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PERS Extra-compensation aka Supplemental Pay Training Module V: Compliance Issues Wednesday, July 23, 2008

SUPPLEMENTAL PAY. 2. Definitions of AY Review OMB Circular A-21 and UCB Faculty Handbook guidelinesEffects on effort reporting. Basic Definitions. 3. Academic Year (AY)Have some ambiguity when defining AYThe July 2001

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PERS Extra-compensation aka Supplemental Pay Training Module V: Compliance Issues Wednesday, July 23, 2008

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    1. PERS & Extra-compensation (aka Supplemental Pay) Training Module V: Compliance Issues Wednesday, July 23, 2008 Demetria Ross Sponsored Projects Accounting 1

    2. SUPPLEMENTAL PAY 2 Definitions of AY Review OMB Circular A-21 and UCB Faculty Handbook guidelines Effects on effort reporting

    3. Basic Definitions 3 Academic Year (AY) Have some ambiguity when defining AY The July 2001 “Boulder Campus Policy on Additional Pay to Regular & Research Faculty says AY=August to May (i.e., Aug 15-May 15) [called UCB 2001 Policy] UCB’s FTE Policy (Feb 2004) defines AY as Mid-August through Mid-May However, The Graduate Student Appointment Manual says AY=Sept 1 – May 31 PBS (Payroll) says AY appointments are generally made on a contract basis for Sept through May and the appointments are paid from Sept through May

    4. Basic Definitions (cont’d) 4 Definition of AY generally based on PBS and payroll schedule PBS states AY appointments will receive no pay during June, July & August ePER system driven by monthly payroll, not term dates ePER system divides year into 3 semesters based on full months Fall (Sept-Dec) Spring (Jan-May) Summer (June-Aug) Summer salary allocated to May (50% of monthly) will report as Spring wages on ePER

    5. Compensation 5 AY Salary = Base Salary Base salary determines what amounts can be earned during summer & what can be charged to sponsored projects OMB Circular A-21: “Charges for work performed …during the AY will be based on…regular compensation for the continuous period which…constitutes the basis of his salary. Charges for work performed…during all or any portion of such period are allowable at the base salary rate.” UCB 2001 Policy: AY salary is the sum paid in consideration of normal services rendered during AY, described as 9/9th of an AY faculty member’s salary AY base salaries may be supplemented by variety of stipends & adjustments but that doesn’t increase base amount (need permission of Dean)

    6. Allowable Additional Compensation 6 Not included in base salary UCB 2001 Policy: Overload teaching during AY – those activities in excess of teaching activities expected as part of the defined workload formula Service that includes responsibility when it is not a regular and ongoing component of normal workload Monetary awards for exceptional service, teaching, research, or other contributions Compensation for consulting activities with entities not associated with the university Dollar amount not restricted Amount of time faculty can devote to consulting during AY is restricted to 1/6 of total time and effort

    7. Compensation Limits 7 During AY UCB 2001 Policy: Prohibits AY faculty from supplementing their 9/9ths salary with grant funds or other university research salary during AY May substitute some base salary with grant dollars if workload is adjusted Needs permission of Dean course buyout reduces university-paid salary monthly base salary remains unchanged

    8. Compensation Limits (cont’d) 8 During AY OMB Circular A-21: “In no event will charges to sponsored agreements…exceed the proportionate share of the base salary for that period.” Intra university consulting is….a university obligation requiring no additional compensation to base salary “However, in unusual cases where consultation is across departmental lines or involves a separate or remote operation, & the work performed by the consultant is in addition to his regular departmental load, any….extra compensation above base salary is allowable provided….specifically provided for in the agreement or approved in writing by sponsoring agency.”

    9. Compensation Limits (cont’d) 9 Summer Salary Limitations UCB 2001 Policy: Allows a maximum of additional 3/9ths to be earned in salary for activities conducted in summer months, not to exceed 1/9th per month Exceptions to maximum require prior approval of Dean’s office and Office of Faculty Affairs 3/9ths for summer salary includes: Any salary paid from sponsored projects Summer teaching for either summer school or continuing ed Maymester is summer teaching, not AY overload Administrative stipends (i.e., Dept Chairs and Faculty Directors) This additional 3/9ths is calculated from the base salary, not on total compensation

    10. Compensation Limits (cont’d) 10 Summer Salary Limitations OMB Circular A-21: Charges for work performed by faculty members on sponsored projects during the summer will be at the monthly rate of the base salary [for AY, generally 1/9th] Doesn’t govern summer teaching or consulting: Teaching during summer or other periods not included in base salary will be based on university policy governing such compensation Non-institutional activities must follow the institution-wide policies & practices governing the permissible extent of such professional services

    11. Compensation Limits (cont’d) 11 External Salary Caps Federal: Some federal agencies require salary cap for employees working on projects they fund Current NIH cap (through 12/31/08) is $191,300 NSF will pay only 2 months summer effort Private Agencies: Some private agencies also set salary limits, such as American Cancer Society To know if there are limits, look at the Additional Terms and Conditions Attachment of the Notice of Grant Award

    12. Effects of Policy on Effort Reporting 12 ePER (effort report) reflects 100% of semester salary earned Total salary always represents 100% (not 100% plus overload %) Total can be distributed among various position numbers (AY pay & effort, summer pay & effort, chair, etc) Spring ePER can also include ˝ month summer salary and effort in total semester pay NOTE: 2001 UCB Policy on Additional Pay to Regular and Research Faculty Directed to faculty on 100% AY or FY appointments Faculty on less than 100% may take on additional duties and compensation equivalent to 100% FTE, as defined in their letter of appointment or reappointment

    13. SPA ePER Contacts 13 epers@colorado.edu Pat Dodson Internal Compliance Coordinator Pat.Dodson@colorado.edu Jim Sheppard: ePERS Specialist James.Sheppard@colorado.edu Demetria Ross: Cost Sharing; ePERS back-up Demetria.Ross@colorado.edu See the UCB ABS website for ePERS policy and info on training opportunities http://abs.colorado.edu/

    14. Charlene Lydick, C.P.M. Associate Director of Procurement Procurement Service Center 14 Small Business Subcontracting Plans Training Module V – Compliance Issues Wednesday, july 23, 2008

    15. Small Business Subcontracting Plans What are they? Statement of goals for subcontracting to small business concerns When are they required? Federal Contracts where award is equal to or greater than $550,000; original or modified award Per FAR 52.219.9 15

    16. Small Business Concerns 16 Small Business Small Disadvantaged Business Woman-Owned Small Business Historically Black Colleges/Universities & Minority Institutions HUBZone Small Business Veteran-Owned Small Business Service-Disabled Veteran-Owned Small Business

    17. Plan Development 17 CU’s Small Business Program https://www.cu.edu/psc/purchasing/sbp/ Contact us: Small.Business@cu.edu Pamela Andrade, Assistant Small Business Liaison Officer (Asst. SBLO) 303.315.2827 or Pamela.Andrade@cu.edu Charlene Lydick, Assoc. Director of Procurement/SBLO 303.315.2780 or Charlene.Lydick@cu.edu

    18. FUNDAMENTALS OF COMPLIANCE: CONFLICTS OF INTEREST & COMMITMENT TRAINING MODULE V: COMPLIANCE ISSUES WEDNESDAY, JULY 23, 2008 18

    19. Conflicts of interest: 19 exist “when an employee’s financial or personal considerations may compromise, or have the appearance of compromising, an employee’s personal judgment in administration, management, instruction, research, and other professional and academic activities.” APS on Conflicts of Interest and Commitment Your CU employment is considered your “primary” employment, and, thus, your primary responsibility and allegiance. Other interests are secondary, when it comes to how you perform your CU job.Your CU employment is considered your “primary” employment, and, thus, your primary responsibility and allegiance. Other interests are secondary, when it comes to how you perform your CU job.

    20. Conflict of commitment: 20 “refers to situations in which outside relationships or activities adversely affect, or have the appearance of adversely affecting, an employee’s commitment to his/her University duties.” APS on Conflicts of Interest and Commitment This is often referred to as the “1/6th rule”, referring to the policy that says that faculty may consult “on University time” up to 1/6th of their time and effort.This is often referred to as the “1/6th rule”, referring to the policy that says that faculty may consult “on University time” up to 1/6th of their time and effort.

    21. Perception is reality 21 Conflict of interest/commitment programs deal with situations in which an employee’s judgment or commitment to the University could be compromised. It is the potential for compromise that is the most likely to cause harm. Often, people think that the only time there actually is a conflict is if they actually act on compromised judgment. In reality, the conflict exists whenever there are two different roles for an employee – as CU employee and as person with financial interests related to CU employment.Often, people think that the only time there actually is a conflict is if they actually act on compromised judgment. In reality, the conflict exists whenever there are two different roles for an employee – as CU employee and as person with financial interests related to CU employment.

    22. What does a CoI/C program do? 22 Identify Manage, reduce, eliminate Notify

    23. Identify 23 Disclosure of External Professional Activities (DEPA) (both CoI and CoC) - Annual FOR ALL TENURE-TRACK AND RESEARCH FACULTY (at employment and the beginning of the calendar year) - On-line (CU Connect, Academics & Research tab) - Review by CoI/C director Determine no conflict; or, Needs further review Disclosure to OCG and HRC (CoI) Application for Approval of Regular and Periodic Consulting Activities (CoC) (http://www.colorado.edu/facultyaffairs/atoz/ofaindex.html - Review/Approval by Unit Head The last one is often called the “1/6th rule” form.The last one is often called the “1/6th rule” form.

    24. Where is the “line” - CoI? 24 Income of >$10,000/year (self, family member) from a business that is related to one’s University activities Equity interests >$10,000 or 5% in a business that is related to one’s University activities Service to company (e.g. Board of Directors) Intellectual property rights

    25. Where is the “line” – CoC? 25 Not remunerative scholarship 1/6th rule (generally > 19.5 days/semester) Interference with “paramount obligations to students, colleagues, and the primary missions of the University.” 1. Remunerative scholarship refers to such things as textbook authorship, involvement with professional societies, and participation on review panels, etc. 2. Traditionally, the University has allowed full-time faculty to be employed in remunerative consultative or research capacities when such employment did not involve more than one-sixth of their time and energy. 3. a conflict of commitment arises when professional service or research contracted outside the University, consultations, or other outside activities (e.g., outside teaching or business) interfere with the paramount obligations to students, colleagues, and the primary missions of the University. 1. Remunerative scholarship refers to such things as textbook authorship, involvement with professional societies, and participation on review panels, etc. 2. Traditionally, the University has allowed full-time faculty to be employed in remunerative consultative or research capacities when such employment did not involve more than one-sixth of their time and energy. 3. a conflict of commitment arises when professional service or research contracted outside the University, consultations, or other outside activities (e.g., outside teaching or business) interfere with the paramount obligations to students, colleagues, and the primary missions of the University.

    26. Manage, reduce, eliminate 26 CoI/C director gathers information from discloser Provides analysis to unit head & discloser Is there a conflict, and, if so, why is it a conflict Suggestions of how to manage, reduce, eliminate Unit head determines if conflict, and how to manage Unit head and discloser sign MOU, send to dean Dean makes decision, notifies discloser and CoI/C

    27. Notify 27 NIH notify that conflicts have been identified before submission of proposal notify that conflicts have been managed before funds disbursed NSF notify of any conflicts that institution cannot manage CU administration gets annual report

    28. Examples (generic) 28 Professor Zen receives $15,000/year for consulting for a company that has also given a large gift to support his research program. Several students are supported by that gift. Is this a conflict of interest? - Yes – it involves issues of scientific integrity and relationships with students. How would it be managed? 1. Disclosure to journals and in public presentations where results are presented 2. Disclosure to students and committee members (if applicable). Is this a conflict of commitment? - No - not as presented

    29. Examples #2 (generic) 29 Professor Yang receives >$10,000/year as an editor of a prestigious journal; he spends one day/month on this activity. Is this a conflict of interest? No, this is remunerated scholarship. It does not need to be reported on the DEPA. Is this a conflict of commitment? No, not as reported.

    30. Example #3 (generic) 30 Professor Xavier has a contract to conduct a large survey of satisfaction of hearing aid users for a company in which she owns a substantial share. Is this a conflict of interest? - Yes – it involves issues of scientific integrity, and protection of human subjects. How would it be managed? 1. Disclosure to journals and in public presentations 2. Disclosure to subjects 3. Possible scientific oversight of conduct of project. Is this a conflict of commitment? - No - not as described.

    31. Example #4 (generic) 31 Professor Wren is assisting a small start-up company for free, in an area related to his University work. He is spending approximately 20 hours/week helping to get it up and going. He does most of the work on nights and weekends, but at times needs to be on site for a day or two every week. Is this a conflict of interest? - No. Is this a conflict of commitment? - Yes. His effort exceeds the 1/6th rule. (The 1/6th rule applies 24/7 during the appointment year.) How would it be managed? 1. Leave for some period of time; 2. Reduction of the appointment percentage.

    32. Information and help 32 (http://www.cu.edu/policies/Academic/coninterest.html) http://www.colorado.edu/VCResearch/ORI/coic.html http://www.colorado.edu/facultyaffairs/atoz/one-sixth-rule.pdf. Jean Wylie, Compliance Director Jean.Wylie@colorado.edu or 303.492.3024 Russell Moore, Associate VC for Research Russell.Moore@colorado.edu or 303.492.2899

    33. Radiation Safety Training Module V: Compliance Issue Wednesday, July 23, 2008 Michelle Law, Radiation Safety Officer Department Environmental Health & Safety 33

    34. Radiation Safety 34 Responsible for reviewing safety of research involving: Radioactive Materials (Approx 125 PIs using Unsealed & Sealed Sources) Radiation Producing Machines (Approx 35 X-rays) Lasers (Under Development) Personnel: Full-time Radiation Safety Officer (RSO) Full-time Alternate RSO (ARSO) 2 Radiation Safety Specialists, 1 Part-Time Student 10 Committee Members (UCB and UCCS) Unique situation for RAM under one license, UCDHSC under different licenseUnique situation for RAM under one license, UCDHSC under different license

    35. Radiation Safety 35 Physical Safety Protection of personnel, environment, and property License Review, Equipment, Cradle to Grave Administrative Safety Protection from Regulatory Citations Developing/modifying procedures as needed Review of proposed experiments Ensure proper equipment is used (shielding, hoods, refrigerators/freezers, waste containers, etc.) Receipt, Use, and Disposal (order approvals – currently working with PSC, receiving materials daily, weekly waste collections & processing for disposal) Regulatory requirements (control of materials from cradle to grave, security changes)Review of proposed experiments Ensure proper equipment is used (shielding, hoods, refrigerators/freezers, waste containers, etc.) Receipt, Use, and Disposal (order approvals – currently working with PSC, receiving materials daily, weekly waste collections & processing for disposal) Regulatory requirements (control of materials from cradle to grave, security changes)

    36. Radiation Safety 36 Training Initial Training for Unsealed materials in our office Other training is available on-line or by request Unsealed Refresher Training Sealed Source Training & Refresher X-ray Training & Refresher New Requirements Security Previously Exempt Materials (NORM)

    37. Contact Information Environmental Health and Safety (303) 492-6025 Radiation Safety Office (303) 492-6523 Michelle.Law@colorado.edu www.colorado.edu/radsafety Radiation Safety 37

    38. Animal Resources Contact Info 38 http://www.colorado.edu/VCResearch/AnimalResources/index.html Albert R. Petkus, DVM, ACLAM Director, Animal Resources University of Colorado - Boulder UCB 345 Boulder CO 80309 ph 303 492-3411 fax 303 492 -2967 albert.petkus@colorado.edu  

    39. Animal Resources Contact Info (cont’d) 39 Silvia N. Iorio Program Coordinator/IACUC Administrator Institutional Biosafety Committee University of Colorado-Boulder Muenzinger Psychology - Room E227 Campus Box UCB 345 Boulder, CO   80309 303 492-8187 office 303 492-2967 fax Silvia.Iorio@colorado.edu  IACUC meetings occur on the 3rd Wednesday of every month. Deadline for Animal Care and Use Protocol submission is one and one-half weeks (Monday) prior to IACUC meeting

    40. Human Research Committee (HRC) Training Module V: Compliance issues Wednesday, July 23, 2008 Claire Dunne HRC Education Coordinator Wednesday July 23, 2008 40

    41. Research with human subjects Your ethical responsibilities 41

    42. Human Research Committee (HRC) Federally mandated Reviews research involving human subjects to ensure that research is conducted ethically and safely 42

    43. What is Research? 43 A systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge. Systematic: a process for data to be considered valid, thus able to be generalized so that the activity might be considered research. Designed to: a deliberate intent to create or add to generalizable knowledge. Generalizable: relevant to more than the particular circumstance that produces it and intended to be shared for a broader audience.

    44. What is a Human Subject? 44 A living individual about whom an investigator conducting research obtains: Data through intervention or interaction with the individual, or Identifiable private information. 45CFR46.102(f)

    45. Is It Human Subject Research? 45 1979 The National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research 1979 The National Commission for the Protection of Human Subjects of Biomedical and Behavioral Research

    46. Approval process 46 Class projects not resulting in publication Instructor applies to the HRC for approval Honors theses, other independent research that may result in publication Requires individual approval Refer to the HRC website for instructions and forms HRC website: http://www.colorado.edu/VCResearch/HRC/index.html

    47. CITI Tutorial 47 CITI tutorial: http://www.colorado.edu/VCResearch/HRC/EducationalTools.html Complete the “Students in Research” module for class projects For independent research complete the “Social Behavioral Research” or “Biomedical Research” module, as appropriate

    48. On-line system – IRB Manager Submitting to the HRC 48

    49. HRC Staff Melissa Diemer Program Coordinator Melissa.Diemer@Colorado.EDU 303-735-3702 Amanda Whitson Social / Behavioral Panel Coordinator Richard Husser Biomedical Panel Coordinator Erin Coons, CIP Quality Assurance Coordinator Claire Dunne, PhD Education Coordinator Joseph Rosse, PhD Director, Office of Research Integrity 49

    50. Institutional Biosafety Committee Compliance Training module V: compliance issues Wednesday, July 23, 2008 Denise A. Donnelly, Campus Biosafety Officer Department of Environmental Health & Safety

    51. Institutional Biosafety Committee The Institutional Biosafety Committee (IBC) is responsible for reviewing all University research and teaching activities involving the use of biohazards, recombinant DNA molecules, select agents, or bloodborne pathogens.

    52. Institutional Biosafety Committee Who Are We? IBC Membership includes: No fewer than five members with the appropriate expertise in recombinant DNA technology Biological Safety Officer At least one individual with expertise in animal containment principles for rDNA research involving animals At least one individual with expertise in plant, plant pathogen, or plant pest containment principles for rDNA research involving plants At least two members not otherwise affiliated with the institution

    53. Institutional Biosafety Committee Biohazards consist of the following: Infectious/pathogenic agents classified in the following categories: Risk Group 1, 2, 3, or 4 bacterial, fungal, parasitic, viral, rickettsial or Chlamydia agents or, Plants, animals or derived wastes which contain or may contain pathogenic hazards (including xenotransplantation tissue) or, Human and nonhuman primate tissue, body fluid, and cell culture (primary or continuous) or,

    54. Institutional Biosafety Committee Biohazards consist of the following: Pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV) or, Administration of hazardous materials to animals and their associated tissues and body fluids or,

    55. Institutional Biosafety Committee Biohazards consist of the following: Select Agents - specifically regulated pathogens and toxins as defined in Title 42, CFR, Part 73, Title 9 CFR 121, and Title 7 CFR 331. These agents have the potential to pose harm to human health, animal health or products, and/or plant health or products or, Other agents that have the potential for causing disease in healthy individuals, animals, or plants.

    56. Recombinant DNA Research Must comply with the NIH Guidelines for Research Involving recombinant DNA Molecules http://www4.od.nih.gov/oba/rac/ guidelines/guidelines.html Institutional Biosafety Committee

    57. Institutional Biosafety Committee

    58. Institutional Biosafety Committee Responsibilities of Biosafety Officer: Member of the IBC Member of the IACUC Review HRC Applications Develop and Manage Campus Biosafety Program

    59. Institutional Biosafety Committee Campus Biosafety Program consists of: Compliance with Federal, State, local, and funding agency laws and requirements Compliance lab inspections Training – Biological Lab Safety, Bloodborne Pathogen, Packaging & Shipping Management and disposal of biological waste Import/Export of biological, animal, and plant materials

    60. Institutional Biosafety Committee IBC Contact Information IBC Chair Dr. Gretchen H. Stein gretchen.stein@colorado.edu (303) 492-5229 Biosafety Officer Denise A. Donnelly denise.donnelly@colorado.edu (303) 492-7072 IBC Administrator Silvia Iorio silvia.iorio@colorado.edu (303) 492-8187

    61. RESEARCH MISCONDUCT TRAINING MODULE V: COMPLIANCE ISSUES WEDNESDAY, JULY 23, 2008 Joe Rosse Research Integrity Officer Wednesday July 23, 2008

    62. What is Research Misconduct? The Federal Big Three Fabrication* Falsification* Plagiarism Other serious deviations from accepted practices CU adds: Authorship disputes Fabrication: making up data, notes, or other research information and reporting them. Falsification: manipulation of the research process, or altering data, such that reported results are not accurate. Plagiarism: portraying another person's intellectual property as one's own. Not simply wholesale “cut and paste”’; may involve appropriating ideas, concepts, or data without credit and then changing the actual language so as to give the impression that the ideas are one's own, or providing a citation for one particular use, but then making extended future use of the original work without further citation. Discuss why this is important: Public investment in research requires accountability Research is cumulative, researchers generally assume that others’ reports are accurateFabrication: making up data, notes, or other research information and reporting them. Falsification: manipulation of the research process, or altering data, such that reported results are not accurate. Plagiarism: portraying another person's intellectual property as one's own. Not simply wholesale “cut and paste”’; may involve appropriating ideas, concepts, or data without credit and then changing the actual language so as to give the impression that the ideas are one's own, or providing a citation for one particular use, but then making extended future use of the original work without further citation. Discuss why this is important: Public investment in research requires accountability Research is cumulative, researchers generally assume that others’ reports are accurate

    63. What Research Misconduct is NOT Honest error vs. intentional or reckless Honest differences of opinion or interpretation Anything not involved in proposing, conducting, or reporting research Violations of other policies (e.g., fiscal misconduct, conflict of interest)

    64. Investigation of Research Misconduct Concerns may be addressed to Research Integrity Officer (Joe Rosse) Standing Committee on Research Misconduct will conduct inquiry Normally a very confidential process

    65. EXPORT CONTROLS TRAINING MODULE V: COMPLIANCE ISSUES WEDNESDAY, JULY 23, 2008 Joe Rosse & Linda Morris Office of Research Integrity Wednesday July 23, 2008

    66. Export Controls National Security Defense-related technology “Dual-Use” technology National/Foreign Policy Embargoed countries Banned groups or individuals

    67. Export Controls Restrictions Physical exports - rare Laptop computers usually not a problem “Deemed exports” – more common Transfer of knowledge to foreign nationals, even if the transfer occurs in U.S. Via documents, emails, even site visits Collaboration with foreign scientists or students is most common example

    68. Export Controls Restrictions Financial transactions with embargoed countries Balkans, Belarus, Burma, Cuba, Iran, Iraq, Ivory Coast, Liberia, N. Korea, Sudan, Syria, Zimbabwe Travel ban with Cuba Transcations with people/companies on various Denied Parties Lists

    69. Export Controls Implications Exports—physical or “deemed”—may require a license, depending on: Type of technology What the other nation is Whether an exemption applies Fundamental research/public domain Education Laptop computer/PDA/cell phone Where you travel and who you talk with may be restricted Check with Linda Morris to determine

    70. Contractor Code of Business Ethics FAR 52.203-13 Training Module V: Compliance Issues Wednesday, July 23, 2008 Kathleen R. Lorenzi Office of Contract and Grants

    71. FAR 52.203-13, Contractor Code of Business Ethics

    72. FAR 52.203-13, Contractor Code of Business Ethics

    73. FAR 52.203-13, Contractor Code of Business Ethics

    74. FAR 52.203-13, Contractor Code of Business Ethics

    75. FAR 52.203-13, Contractor Code of Business Ethics

    76. FAR 52.203-13, Contractor Code of Business Ethics

    77. FAR 52.203-13, Contractor Code of Business Ethics

    78. Contact Information Randall Draper - OCG (303) 492-2695 Kathleen Lorenzi – OCG (303) 492-2692 Demetria Ross – SPA (303) 735-5083 Charlene Lydick - PSC (303) 315-2780 Jean Wylie – COI (303) 492-3024 Michelle Law – EHS (303) 492-6523 Al Petkus – LAR (303) 492-4311 Claire Dunne – HRC (303) 735-5014 Denise Donnelly – EHS (303) 492-7072 Joe Rosse – ORI (303) 735-5809 Linda Morris – ORI (303) 492-2889 78

    79. THANK YOU FOR ATTENDING 79

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