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Policies, Process and the PUI. Julie Cole, Director of Compliance, Duke University Peggy Lowry, OSP Director (Retired) Oregon State University Pam Whitlock, OSP Director (Emeritus) UNC-Wilmington. Thoughts to Ponder. Setting the Stage: The Empty Room
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Policies, Process and the PUI Julie Cole, Director of Compliance, Duke University Peggy Lowry, OSP Director (Retired) Oregon State University Pam Whitlock, OSP Director (Emeritus) UNC-Wilmington
Thoughts to Ponder Setting the Stage: The Empty Room Risk Analysis: Tone at the Top for Accepting Institutional Risk Categories of Polices and Procedures : What do You Need Roles and Responsibilities (and Why This is Important) Communication and Commitment : Who are the Stakeholders?
The Empty Room…. You are a newly hired director of sponsored programs at a regional university that has aspirations to expand a relatively small funded portfolio and to successfully compete for students, talented faculty and increased national regard for its teaching and student research programs. When you arrive, you discover that grant management policies and procedures are either very dated or don’t exist. Your only resource: a faculty handbook and a state policies and procedures that are not specific to federal funding. Welcome to the Empty Room.
Preparing to Fill the Empty Room: Understand Your Institution’s Culture and Perspective • Does the institution have an expectation for extramural funding to support scholarship/research? • Does culture support expectation? • Does the institution understand commitments that come with sponsored programs? • What is the institution’s risk tolerance level? • Risk tolerance in research activities • Risk tolerance in budget management Tone at the Top
Research Compliance Internal Controls Sponsor Expectations Nature of Research Institutional Posture Research Methodology Institution Policies Tone at the Top
Policy Tone at the Top
Certs and Reps • Conflict of Interest • Institutional Authority What Do You Need?
Core Questions: • Subject to A-21 and A-110, plus certain FAR clauses? • State or private governance? • Subject to A-133? • Financial management systems allow for segregation of funds? • System of internal controls? • Allowability, allocability and reasonableness guidance and process? • Reconciliation process? • Human Subjects, including student research? • Animal Use, including demonstration, housing, unique centers? • Biosafety or hazardous materials? • International Travel and Collaborations? • Who may submit and internal review process? • Cost sharing? • Who can accept an award? • Who can sign for the institution? • Certifications and Representations What Do You Need?
Elements: • Steps to be taken • Related forms and procedures • Navigation Tools • Quick reference to contact list • Roles and responsibilities Handouts What Do You Need?
Why Defined Roles and Responsibilities Ensure necessary tasks are being performed Accountability to sponsors Professional development Smoother processes Communication Improved collaboration and work environment R&R’s
Types of Responsibilities Initiate Plan Implement Monitor Controlling Closure R&R’s
Defining Roles Define parameters of each process Detail all tasks required for successful execution of process Review workflow process Assign tasks/processes TEST to ensure workable R&R’s
Issues with Unclear Roles and Responsibilities A critical task is not performed Lack of ownership Finger pointing Blame Mistaken expectations Unhappy surprises R&R’s
Communication:Understand their primary focus • Credibility • Needs, wants and wishes constitutes motivation Communication
Faculty • Students • Teaching • Publishing • Staff managing risk providing service to faculty keeping knowledgeable about sponsors improving skills implementing best practices enhancing communications between research administrators providing transparency enhancing connectivity between functions updating policy overseeing a financial compliance program informing leadership refining business process improvements retaining your sanity Communication
Provost • Academics • Community • Students • Retention • More……. • Finance • Risk • Budget • Audits P&T Students Buildings Union Gov Rel Retention Hiring Trustees Accreditation Grants Communication
Advancement • Donors • Gift Totals • Foundation relations • Capital campaigns Communication
Knowing the stakeholder needs/ expectations, helps answer priorities of the stakeholders? existing knowledge? level of language to use? communication method? tone and style? who else to involve? “competition?” Communication Peggy S. Lowry
Communication MESSAGE Communication
Frame Message • Relate content to • What you know about the stakeholder • What you know about the stakeholder needs • Build a base of content that can be mixed and matched for future communications Communication Peggy S. Lowry
Five Key Steps for Policy Communication Communication
Policy and Procedure Resources NCURA Regulation and Compliance https://www.ncura.edu/online/cgi-bin/msascartlist.dll/ProductList?ONWEBFLG=y&SORT=UDEF1QTY Tufts University Policy Model Policies: You Gotta Have Them, Federal Grant News, April 2011 (1st article) 13 Common Mistakes about Communicating Policies and Procedures Information www.urgoconsulting.com University of Santa Cruz: Guide to Writing Policy andProcedure Documents http://policy.ucsc.edu/pdf/guide.pdf Murray State Policies and Procedures Guide http://www.murraystate.edu/SponsoredPrograms.aspx