Compliance Roles by Unit

• Financial Compliance
• Animal Care & Use Program
• Human Subjects
• Significant Financial Interest
• Environmental Health and Safety

Financial Compliance

Principal Investigator

• Salary certification
• Faculty effort certification
• Purchase orders
• Authorize purchase of goods and services or delegate the authority to do so
• Transfer of expenditures or delegate the authority to do so
• Document Cost Sharing
• Monitor to ensure expenditures are allowable and within budget limitations
• Seek required prior approvals
• Assumes accountability for deficits or disallowances that occur under a grant or contract account

Department Administrator

• May provide assistance or guidance to PIs with regard to fiscal oversight on grants and contracts and compliance with regulations
• Ensures purchase orders are submitted online

Departmental Chair

• Approve advances
• Approve faculty effort certification in absence of faculty member
• Consult with faculty on deficits

Dean

• Signs advances or delegates to the chair
• Establishes systematic procedures in the college for supervision of
  grant and contract accounts
• Provides reasonable coordinated administrative support for the management of grant and contract accounts
• Consults with principal investigators concerning the resolution of deficits or disallowances incurred on a grant or contract account and fixes responsibility for settling the problem quickly.
  

Central Office (OSP/GCA/HSD/Animal Subjects)

• Provides guidance on compliance (OSP)
• Provides guidance on financial compliance (GCA)
• Manages property (EIO)
• Establishes new accounts (OSPGCA)
• Prepares financial status and federal cash transaction reports (GCA)
• Prepares requests for reimbursement (GCA)
• Manages cash (GCA)

Vice Provost/ Vice President

• Oversight of management of grant and contract fiscal policy and operations

Animal Care & Use Program

Principal Investigator

• Fills out IACUC protocol and submits
• Renews protocol for approval
• Certifies that they're responsible for all animal subjects use on project

Department Administrator

• May have delegated authority from PI

Departmental Chair

• Has institutional responsibility for faculty members within their department

Dean

• Has institutional responsibility for faculty members within their school/college

Central Office (OSP/GCA/ HSD/Animal Subjects)

• Provides side-by-side review of grants and associated IACUC protocols to ensure accuracy of IACUC approval date (Animal Subjects)
• Verifies that IACUC review has been performed for all grant proposals involving animals (OSP)

Vice Provost/ Vice President

• John Coulter is designated by President as the Institutional Official for the animal care and use program

Human Subjects

Principal Investigator

• Fills out protocol and submit to HSD
• Certifies training requirements met for all key personnel
• Submits forms for renewal of protocol
• Submits modifications of protocol

Department Administrator  

• May have limited delegated authority from chair

Departmental Chair

• Signs all new applications attesting to scientific merit and investigator qualifications

Dean  

• Signs all new applications involving departmental chairs (or their equivalents) attesting to scientific merit and investigator qualifications

Central Office (OSP/GCA/HSD/Animal Subjects)  

• OSP provides review of grants
• Human Subjects reviews protocol and approves as appropriate, Human Subjects fills out federal assurance (310) form

Vice Provost/ Vice President  

• Serves as Institutional Official for human subjects issues

Significant Financial Interest

Principal Investigator

• Submits disclosure with GC-1 on all investigators, including self, having SFI
• Identifies any SFI on human subjects application

Department Administrator

• Facilitates flow of paperwork, no formal authority

Departmental Chair

• Reviews and approves initial SFI disclosure
• May participate in oversight or other activities as part of Vice Provost's final management plan

Dean

• Reviews and approves initial SFI disclosure
• May participate in oversight or other activities as part of Vice Provosts final management plan; For the School of Medicine, conducts detailed SFI review and makes recommendation to Vice Provost, using advisory committee (CCR) as needed

Central Office (OSP/GCA/HSD/Animal Subjects)

• OSP routes disclosure to Vice Provost for Research and notify Human Subjects if required
• Advises NIH of SFI in appropriate cases; Authorizes funds expenditures upon approval of Vice Provost

Vice Provost/ Vice President

• Reviews disclosure and determines management plan using conflict advisory committee (COFIAC) as needed
• Distributes plan to affected investigators, Chair, Dean, OSP, HSD and other relevant parties; For the School of Medicine, requests Dean's office to conduct initial detailed SFI review and make recommendation

Environmental Health and Safety

Principal Investigator

• Discloses use of hazardous or regulated materials on GC-1
• Signs and submits statement of responsibility on EH&S "Research Project Hazard Assessment" form. EH&S refers projects to institutional health and safety committees for review and approval as appropriate
• Is ultimately responsible for compliance with all required environmental, health and safety mandates in work and laboratory areas and for appropriate shipping of materials; Must gain additional approvals from Responsible Official and EH&S if working with select agents
• Must contact EH&S in advance for required environmental compliance signatures and approvals requiring signature

Department Administrator

• May have delegated responsibility for specific aspects of environmental health and safety compliance
  • record keeping
  • health and safety
  • committee support and participation, etc.

Departmental Chair

• Has primary responsibility, along with Deans and Directors, for department's environmental health and safety compliance and for providing a safe and healthful work environment
• Participates in Select Agent Security Review

Dean

• Has primary responsibility, along with Chairs and Directors, for department's environmental health and safety compliance and for providing a safe and healthful work environment; Health and Safety Committees report to Deans

Central Office (OSP/GCA/HSD/Animal Subjects)

• OSP reviews GC-1 and notifies Environmental Health and Safety if required

Vice Provost/ Vice President

• Has ultimate responsibility, along with Deans and Directors, for department's environmental health and safety compliance and for providing a safe and healthful work environment.