Policy? Guidance? Standard Operating Procedure?

1. Policy? Guidance? Standard Operating Procedure? Tips on how to achieve compliance with minimum red tape Carolyn Bargoot, Associate Director Post-Award Administration Sheila Freedman, Associate Director Audit and Compliance Office for Sponsored Programs, Boston College

2. Agenda • Policy • When is developing a policy necessary? • How should you go about creating a policy? • Guidance • When issuing guidance might be the right path to choose • Standard Operating Procedures (SOP’s) • Why develop SOP’s? • How can they help you and your institution?

3. Boston College Fun Facts – FY12 • Located in Chestnut Hill, MA • Total Undergraduates 9,100 • Total Graduate Students 4,900 • Total Operating Expenses $795.7 million • Sponsored Awards $51.5 million • Research $31M • OSP Staff = 12 • No A-133 audit findings!

4. Why Develop Policies? • OMB Circulars • A-110 requires certain policies • A-21 further restricts • A-133 tests you on your policies • Funders expect we have certain policies • Ensure compliance

5. You should know • You are always bound to your institutional policies • University and OSP Policies • In most cases it is best NOT to introduce new polices, unless something more is required by Federal or State funding agencies or by law. • It is important to remember if your policies are stricter than required you need to make sure that your systems and administrators can meet those stricter requirements.

6. Policy Development • Research • What is required for your institution? What type of institution are you? • Look at what other similar institutions are doing (websites) • Higher Ed is big on sharing • Reach out to other institutions directly • Analysis • What would work best for your institution • What does your institution need to include in the policy for compliance, regulatory or other purposes? • Consult within your department • Consult with other departments • Most policies today affect multiple departments, therefore to be successful you must identify who needs to be part of the process and get their cooperation and buy-in • Consider whether a policy is the right method!

7. Include in your Policy • Clear Purpose • Scope • Assumptions • Requirements • Define Key Terms • Reference federal, state or other pertinent regulations

8. Successful Policy Development • Policies in your department/area should all have the same look and feel • Keep it simple and include only necessary information • Make sure you can adhere to what is in the policy • you do not want to increase your audit risk! • Review regularly to make sure the policy is still relevant • Resources available / Communication • Training, memos, forms, brochures, etc..

9. A few examples of Policies your institution should have: • Cost Sharing Policy • Conflict of Interest Policy • Effort Reporting Policy • Intellectual Property Policy • Capital Equipment Policy • Travel Policy • Procurement Policy • Cost Transfer Policy

10. Getting your policy approved: • Navigating the policy approval process at your institution can be tricky! • Many departments might need to be involved based on the topic of the policy • OSP • HR • Legal • Procurement • Provost Office • Controller’s Office

11. Getting your policy approved: • Might help to ask for more authority if the policy is only going to impact sponsored activity • Get all major players in a room together to discuss and review

12. After your policy has been approved: • Set a timeline for issuing your policy • Policy effective date is important • Training your audience on the impact of the new policy • Decide where on your website the policy will reside

13. Guidance • Unlike policy it is not mandatory • Seeks to simplify a set of processes with regard to an established habit or practice • Goal is to increase quality and consistency • Guidance is a great way to raise the bar and get the research community to strive for best practices

14. When should you issue “guidance”? • Ideally guidance should be developed in all major areas of compliance even if you do not have a policy • Guidance could become policy in the future • If you are unable to get a policy approved you might consider issuing guidance instead • Faculty and administrators should be trained • Example

15. Why create Standard Operating Procedures (SOP’s)? • Consistency, routine • Improve Productivity • Quality Control, Compliance • Training and cross-training (staff turnover) • Best practices can be established • Collaboration as a department in developing SOP’s can increase morale • Employee evaluations • Help in an audit (internal or external)

16. Standard Operating Procedures…where to begin? 1. Identify - Determine which areas of your work will benefit from a standard operating procedure - Where would it help have consistency? - Where will you see the greatest success? 2. Risk and Controls - Focus on the areas where the risk is high and controls are needed

17. Standard Operating Procedures…where to begin? 3. Collaboration - Determine who is going to take the lead to document each SOP - Brainstorm as a group on the SOP - discuss at least the high level controls needed 4. Development - Work as a team in development with one clear lead - Include an introduction or scope of the procedure - List all tasks and include descriptions of the tasks - Define any necessary terms upfront - Keep it short, without leaving out necessary information or consider breaking into smaller SOP’s - Determine the best format – checklist, word doc, flowchart

18. Standard Operating Procedures…where to begin? • Test - Ask a few of the team members to check the SOP when performing actual procedure 6. Notification - Notify necessary people of the new SOP - Give access to SOP document on website or server 7. Training - Provide training on the new SOP 8. Review - Establish process for reviewing SOP (e.g. annually)

19. Questions? Thank you!