." Another person may be delegated to send the
application to Grants.gov, once it has been approved.  This sender is
the AOR.   The name of the who sends the application, the AOR, shows
up on the last line of section 19 -- signature of Authorized
Representative.  If the person who approved the application is not
the same person who sent it, then there will be two different names
on the application.  This might lead to confusion by the grant agency
-- why two different names?

I am suggesting that to make the process less confusing, all the
names should be the same.  If the AOR who submits the application is
not the application approver (Authorized Representative), then the
AOR should use the Authorized Representative's name.  When the EBiz
POC registers an AOR for the University, that person's name and
address are used in the Credential Provider section, and in the
Grants.gov process.  However, each AOR is given the user name of the
Authorized Representative.  All AOR's have their own userid and
password so each submission can be tracked back to the person how did
the submission.

This step is merely to save grants agencies from having to worry
about how a University
handles its internal approval process. All they need to know is:  the
grant has been approved by someone authorized to do so and it has
been sent by someone authorized to do so.  The fact that the grant
comes through Grants.gov means the EBiz POC has approved the sender.
Each University can have its own rules for whom to approve.  We
approve only Grants Office staff, for example.  The grants agency can
assume that the application has been approved by the person listed in
section 19, and that person is authorized to do so.

Giving the SO role to people who are not authorized to sign
applications is necessary to allow grants office staff to do their
various functions.  Until NIH has the forthcoming rights, instead of
roles, system in place, it is necessary to give the SO role to people
who do not have all the rights associated with it.  People other than
the application approver need to be able to look at application
status and other SO functions.  People given the SO role perform only
those tasks which the University business rules give them. For
example, I am delegated to be an SO but I do not approve anything. I
check on status, do AA functions, I will reject a successful
submission if asked to do so by the person who is authorized to
approve applications, I will make necessary changes to the
Institutional Profile.  I do not approve eSNAPs (but will help PI's
with them) or JOT; nor to I delegate faculty to submit eSnaps.

In general, I am suggesting that Grants Office officials make life
easy for their staff; using their own business rules to manage
proposal submission and other related tasks.  Electronic systems
should not make things more difficult and need to be subject to
University processes.

Clearer?

Bob
xxxxxx@umich.edu

On Jun 22, 2006, at 1:17 PM, Charlie Hathaway wrote:

I am confused.  How did you push the submit button (and enter the AOR
user name etc) if you are not the AOR?

IF the answer is that the AOR gave you this info, I think this kind
of INFORMAL delegation of authority is a larger and potentially more
dangerous issue than arguing over whether an AOR should be an SO.  If
someone other than an AOR can be submitting, then why not hand out
the AOR log-in info to every PI?

An institution has an EBiz POC who decides who can be an AOR.  These
people submit.  IF they happen to have true signature authority (as
defined long ago), fine.  If they do not, fine.  Let's not confuse
true signature authority with the realities of the need for FORMAL
delegation of this authority to AORs (a Grants.gov role) and SOs (an
NIH role).

Bob...I don't get this giving different people the same name???  Are
you doing some RESADM genetic engineering?

Charlie

At 12:54 PM 6/22/2006, you wrote:
> Yesterday we submitted our first ever GG proposal, an NIH AREA
> grant.  After receiving only two minor warnings from ERA Commons'
> end everything is fine, but we did wonder about the two different
> names of section 19's Authorized Rep and the signature line.  I
> called GG and was told it did not matter to their system
> (obviously, as the proposal went on to the Commons), but that each
> agency might treat any matter differently.  I called the Commons
> help line and was told the two different names did not matter as
> long as both persons were fully registered with ERAc.  However, as
> I was the person who pushed-the-button and 'signed' for the
> submission I have to rely on the 'authorized rep' to forward any
> messages, which is not a problem in our two-person office, but
> still an annoyance so from now on we will have the rep and signer
> be the same person.
>
>> I am the designated person who oversees grants at my university.
>> Prior to submission, all proposals must go through a routing
>> process and ultimately the Provost must sign off. With that said,
>> I am the person responsible for submitting proposals to the
>> funder. I have a Grants.gov application going out next week and I
>> want to try to prevent as many problems as possible. My question...
>>
>> According to Grants.gov I am an AOR.
>> According to eRA Commons I am an AA. (The Provost is the SO.)
>>
>> Is this a problem?
>
>
> Carmen Silva
> Assistant Director, Office of Sponsored Projects
> University of San Francisco  (LM132)
> 2130 Fulton Street, San Francisco, CA  94117-1080
> office: 415/422-5203; fax: -6222; e-mail: xxxxxx@usfca.edu
> http://www.usfca.edu/osp/index.htm
>
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