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Policy and Procedures

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Compliance Roles and Responsibilities, by Unit

  Financial Compliance Animal Care & Use Program

Human Subjects

SFI Environmental Health and Safety

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
  • Fills out IACUC protocol and submits
  • Renews protocol for approval
  • Certifies that they're responsible for all animal subjects use on project
  • 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
  • Submits disclosure with GC-1 on all investigators, including self, having SFI
  • Identifies any SFI on human subjects application
  • 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 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
  • May have delegated authority from PI
  • May have limited delegated authority from chair
  • Facilitates flow of paperwork, no formal authority
  • 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

  • Approve advances
  • Approve faculty effort certification in absence of faculty member
  • Consult with faculty on deficits
  • Has institutional responsibility for faculty members within their department
  • Signs all new applications attesting to scientific merit and investigator qualifications
  • Reviews and approves initial SFI disclosure
  • May participate in oversight or other activities as part of Vice Provost's final management plan
  • 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
  • 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.


  • Has institutional responsibility for faculty members within their school/college
  • Signs all new applications involving departmental chairs (or their equivalents) attesting to scientific merit and investigator qualifications
  • 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
  • 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)
  • 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)
  • 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)
  • OSP provides review of grants
  • Human Subjects reviews protocol and approves as appropriate, Human Subjects fills out federal assurance (310) form
  • 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
  • OSP reviews GC-1 and notifies Environmental Health and Safety if required
Vice Provost/
Vice President
  • Oversight of management of grant and contract fiscal policy and operations
  • John Coulter is designated by President as the Institutional Official for the animal care and use program
  • Serves as Institutional Official for human subjects issues
  • 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
  • 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