Jekyll and Hyde: Balancing Research Development and Compliance

Jekyll and Hyde: Balancing Research Development and Compliance Kris A. Monahan, Providence College Joseph Tomaras, Bates College Mabel Chee, Borough of Manhattan Community College

Session Objectives Learn to identify compliance risks before they become emergencies. Develop strategies for integrating compliance training into pre-award development activities. Identify skills of interpersonal communication to help maintain healthy working relationships even in worst-case scenarios.

Identifying Compliance Risks Review the environment and ask questions to determine risks: Any changes in regulations/policies/requirements? For example, Grants Reporting Information Project: www.recovery.gov/About/board/Documents/Grant%20Reporting%20Information%20Project%20Report_June%202013.pdf How will institution demonstrate compliance? Who needs the information and how will it be used?

Compliance Risks I. Research Compliance Protection of Human Subjects Animal Care & Use Biohazards & Biosafety Responsible Conduct of Research Conflict of Interest Research in a Foreign Country Data Management II. Award Compliance Types of Awards Terms and Condition of Award Performance Obligations Reporting Requirements ReportingCost Sharing Management Allowable Costs Intellectual Property Hiring and Contracting Policies Subcontracts vs. Consulting Export Control Evaluation Effort Reporting

Strategies Lead Time Checklists Demonstrate Value

Lead Time Balance between nimble, customer service orientation, & need to vet outgoing proposals Commit to reading/reviewing all proposals (even the biochemistry ones!) Communicate reasonable expectations for turnaround

Checklists Populate based on likely risks @ your institution, e.g. Cost Sharing (& documentation) Allowability of costs PI effort commitments Human Subjects / Vertebrate Animals

Checklists Likely risks (continued) Subawards Research in foreign countries HR Issues (hiring; leave/benefits for project staff) Facilities security, safety, or suitability for new equipment Conflict of Interest

Ways to Demonstrate Value You found the funding opportunity You noticed a key requirement in the RFP You trouble-shot a knotty budget issue You found a weakness in the project narrative You offered edits—and they were good! You helped the PI make the case for institutional resources/support

General Rules If possible, demonstrate your value BEFORE alerting a PI to compliance concerns. Frame concerns as a shared challenge to be met cooperatively, rather than a violation of ethics or institutional policy.

Case Example #1 PI is applying for a Federal student scholarship grant w/ several eligibility restrictions. If awarded, he will need timely information re: entering students from Admissions & Financial Aid. If he does not seek the information, expenditures could be disallowed. If he seeks it but does not receive it promptly, he may not be able to spend funds on time.

Case Example #2 PI has assisted a small company in obtaining an SBIR grant from DARPA. Company now wants to subcontract to PI. Company wants royalty-free exclusive license on all IP to be developed. On an FCOI disclosure form filed on his NIH grant, PI lists this company as owned by his wife.

Case Example #3 PI wants to conduct research surveying current & former sex workers in Cambodia. He is applying for an NSF grant; if awarded, more than 50% of total award will be subcontracted to an NGO in Phnom Penh. Your institution has never worked with a foreign subawardee before.

Interpersonal Skills Needed Definition of 'Interpersonal Skills' "The skills used by a person to properly interact with others. In the business domain, the term generally refers to an employee's ability to get along with others while getting the job done. Interpersonal skills include everything from communication and listening skills to attitude and deportment. " Source Investopedia

TELL US! What are the characteristics of a successful research administrator who can balance promoting compliance with encouraging proposal submission?

Characteristics of Successful Research Administrator Political Leadership Effective and Proactive Communicator Responsive to Input Garners Support/Gains Trust

Characteristics of A Successful Research Administrator Managerial/Administrative Leadership Balances Priorities Fosters Shared Leadership Maintains Accountability Encourages Innovation Continuous Improvement of Leadership

Self-Reflection What is one thing you can do differently or more effectively to balance research development with compliance?

Resources NCURA Resources *Report on Research Compliance: http://www.reportonresearchcompliance.com/ *Research Administration Training and Compliance at the Department Level for a Predominantly Undergraduate Institution Beryline Temples, Paula Simons, and Timothy N. Atkinson, University of Central Arkansas, Vol. 19, No. 1 - 2012 National Institute of Health http://grants.nih.gov/grants/compliance/#glance http://www.youtube.com/user/NIHgrants National Science Foundation http://www.nsf.gov/bfa/dias/policy/guidance.jsp

Jekyll and Hyde: Balancing Research Development and Compliance