(5) Researcher Responsibilities
(5A) SPONSORED PROJECTS
(5B) INTELLECTUAL PROPERTY POLICY
(5C) OPEN ACCESS POLICY
(5D) USE OF HUMAN SUBJECTS IN RESEARCH
(5E) ANIMAL CARE
(5F) SCIENTIFIC MISCONDUCT
(5G) CONSULTING POLICY
(5H) UNDERGRADUATE RESEARCH PARTICIPANTS
(5A) SPONSORED PROJECTS
For a summary of recent changes to this chapter, see Chapter 9A: Summary of Recent Revisions to this Handbook.
Contents of this page:
I. STATEMENT ON SPONSORED PROJECTS FOR RESEARCH, SCHOLARLY WORK, AND PUBLIC SERVICE
Statement on Sponsored Projects for Research, Scholarly Work, and Public Service
University Responsibilities (To the Investigator; To the Sponsoring Agency)
Proposal Development (Internal Review Procedures Prior to Proposal Submission; What to Submit and When; Internal Review Timetable; Project Management; Proposal Format for Private Foundations and Corporations)
Administration of Sponsored Projects
This statement applies to sponsored activities undertaken within the institutional framework of the University in the fields of research, scholarly work and public service. Sponsored activities shall be understood to include all organized projects supported by funds obtained from the following sources:
1. University grants for specific projects, internally funded to meet University objectives.
2. Institutional grants (funds obtained from extramural sources but allocated internally at University discretion).
3. Project grants from sponsoring agencies other than the University.
4. Project contracts from sponsoring agencies other than the University.
The conduct of sponsored activities at the University will be controlled by the specific statements below and guided at all times by the following primary and basic objectives.
1. The advancement, dissemination, and preservation of knowledge through teaching, research, and scholarship at the undergraduate and graduate levels.
2. The protection and advancement of the interests and welfare of the University.
3. The advancement and protection of the public interest and public welfare.
II. INVESTIGATOR RESPONSIBILITIES
Faculty members who propose to carry out a sponsored program at the University will agree to comply with the following provisions:
A. The project proposed will be carried out within the framework of a regular department or through the cooperation of several departments and will be directed by members of the faculty.
B. The faculty member will assure that the proposed program meets the following qualifications:
1. It is consistent with the overall academic objectives of the University.
2. Adequate facilities and space will be available for the successful conduct of the proposed sponsored activity. The designated and negotiated share of the time and talent of those members of the faculty, technical personnel, student assistants, and staff who have committed to perform the sponsored activity will be made available.
3. The technical capacity of the project personnel to perform the proposed effort effectively and to meet the sponsor’s requirements is assured.
4. It does not divert the University resources from the attainment of the academic goals of the University.
The above will be a basis for evaluation of projects prior to approval by the Associate Vice President for Academic Affairs: Budget and Research (AVPAA:BR).
The budget for the proposed project should be adequate for the work proposed, including allowances for contingencies and salary increases; and any University contribution should be specifically provided for and approved whether in the form of direct or indirect expenses.
The project, whether supported by grant or contract, must not conflict in any way with University administrative regulations or academic policy regarding employment and employee relations, fiscal policy and procedures, purchasing, patent policy, conflict of interest policy, policy on use of human subjects in research, or policy on use of animals in research.
The project, whether supported by grant or contract, must conform with the University standards of academic freedom, including the right to publish results of the investigation.
The acceptance of funds to support a research project shall be construed as evidence that the investigator has agreed to comply with the policies of the supporting agency which are pertinent to his/her project, including meeting deadlines and preparing and publishing necessary reports.
In cases of conflict between the policies of the University and the outside supporting agency, the University policy should have priority. Exceptions must be approved by the appropriate academic and administrative authorities of the University.
C. The faculty member will cooperate with University officials in ensuring that Significant Financial Interests do not bias research or other activities carried out under the auspices of externally sponsored projects.
1. Training in Conflict of Interest Policies and Principles
Each investigator who is/will be responsible for the design, conduct, or reporting of research or educational activities funded by the U.S. Public Health Services (PHS) must complete training in Conflict of Interest principles.
prior to engaging in research related to any grant or conduct funded by the U.S. Public Health Service (PHS);
at least every four years while PHS funding is active;
if the Institutional FCOI policies change;
when the Investigator is found noncompliant with the University's FCOI policy or management plan.
2. Disclosure of Significant Financial Interests
Each investigator who is/will be responsible for the design, conduct, or reporting of research or educational activities funded by federal monies OR funded by other external sources in excess of $10,000 will submit an Annual Disclosure Statement to the AVPAA:BR. Significant financial interests of an investigator's spouse and dependant children must also be disclosed on the Annual Disclosure Statement.
Annual Disclosure Statements should be submitted between the first business day of April and the last business day of April or upon request of the AVPAA:BR. Disclosure must also be made before applying for any PHS grant and within 30 days of any change pertaining to the financial interests of the PI or other decision-making project staff.
In the event that an intentionally undisclosed Significant Financial Interest is discovered, the Research Integrity Committee may remand the Investigator to the University Conflict of Interest Committee for disciplinary action. If the undisclosed Significant Financial Interest is related to PHS-funded research, the AVPAA:BR. is responsible for conducting a retrospective review of the investigator's research and notifying the cognizant agency of all actions taken within 120 days.
3. Review of Significant Financial Interests
All disclosures of Significant Financial Interests will be reviewed by the Research Integrity Committee to determine whether the SFIs constitute conflicts of interest in relation to the Investigator's externally funded research.
4. Findings of Conflict of Interest
In the event that the Research Integrity Committee judges a Significant Financial Interest to constitute a real, potential, or perceived conflict of interest in relation to the funded research or project, a plan must be put in place to manage, reduce, or eliminate the conflict. The management plan may include any of the following or an alternative action deemed reasonable by the committee and the investigator.
monitoring of research by independent reviewers
modification of the research plan to avoid conflicts of interest
disqualification of Investigators from the portion of the funded research that could create conflicts of interest
divestiture from Significant Financial Interests
severance of relationships that create conflicts of interest
disclosure of potential FCOI to all research participants, journal reviewers, and the public.
Failure to comply with the management plan within 60 days or prior to start of work on the PHS-funded project may be grounds for disciplinary action as determined by the University conflict of interest policy.
If an Investigator is found to be in noncompliance, or if research results are found to be biased as a result of the FCOI, the Research Integrity committee and the Investigator will devise a mitigation plan and the AVPAA:BR will report all actions taken to the cognizant agency.
5. Record-keeping and disclosure related to Financial Conflicts of Interest
If the FCOI finding is related to PHS-funded research, the AVPAA:BR will notify the cognizant agency of the following information within 60 days of becoming aware of the FCOI:
Project Director/Principal Investigator (PD/PI) or Contact PD/PI,
Name of Investigator with FCOI,
Whether FCOI was managed, reduced, or eliminated,
Name of the entity with which the Investigator has an FCOI,
Nature of FCOI, e.g., equity, consulting fees, travel reimbursement, honoraria,
Value of the financial interest, and
A description how the financial interest related to PHS-funded research and the basis for the institution's determination that the financial interest conflicts with such research.
The AVPAA:BR will be responsible for documenting all actions taken by the University with respect to each significant financial interest. Relevant documents will be retained for 3 years after the completion of the grant, where completion is marked by the date of submission of the final expenditures report.
In the case of findings of FCOI, the AVPAA:BR is responsible for completing annual reports about FCOI findings and mitigation actions to the cognizant federal agency and making up-to-date FCOI information available within five days of any request.
All financial disclosures must be updated during the pendency of a research award, either on an annual basis or as new reportable significant financial interests are obtained.
III. UNIVERSITY RESPONSIBILITIES
A. To the Investigator
The Office of the Vice President for Faculty and Student Affairs is the central office charged with maintaining an overview of the internal research commitments of the University as well as research, training, demonstration, equipment, and course improvement projects sponsored by external sources.
When a proposal by a faculty member to undertake a sponsored program has been signed by the AVPAA:BR, the University is understood to have assumed certain general and specific obligations to the investigator:
1. An appropriate and reasonable adjustment in teaching requirements may be made to permit a faculty member to carry out a program for which sponsorship is being sought.
2. Equivalent full-time responsibilities will be based upon teaching loads customary in each department. As an example, half of such a teaching load plus half-time devoted to sponsored responsibilities will be considered full-time activity.
3. The University will provide administrative assistance to aid faculty in the conduct of approved sponsored projects including maintenance of records.
4. The appropriate department(s) of the University will provide and maintain adequate space, facilities, utilities, and equipment for the conduct of the sponsored program.
5. Under no circumstances will either an individual’s existing tenure privileges or University contract salary be affected by reason of involvement in approved sponsored programs.
6. The University will not without just cause cancel or withdraw any commitment it has made in accepting a grant or contract for sponsored support with regard to such items as facilities, professional assistance, or an appropriate share of the time of the personnel concerned.
7. Failure of the University to meet the obligations specified herein shall be appealed to the VPFSA and then to the President of the University.
B. To the Sponsoring Agency
In accepting a project for sponsored effort the University assumes all obligations specified or referred to in the award vehicle. In addition, the University accepts the following general obligations to a sponsoring agency:
1. A staff will be maintained to provide adequate control over expenditures of grant or contract funds and property; this staff also will prepare and submit the necessary fiscal reports as required by the sponsor.
2. For such purposes as maintenance of records and fiscal controls, provision of facilities and space, purchasing procedures, and property control, the University will not discriminate in its policies and administrative controls between its own funds and those obtained from a sponsor.
3. Personnel salaries and employee benefits paid from extramural funds will be consistent with University rates and standards and with the policies of the granting agency involved.
4. The use of federal funds will comply with OMB Circular A-21, the grant or contract instrument, and its accompanying guidelines and instructions. The use of non-federal funds will comply with the sponsoring agency guidelines.
IV. PROPOSAL DEVELOPMENT
A. Internal Review Procedures Prior to Submission of the Proposal
Before a proposal may be sent to either a government agency or a private sponsor, it must go through Institutional Internal Review. This assures that institutional policies and contributions of resources are appropriate and approved by the Chair and appropriate administrators. Consideration of the following procedures will contribute to how easily a proposal moves along.
1. Make certain that the departmental Chair and the AVPAA:BR are kept apprised of any departmental or institutional responsibilities or commitments which are included in your proposal, and that they understand all of the implications of future commitments by the institution if the project is funded. Unsolicited and some solicited grants and contracts may require cost-sharing which is commonly provided by the contribution of faculty or support personnel time or non-federal, institutional funds.
2. If you request faculty time for the project, be sure to get prior approval from the faculty member’s departmental Chair and the AVPAA:BR.
The teaching load for all regular full-time faculty members is set at 12 hours per semester or 24 hours in a year. For faculty members holding distinguished professorships, the teaching load is the same. Of those 12 hours, the normal, actual teaching load for full-time regular faculty members is 9 hours per semester or 18 hours per year. For distinguished professors, the actual teaching load is 6 hours per semester or 12 hours per year. The release of 3 hours per semester for regular full-time faculty and 6 hours per semester for distinguished professors is considered research-related time. Therefore, on the receipt of a grant or contract to perform research in which the grant or contract provides for faculty salaries and the purchase of faculty time, the contract and grant monies would be used, first, to offset the time that the faculty member is paid to do research. In other words, the first 25 percent of salary for regular faculty members and the first 50 percent of salary for distinguished professors would not result in any reduction of teaching loads. Only when the amount of salary recovery exceeded those percentages would the issue of teaching load reduction be discussed. These provisions, of course, apply only to faculty members on 9-month contracts and apply only during the term of those 9-month contracts.
Requests for compensation and percent of faculty time must be included in the proposal. Information on faculty salaries and fringe benefits may be obtained from the Office of Academic Affairs. Job descriptions and pay grades for classified personnel and student assistants should be checked with a representative of the Office of Human Resources.
Before institutional cost-sharing allocations are placed in proposal budgets, principal investigators (PIs) must discuss them with Chairs and the AVPAA:BR. Indirect Cost and Tuition Remission cannot be used as cost-sharing. Faculty and staff time used as cost-sharing must come from regular, allocated funds within the departmental or institutional budgets.
3. Institutional policy requires that an indirect cost allowance, determined by federal specifications, be charged to all government projects to cover the expense of services and facilities provided by the University, e.g., utilities, physical plant and equipment, insurance coverage, security, and administrative costs. Some private sources will also allow indirect cost or administrative charges. The indirect cost figures are available in the Office of Academic Affairs.
4. Depending on project needs, appropriate institutional boards or committees may need to be consulted, e.g., if human subjects are to be involved, the project must have the approval of the Institutional Review Board.
5. Equipment not available within your department but necessary for your project may be available from another source on campus. Check with the Inventory Control Office early in the budget development of your proposal to determine whether or not the requested equipment is available on campus.
6. Consulting services are allowable costs, and the use of such services must be specifically identified in the proposal. Since there are conditions and policies regarding consulting, contact the Office of Academic Affairs early in the process of preparing your proposal.
7. If the project requires the involvement of another institution or organization as a subcontractor, the subcontract must be identified in the proposal and a detailed subcontract budget included. Letters of agreement between Trinity University and the subcontractor must be exchanged and included in the proposal.
Subgrantees and subcontractors who are involved with federal awards to the University and who are not employed by or otherwise affiliated with the University must also be in compliance with Federal FCOI guidelines. They can comply in either of the following ways:
A subgrantee may follow Trinity's procedure for the disclosure of Significant Financial Interests and agree to comply with any decision of the University's administration; or,
If the subgrantee or subcontractor is employed by an institution that has enacted a financial conflict of interest policy that is in compliance with applicable federal regulations, including 42 CFR § 50.604, the subgrantee's employer may provide assurance that any conflicts related to the project under consideration have been managed, reduced, or eliminated pursuant to the employer's policy.
8. If your proposal involves hiring personnel, you must either (a) name the specific person in the proposal and apportion the wage charge correctly, or (b) identify and recruit someone for the position if an award is received. If you must recruit, you should discuss the proper classification and salary of the position with a representative of Human Resources during the preparation of the budget, and acquaint yourself with proper recruitment and Equal Employment Opportunity procedures.
9. Attention should be given to the inclusion of a realistic inflation percentage of costs for personnel salaries, student tuition and stipends, supplies, travel, and other line items. Check with the Office of Academic Affairs for percentages which the administration has established to accommodate estimates of rising costs.
10. If your project requires institutional space allocations, check with the appropriate office; e.g., the Registrar's Office for scheduling classroom space
11. The Office of Conferences and Special Programs should be consulted when the proposal includes conferences and other special events. The Office of University Communications can give cost estimates for publicity mailings.
12. If the proposal involves a private foundation, corporation, or other private sponsor, the PI should request that the AVPAA:BR coordinate the proposal with the Vice President for Alumni Relations and Development.
B. What to Submit and When
When your proposal is completed, submit the final copy with the Internal Approval Form to the Chair for approval.
If the proposal involves a cost-sharing agreement, a Cost-Share request must be attached to the Internal Approval Form.
The Internal Approval Form must be signed by the principal investigator (PI), departmental Chair and the Office of Grants Accounting, and must accompany all proposals to the Office of Academic Affairs for administrative approval.
The authorized institutional administrator has sole authority to commit institutional resources and facilities and to enter into agreements on contracts and grants. PIs are encouraged to consult freely with prospective sponsors, and to discuss conditions of the grant or contract. However, such discussions, particularly during pre-award negotiations, must be regarded as tentative pending approval by the authorized institutional administrator.
Time must be allotted for administrative review by the Chair, the Office of Grants Accounting, and the authorized institutional administrator, and for corrections or changes in the proposal. If substantive budget and/or task revisions in the proposal are made during the review process, the original endorsements must be reaffirmed before it will be signed by the authorized institutional administrator for submission to the sponsor.
C. Internal Review Timetable
Allow at least two days for the Chair to read, request any revisions, and approve the proposed narrative and budget.
Allow one week for the Office of Grants Accounting to review the budget and check for compliance with institutional and sponsor’s regulations, and read the narrative.
Allow two days for the AVPAA:BR to read the proposal, confer with the principal investigator (PI) or Chair on necessary changes, and approve the proposal for presentation to the sponsor.
Final photocopying and mailing are the responsibility of the PI, using departmental funds which have been allocated for this purpose. Copies should be sent to the offices of Academic Affairs and Grants Accounting. If the proposal was submitted to a private foundation, a copy should also be sent to the Director of Corporate and Foundation Relations.
If the scope of the project and/or the budget must be negotiated, the PI should revise the task schedule and budget, and it may be necessary for the PI to discuss changes with the agency project officer. Revisions must be submitted through the internal review process and approved by the AVPAA:BR.
D. Project Management
Grants and contracts are awarded to Trinity University, which has final responsibility for the successful administration of the grant or contract. However, the technical requirements and the day-to-day administration of the project are the responsibility of the PI. The Chair of the department in which the PI holds appointment has administrative oversight duties. The AVPAA:BR assists in administratively fulfilling the contract or grant requirements. The Office of Grants Accounting is responsible for financial accounting and audit. In addition, Human Resources and other staff and service departments will assist in the successful operation of the project.
It is the responsibility of the principal investigator to:
1. Conduct the project according to the statement of work set forth in the award document.
2. Supervise expenditures in conformity with the contract or grant budget. Small, routine budget changes within budget categories may require the approval of the Chair, the AVPAA:BR, and the Office of Grants Accounting. Major budget changes or budget transfers between budget categories that significantly alter the project will normally require approval of the funding agency, the Chair, the AVPAA:BR, and the Office of Grants Accounting.
3. Adhere to institutional policies and procedures.
4. Initiate the necessary documents requesting payment for travel, purchase requisitions, payroll authorization for project employees, and other forms required for the project.
5. Report to the Grants Accounting Office the time and effort devoted to the project by all project personnel during each pay period.
6. Contact the AVPAA:BR regarding potential patentable discoveries and copyrights.
7. Provide institutional identification, care and maintenance of all equipment procured with project funds in accordance with the University and sponsor’s regulations.
8. Write and submit progress reports as required by the sponsor.
9. Review reports of expenditures prepared by the Grants Accounting Office and closely monitor all financial transactions.
10. Assure that cost-sharing requirements are fulfilled for the project.
11. Assure that project funds are spent in an orderly and timely manner. This is particularly important when spending funds for equipment and supplies, because budgeted line items and project tasks must be closely related and fit well within the award time schedule so that they will be allowable and “auditable” costs.
12. Provide all expenditure documentation that may be requested by the Grants Accounting Office as needed for financial reporting to the project sponsor.
13. Cooperate with the offices of Human Resources and Payroll to give notice of anticipated termination to project personnel a month prior to the close of grants and contract.
14. Confirm and file with the appropriate offices all other termination documents, e.g., invention disclosures, copyright or patent statements, disposition of property acquired with award funds, contractor’s assignments, releases and rebates.
15. Complete and submit the final technical report to the sponsor by the required date. Send copies to the AVPAA:BR and Grants Accounting.
E. Proposal Format for Private Foundations and Corporations
For projects involving a private foundation, corporation, or other private sponsor, the AVPAA:BR will coordinate the proposal with the Vice President for Alumni Relations and Development.
V. ADMINISTRATION OF SPONSORED PROJECTS
Awards for sponsored projects are made to the University, which is identified as grantee in grant documents. It is the responsibility of the AVPAA:BR as the designated institutional representative to serve as intermediary between the agency and the principal investigator (PI) for pre-award changes of the grant and for post-award modifications, date extensions, and other administrative processing.
The PI will make such adjustments as are necessary for agency satisfaction within the context of more limited but adequate budget and line item changes. The final budget should be checked with the Chair and returned to the AVPAA:BR for approval. Contract agreements with sponsoring agencies require both agency and University signatures before they become effective. PIs must thoroughly review but are not authorized to sign these documents. The PI, the AVPAA:BR, and the Office of Grants Accounting review the final documents before contracts are approved and signed by the AVPAA:BR.
When an award has been accepted by the sponsoring agency and the University, the AVPAA:BR and the Office of Grants Accounting will review the terms and conditions of the award and issue a Notice of Award which advises the PI of the establishment of the project budget account. Until the award notice is received, no cost to the project can be incurred or paid. In setting up an award budget, the Office of Grants Accounting will review the award documents and include any special conditions in the administrative notes. These serve as guidelines to the PI in operating the project and expending funds. There will also be a listing of dates on which financial and technical reports are due, the anticipated date during project operations beyond which funds for equipment and supplies should not be spent, and the project budget identification number. Following this Notice of Award the PI should process all staff needs to the Office of Human Resources. All employment must be done according to established University job descriptions and salary scales.
The University has the responsibility for making required fiscal reports and insuring compliance with agency regulations. This does not absolve the PI of the responsibility for operating within administrative constraints imposed by the agency and the University. The PI must assume the responsibility for directing the technical aspects of the project and carrying out the methodology and scope as authorized by the agency. The PI is also responsible for authorizing and documenting all expenditures of grant funds including time and effort reports as specified in the grant. These are subject to the approval of the Office of Grants Accounting and the AVPAA:BR.
The PI will be responsible for preparing all final technical reports and budget close-out documentation required by the government agency. All of this information will be checked by the AVPAA:BR and the Office of Grants Accounting prior to submission to the agency but within the deadline specified by the agency. Records of all grants and contracts are retained for three years from the completion of the grant or contract project.
A. Activities. Include both direct activities and financial interest in the activities of other businesses.
B. Business. Any corporation, partnership, proprietorship, firm, franchise, association, holding company, joint stock company, receivership, trust, or any other legal entity organized for profit. This does not include mutual funds over which the investigator has no control, or any governmental committee, community, political, academic, charitable, religious, social, or professional non-profit organization.
C. Contracts. Excludes the terms of the investigator's own or any family member's employment contract with the University.
D. Employee. Includes faculty (full-time and part-time), staff (contract and classified), and visiting faculty and staff.
E. Equity Interests. Ownership or control of stock, stock options, or other investment instruments.
F. Facilities. Excludes the investigator's office, office equipment, and incidental supplies (e.g., copying, fax, long-distance telephone service) for which the investigator reimburses Trinity University.
G. Family. Spouse and dependent children.
H. Intellectual property. Includes organized information, ideas, fabrication methods, devices, or substances that are patented or copyrighted or have that potential, and that are partially or fully owned by Trinity University Excludes any intellectual property for which the investigator holds a license from Trinity University or which is in the public domain.
I. Investigator. The principal investigator, co-principal investigators, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities funded by a federal grant.
J. Policy position. A director, officer, partner, manager, or agent in any managerial position.
K. Receipts. Includes loans, gifts, royalties, and earned income other than consulting fees. Excludes grants, contracts, or any other sums that the investigator or the investigator's family member receives from Trinity University, no matter what the original source.
L. Research Integrity Committee. A group made up of the AVPAA:BR, the Manager of Grant and Plant Fund, and the chairs of the Institutional Review Board (IRB) and the Institutional Animal Care and Use Committe (IACUC). This group is charged with reviewing disclosures of significant financial interest related to externally funded programs in order to determine if a conflict of interest exists.
M. Significant financial interests. Any business, equity interests, or intellectual property of the investigator, her/his spouse or dependent children that would reasonably appear to be related to his/her ongoing or proposed federally funded research, including business, equity interests, or intellectual property, anything of monetary value including but not limited to salary or other payment for services (e.g., consulting fees or honoraria sponsored or reimbursed travel), equity interests, and intellectual property rights. Significant Financial Interests do NOT include:
income from seminars, lectures, or teaching engagements or from service on advisory committees or review panels if said income is paid by a federal, state, or local government agency, an Institution of higher education as defined at 20 U.S.C. 1001 (a), an academic teaching hospital, a medical center, or a research institute that is affiliated with an Institution of higher education.
financial interests in business enterprises or entities if the value of such interests does not exceed $5,000 or represent more than 5% ownership interest for any one enterprise or entity when aggregated for the investigator and the investigator's family; or
income from investments vehicles, such as mutual funds and retirement accounts, as long as the Investigator does not directly control the investment decisions made in these vehicles.
N. Staff services. Excludes infrequent secretarial support.
O. Subgrantees. Individuals and institutions that are unaffiliated with Trinity University and that enter into contractual agreements with the University for the design, conduct, or reporting of research funded by extramural sources. This definition includes contractors and consultants as well as collaborators at other institutions.
P. Trinity University. Includes all units operated by the University.
Q. U.S. Public Health Service (PHS). The Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority involved may be delegated, including the National Institutes of Health.
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