Introduction to Research Management Functions of the Partners Pre – Award, Post - Award and Research Finance Teams 2010

1. Introduction to Research Management Functions of the Partners Pre – Award, Post - Award and Research Finance Teams 2010 © Partners HealthCare System, Inc., 2010

2. Pre-Award Office Structure • The Pre-Award Office is part of the overall Office of Research Management • The Pre-Award staff are responsible for the following steps in the Grant Lifecycle : • Primary Tasks: • In addition to reviewing the proposal, budgets and supporting documentation they are responsible for reviewing the proposal guideline or RFP, BAA to ensure that if awarded, the resulting award terms and conditions are in keeping with Partners Policy and compliance with Sponsor specifications (federal, foundation and subcontracts under other entity applications) • Ensure proper institutional sign-offs on proposals and budget, as well as other commitments (commitments of space, resources, specialized facilities or equipment, level of effort, cost sharing, etc.) • Review Just In Time submissions • Review and submit Grant Progress Reports • Creation of the InfoEd shell (electronic) record • Provide technical guidance to PI and Department Administrators • Liaison between PI and sponsor

3. Proposal Creation and Submission Process • Step One: Identification of Funding Opportunities • Search for opportunities • Performed By: Principal Investigator (PI) and Department Administrator (DA) • Step Two: Proposal Preparation • Develop and revise proposal (narrative, budget/justification, key personnel) • Performed By: PI and DA • Step Three: Proposal Review and Approval • Proposal will require technical/scientific and administrative approval from the Department Chief (Cost Sharing, Budget, Review of proposed science) • Performed By: Division Chief and in some cases, Department Chief • Proposal receives Institutional Approval when Research Management review is completed and all errors and/or omissions have been corrected and any proposed cost sharing has been approved by Research Management. • Step Four: Proposal Submission • Proposal is submitted electronically or in some cases is mailed to sponsor organization • Performed By: Pre-Award Office or PI when hard copy submissions are required - Step Four B: Re-submissions and Just In Time • Re-submissions: A proposal may be re-submitted by the institution for re-consideration by a sponsor after being originally rejected • Just-In-Time: A proposal may be submitted with limited details, with the supporting information being provided at a later date when requested by the sponsor.

4. Documents Required and Deadlines • Partners Pre-Award offices will require numerous internal and/or external documents to be submitted by a PI to support their proposal, the list below are some common examples: • Division Chief’s Approval and as required, Department Chief’s approval, both of which are signified by signature on the Partners Proposal Coversheet. • Cost Sharing Approval Forms – Partners policy requirement (Partners requires internal approval for any and all cost sharing being proposed) • Agency Guidelines – Partners Research Management requirement (Research Management requires agency guidelines so that Pre-award staff can make sure all of the Sponsor requirements were met and so they are kept on file for future use) • Conflict of Interest - Partners requires a Conflict of Interest (COI) form for new and continuing grant applications to all federal agencies and not-for-profit sponsors. • “Letter of Intent” – specific sponsor requirement (this may be required from the subcontractor and goes to the sponsor when called for in guidelines) • Subcontract Documentation – specific sponsor requirement • Modulars – budget worksheet for Pre-award staff review, but not required by sponsor • Exclusions worksheet – budget worksheet used by DA’s when working with costs that are not subject to F&A recovery (subcontract costs > 25k, equipment, animal costs…) • http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Forms.asp

5. Partners Research Management Internal Grant Review and Approval Deadline Guidance • Deadlines for Electronic Submissions to Grants.gov15 business days before the grant deadline • All required sections of the grant application (refer to NIH eGrants Submission Proposal Checklist and the Partners SF424 Checklist) must be submitted to Research Management. The administrative portions of the grant must be complete at this time. Research Management comments will be communicated to the PI and/or departmental administrator within 5 business days of receipt. • Final version due to RM 5 business days before the grant deadline • After Research Management review, the entire grant application, must be electronically submitted to Research Management by uploading the COMPLETE and FINAL forms to the secure website at http://insight.partners.org/documentsubmission/This FINAL grant application file will be uploaded to Grants.gov beginning 5 business days before the grant deadline. Review and approval by Department/Division Chief is still required and must be completed by this time. • Deadlines for Paper Applications and electronic submissions to other agencies (All Sponsors, including Non-Competing Progress Reports)10 business days before the application deadline • All required sections of the grant application (refer to Grants and Contracts Proposal Checklist) must be submitted to Research management for review and approval. The final research plan does not need to be included, and can be added to the grant immediately prior to mailing to the sponsor. Review and approval by Department/Division Chief must be completed before Research Management approves the application.

6. Just-In-Time Submissions • Just-In-Time – Allows Institutions to submit supporting information after the proposal has been submitted • Some Common JIT Attributes: • Institution Review Board (IRB) approval, pending or out of date approvals are not acceptable • Certification for Key Personnel to verify that they have completed an educational program in the protection of human subjects • IACUC (Institutional Animal Care & Use Committee) approval – pending or out of date approvals are not acceptable • Current Other Support – list funding for each person considered Key Personnel for the project. Address how you would resolve any budgetary, scientific or effort overlap if this proposal is funded. • Budget Breakdown/Budget Justification, only as requested • Requests for Just-In-Time submissions come to the Central Awards Mailbox for each respective hospital. They are then forwarded to the Pre-award Grants Administrator working with the PI and Department. The information requested is then collected, reviewed and once approved, is submitted to the Sponsor. • Sponsor/Application Specific

7. Just-In-Time, cont. • The other support and Human subjects education information should be submitted within two weeks of receiving the JIT request. • IRB or IACUC approval are understood to take longer and may be submitted later, at the earliest date that they become available. • All of the JIT information can be submitted via eCommons using the Just in Time feature found in the “status” section. If submitting via eCommons, all information must be submitted at one time. • All Just- in-Time submissions must be countersigned by an authorized institutional official (RM pre-award grants administrator). Just-In-Time requests are NOT a Notice of Award, they are an indicator of a possible award.

8. Non-Competing Grant Progress Reports • Progress reports usually are required annually as part of the non-competing continuation award process. However, NIH may require these reports more frequently. • The “Grant Progress Report” (PHS 2590) form is used and submission is made directly to the awarding office.  • Many progress reports qualify for a streamlined process for submitting known as SNAP, Streamlined Non-competing Award Process.  • To determine when a progress report is due, there are several tools available: • eRA Commons Status • Electronic Notifications:  The Principal Investigator is sent an e-mail 2 months before the scheduled due date. In the event a progress report is not submitted on time, a reminder e-mail is sent to the PI.   • Progress Report due dates are also entered in to the InfoEd system, see the Deliverable tab.

9. Non-Competing Grant Progress Reports, (cont) eSNAP submissions: • Progress reports for applications that qualify for SNAP may be submitted electronically and are known as eSNAP.  The eSNAP system allows extramural grantee institutions to submit an electronic version of the PHS 2590 Progress Report to the NIH via a web interface. • Electronic progress reports must be submitted at least 45 days before the beginning date of the next budget period and are submitted by the Pre-Award Grants Administrator. Paper submissions of the PHS 2590: • Non SNAP progress reports require paper submission. Complete the PHS 2590  progress report to continue support of a PHS grant. It should be ready to send at least 60 days before the beginning date of the next budget period and are submitted by the PI or DA. • The signed original progress report and one copy (with required signatures) must be submitted either via courier delivery or via the US Postal Service (USPS) to the following centralized mailing address: Division of Extramural Activities Support, OERNational Institutes of Health6705 Rockledge Drive, Room 2207, MSC 7987Bethesda, MD 20892-7987 (regular USPS or USPS Express mail)Bethesda, MD 20817 (other courier/express mail delivery)Phone Number: (301) 594-6584

10. Pre – Award Links • To find the staff assigned to work with your department on pre-award activities http://phsresearchintranet.partners.org/PHS_ResearchMgmt/documents/contact%20lists/BWHDeptAssignments.pdf • Download site for free software needed to apply for NIH grants (Adobe Reader, PDF Conversion Programs) http://www.grants.gov/help/download_software.jsp • Brigham and Women’s Hospital Standardized Grant Application Facts page http://bwhbri.partners.org/ResearchAdmin/Grants/StandardGrantInfo.aspx • Mass General Hospital Standardized Grant Application Facts page http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_MGH_Institutional_data.asp • Link to Partners forms page (Partners Proposal Cover Sheet) and proposal checklists http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Forms.asp • Link to Partners Research Management pre-award procedures and best practices guidance • http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Prepare_Proposal.asp#JIT

11. Post-Award Office Structure • The Post-Award Office is part of the overall Office of Research Management and includes the Contract/Subcontract team and the ARRA (stimulus funds) team as well as the team doing account set up and fund management (post award) activities. • The Post-Award office is responsible for the following steps in the Grants Lifecycle: Primary Tasks; • Review the terms and conditions of all in-coming grants and contracts from Federal funding sources, Universities or other not-for-profits and Foundations • Review/QC pending record in InfoEd and set up/activate accounts for new awards, subcontracts and out year amendments • Issue and execute all out-going subcontracts • Review, process and submit all post-award administrative actions (such as requests for re-budgeting approval, no-cost extensions, requests for change of scope, requests to add a subcontractor) • Review and approve employee data changes and equipment requisitions in eBuy • Monitor all active award accounts • Participate in the Close Out process • Provide technical guidance to PI and Department Administrators • Liaison between PI and sponsor

12. Negotiations Done by Research Management’s Contracts/Subcontract Team: All Foundation Awards All awards from Foundations and other not-for-profit entities Federal Grants and Contracts, including Federally sponsored Clinical Trials All Federal awards (National Institutes of Health (NIH), National Science Foundation (NSF), National Aeronautics and Space Administration (NASA), Department of Defense (DOD), Congressionally Directed Medical Research Programs (CDMRP), The Center for Disease Control (CDC)……) Subcontracts for sponsored research activity All in-coming subcontracts, regardless of sponsor Out-going subcontracts that are issued by the Contract team, are also negotiated and administered by the Contract team.

13. Award Setup Steps • Step 1 - Sponsor Notification of an Award • Receiving and Routing the Award • Required Documentation/ Institutional Clearances • Require notification of Receipt? • Step 2 - Reviewing/Negotiating Terms and Conditions • Binding Contract to the Hospital • Acceptable to the Hospital? • Step 3 - “Setting Up” the Award • Subcontracts • Multi-project/Program Awards • Training Awards • Budget/Account Numbers • Funding Mechanism – “The financial Side” (Letter of Credit/ Cost Reimbursable/Fixed Price) • Step 4 - Account Number and Routing the Award (Award will be uploaded into InfoEd) • The new fund number will be emailed to the PI and DA upon completion of account set up/activation

14. Other Award Setup Activity • Renewal Setup • Fund setup of continuation years • Typically based on award projected at year 1 • Internal compliance documentation required (ie COI forms, Cover sheet etc.) • Research Sundry Fund Setup • Fund setup for discretionary research spending • Request form with approval by division chief & entity controller • $25K minimum balance to open fund • 15% overhead

15. Post-Award ProcessAll recipients of grants from the NIH, need to realize that there is a great deal of information that we, as an organization, will need to monitor in order to be successful stewards of federal funds. Monitoring an Award All Grantees are responsible for managing the day-to-day operations of their grant. This active monitoring is accomplished through review of accounts and expenses, correspondence with subcontractors (as applicable), requests to the Sponsor and the justification for each prior approval request made, audit reports, site visits, and other information that may be available. Monitoring Expenditures All Grantees are required to have financial systems in place to monitor their grant expenditures. A good steward will monitor expenditures under individual grants within each budget period and within the overall project period. The funding that NIH provides for each budget period is based on an assessment of the effort to be performed during that period and the grantee’s associated budget, including the availability of “un-obligated” balances. Although NIH allows its grantees flexibilities with respect to re-budgeting (see “Administrative Requirements – Changes in Project and Budget” in the NIH Grants Policy Statement), NIH expects the rate and types of expenditures to be consistent with the approved project and budget and may question or restrict expenditures that appear inconsistent with these expectations. Monitoring of active accounts

16. All requests that require prior NIH approval must be made in writing (e-mail is acceptable) to the Grants Management Officer at least 30 days before the proposed change. The request must be endorsed by the Authorized Organization Representative. Failure to obtain required prior approval from the appropriate NIH awarding office may result in the disallowance of costs, termination of the award, or other enforcement action within the NIH’s authority.E-mail requests must be clearly identified as prior-approval requests, must reflect the complete grant number in the subject line, and should be sent by the AOO to the GMO that signed the NGA. (E-mail addresses for NIH staff can be obtained from the NIH Directory and E-Mail Forwarding Services at http://directory.nih.gov) E-mail requests must include the name of the grantee, the name of the initiating PI, the PI’s telephone number, fax number, and e-mail address, and comparable identifying information for the AOO. If the entire message of the request cannot be included in the body of the e-mail, the request should be submitted to NIH in hard copy. Prior Approval Requests (NIH specific)

17. Rebudgeting into A&R costs that would exceed 25 percent of the total approved budget for a budget period. If rebudgeting would not meet this threshold but would result in a change in scope. Any single A&R project exceeding $300,000. Capital expenditures (construction, land, or building acquisition). All instances when purchase proposed; any proposal to convey, transfer, assign, mortgage, lease, or in any other manner encumber real property acquired with NIH grant funds. Change of scope Changes in status of key personnel (Withdrawal from the project; absence for any continuous period of 3 months or more; reduction of time devoted to project by 25 percent or more from level in approved application) Change of grantee organization Carryover of unobligated balances (If the NGA indicates that the grantee does not have the authority to automatically carry over balances) Deviation from award terms and conditions (Includes undertaking any activities disapproved or restricted as a condition of the award) Actionsrequiring NIH prior approval

18. Foreign component added to a grant to a domestic organization Need for additional NIH funding (Including extension of a final budget period of a project period with additional funds) Pre-award costs (If more than 90 days before effective date of the initial budget period of a new or competing continuation award) Retention of research grant funds when the award is K series award Second no-cost extension or extension greater than 12 months Transfer of funds between construction and non-construction work Transferring amounts from trainee costs Actionsrequiring NIH prior approval, cont.

19. Closeout NIH closes out a grant as soon as possible after expiration if the grant will not be extended of if continued funding is not provided. Closeout includes ensuring timely submission of all required reports and adjustments for amounts due the grantee or NIH. Closeout of a grant does not automatically cancel any requirements for property accountability, record retention, or financial accountability. Following closeout, the grantee remains obligated to return funds due as a result of later refunds, corrections, or other transactions, and the federal government may recover amounts based on the results of an audit covering any part of the period of grant support. Required closeout reports include: Final FSR Final progress report Final Invention Statement and Certification Final population tracking data when applicable These reports are due within 90 days of the end of grant support. Failure to submit timely and accurate final reports may affect future funding to the organization or awards with the same PD/PI. Closing out an award

20. No-Cost Extensions • An NCE allows the PI to complete the scope of work without additional funding • Does not change the scope of work • Does not involve additional funding • Does need to be justified • Extensions can be requested through NIH Commons for 3, 6, or 12 month durations and are covered under expanded authorities • 2nd no-cost extensions always require prior approval by NIH and require a more detailed justification and in most cases a budget and spending plan • All extension requests require the following: • Unexpended funds remain on the award • Current conflict of interest forms • Current IRB / IACUC approvals in place

21. Post – Award Links • To find the staff assigned to work with your department on post-award activities http://phsresearchintranet.partners.org/PHS_ResearchMgmt/documents/contact%20lists/BWHDeptAssignments.pdf • To view your grant in the InfoEd system http://phsresearchintranet.partners.org/PHS_eSubmissions/PT.asp?subID=leftnav2 • To access, monitor and manage your accounts in InSight http://phsresearchintranet.partners.org/PHS_ResearchAppGroup/PHS_ResearchAppGroup_Insight.asp • Information on award management (specific to Partners) http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Manage_Award.asp#Award_Management • Effort Reporting http://phsresearchintranet.partners.org/PHS_ResearchMgmt/EffortReporting.asp

22. The Research Finance Office is also part of the overall Office of Research Management The Finance office is responsible for the following steps in the Grants Lifecycle: Primary Tasks; Fund monitoring Preparation and submission of Financial Status Reports Issuance of invoices for billing funds Audits Cash Management including LoC Journal Entry approval and processing Payments to subcontractors (out-going) Award Closeouts Month-end Allocations and Close Implementation and support of PeopleSoft Grants Modules Approval for Document Direct requests Research Finance Analytics including - Consolidated reporting of all research activity Rate Negotiation for Indirect Costs, Fringe Benefits and Patient Care Core Service Business Plan Approvals and routine monitoring Research Finance Office Structure

23. Responsibilities of the Billing team • Billing and Revenue • Billing Group • Invoices Sponsors • Invoice for IRB and Medicare Coverage Analysis fees as applicable for industry sponsored clinical trials • Accounts Receivable • Cash collection and processing • Accounts Receivable monitoring and follow up • Letter of Credit • Request, review and post weekly cash draws

24. When looking at your grant expenses • Direct Costs • Personnel Costs – Salaries/Fringe Benefits • Department Administrator submits data change to allocate a percentage of salary to the grant • Fringe benefits are charged as a percent of salary. 3 rates, Professional (MD/PhD), Fellow, non Professional (techs or admin) • Fringe Benefits covers the costs of Health Insurance, FICA (employer portion), retirement, life insurance, malpractice and other benefits • Non Salary Expenses • Accounts Payable Invoices and check request • Supplies, Subcontract payments, etc. • Expense Reimbursements - Travel • Core Charges – DNA sequencing, Assay’s • Institutional Charges – Beeper, phone • Journal Entries – • Standard and late Cost Transfers • Record Original Costs (core charge)

25. Expense Classification Cont. • Indirect Costs • Method to allocate costs that are not grant specific • Space, Heat, Lights and Maintenance, etc • Charged to the grant as a percent of the Modified Total Direct Costs (MTDC) most common method or Total Direct Cost (TDC) • MTDC is total Direct Costs less capital equipment, patient care, subcontracts over 25K and alterations and renovations Off-Site and On Site rates • Currently at 78 and 27% at BWH • Currently at 77 and 27% at MGH • Clinical Trial rate • Currently is 25% (for industry sponsored) • Assumption that activity takes place in clinical space • Sundry Rate • 15% used for gifts and internally funded projects

26. Payment Methods There are three main ways to receive payment for research expenses incurred: • Upfront or automatic payment schedule • Letter of Credit (LOC) • Invoicing • Cost Reimbursable (Subcontracts & Contracts) • Milestone • IRB Fee as applicable • MCA Fee as applicable

27. Payment methods - explained Upfront or Automatic payments: • Optimal from a cash management perspective • Cash is received at the time of award or on an automatic payment schedule (typically quarterly or monthly) • No manual intervention needed by Research Finance (usually) • Fund remains in a positive cash position unless spending exceeds payment schedule Federal Letter of Credit: Method of Payment for Grants from Most Federal Agencies: • Process is currently in transition from a system based on estimated expenses to a system based on actual expenses • Weekly draws made to reimburse Partners for expenses ($8-10M/week) Invoicing: • Invoice process is driven by a Fully Executed Agreement (FEA) • No invoicing can take place until that document is signed by both parties. • The FEA contains the Terms & Conditions applicable to Invoices. Favorable Terms & Conditions: Monthly Invoicing 60 Days for Final Invoice No requirement for additional supporting documentation

28. More on Invoicing for payments Milestone Invoicing: • Invoices are required to initiate payment • Payment is NOT based on reimbursement of cost incurred • Instead, invoices are based on reaching milestones of time and/or scientific progress • Rely on PI/department for progress information in order to bill IRB Fee Invoicing: • $3,500 Initial Review Fee, $1000 per Continuing Review – new fee structure applicable for industry sponsor-initiated clinical trial agreements received by Partners Clinical Research Office on or after 8/8/11 • May or May not Require Invoice for Payment MCA Fee Invoicing: • $1500 for qualifying drug, $2000 for qualifying device • Applicable for all qualifying industry sponsored clinical trials • May or May not Require Invoice for Payment Other Invoicing points: • Not all research invoices are generated by Research Finance • Clinical Trail funds are billed and the receivable tracked at the Departmental level. • Recharge Center services are also invoiced by the Departments

29. The Accounting Team - Cost Transfers and Journals • “Five Ws”: Every transaction must identify the who, what, when, where and why of the cost being journaled.  • The “Five Ws” identify the characteristics that are unique to each transaction and document the basis for submitting the journal entry. • Financial records appropriately documenting the transactions must support all journal entries and are the responsibility of the originating department to maintain. The PI Role when completing a cost transfer: • Validate expense activity on an ongoing basis to assure that expenses have been charged to the correct funding source • Identify expense posting errors and initiate corrective action • Provide appropriate justification and designate fund to receive the transfer • Review fund balances to verify that the cost transfer took place

30. Standard Cost Transfers Entries to Book Original Cost Late Cost Transfers Core Journals Regardless of type, all entries must conform to generally accepted accounting principles and be supported by documentation maintained by the department of origin. All transactions must be moved at an itemized level. Journal Entry Types

31. Journal Entries to Book Original Costs • Journal entries that post original expenses (including but not limited to core service facilities and payment for interdepartmental services rendered) must establish an audit trail because they are the initial posting of the expense to the general ledger. • Invoices that include the following detail support these entries: • Vendor name/address and authorized signature or letterhead • Name/address of goods/services recipient • Current date • Clear description of the goods/services provided (including date of service and itemized cost) • Invoice number • Supporting documentation for this type of entry is the invoice being paid. Invoice copies must therefore accompany the entry when submitted to Research Finance for review.

32. More on Cost Transfers / Journals Late Cost Transfers: • Greater than 90 days as defined by PHS Cost Transfer policy • Description of the expenses being transferred, including why and when the original charge(s) occurred • Reason why the receiving account was not originally charged • Explanation of why it is appropriate to charge the receiving account and how the expense is allocable to that account • The reason for the delay in initiating the cost transfer • Steps taken to avoid late cost transfers in the future • Research Finance may request additional supporting documentation to facilitate the review process Journal Submission Timelines: • Journals submitted by the last working day of the month are reviewed by Research Accounting for the month end close • Journals are confirmed after they are loaded into the general ledger • Core journals are due by Business Day 15 and are subject to routine detailed review

33. What is an FSR? Another task done by the accounting team FSRs, or financial status reports, allow Partners to communicate how the sponsor’s funds were spent over the project period. What: An FSR is a legal, signed record stating how the grant recipient spent awarded funds Who: FSRs are created by the Research Finance team for all Federal and Non-Federal awards requiring an institutionally approved financial report. Each FSR is signed by the Principal Investigator (PI) and approved by our Financial Officer – Diane Spiliotis (your team lead will also have signatory authority and will be the one signing reports for you on a regular basis). When: FSRs are completed as required by each sponsor’s terms and conditions—generally on an annual or semi-annual basis according to budget end date, as well as at the completion of the project. Some awards require only one financial report at the end of the project. Why: FSRs tell the sponsor that the funding was spent in accordance with the terms set out in the grant award letter: The grant award letter is a legal contract signed by Partners and the sponsor. How: FSRs are created in excel and sent to sponsor either electronically (through eCommons) or by mail, fax or PDF

34. Federal vs. Foundation Reports FSRs are required by all federal agencies, and most private foundations. Federal FSRs are standardized, with reporting deadlines and formats established by federal agencies. The terms and conditions of non-federal awards, however, are unique to each sponsoring organization. This can make financial reporting difficult and time consuming. While the following items are clearly established for all federal grants, each may vary from one private foundation to another: • Frequency of Reporting – An annual, semi-annual or in some cases, only a final FSR is due at the end of a project period. • Allowable vs. Unallowable Costs – Travel may be allowed on American Heart Association Grants, but not on Robert Wood Johnson Grants. • Format of Reporting – A Sponsor may require you to e-mail PDF versions, fax the report, mail in hard copies or all of the above. In addition some organizations may specify the expense report for you to use, while others have no preference. • Carry Forwards and No Cost Extensions – Organizations vary in their requirements to procure a NCE or a carry forward of funds into the next grant cycle.

35. Research Finance Links • To find the staff assigned to work with your department on accounting or billing activities http://phsresearchintranet.partners.org/PHS_ResearchMgmt/documents/contact%20lists/BWHFinanceDeptAssignments.pdf • Budget template http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Forms.asp#budget • Link to the Research Management Standard Operating Procedures http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM%20SOPs.asp#FSR • Link to the Partners Research Management Policies http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Policies.asp • Link to other important Partners policies related to Research (Code of Conduct, Conflict of Interest) • http://phsresearchintranet.partners.org/PHS_ResearchMgmt/RM_Policies.asp#related