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Policies

 
Universities that accept federal grants which sponsor research and services must also accept many "strings attached"; that is, standard terms, conditions and related federal laws that apply to fund managment and the conduct of research.  State and private funders also have minimum expectations about financial controls and ethics in research.
 
Over the past several years, the Office of the Chancellor has worked closely with the university Provosts and grant directors to address areas where required university policies and procedures were outdated or lacking.  
 

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Misconduct in Research/Responsible Conduct in Research
The Office of Research Integrity of the US Department of Health and Human Services and most federal sponsors require unviersities to have a policy on the responsible conduct of research and responding to allegations of misconduct.  The Office of the Chancellor works with Universities as each modifies and updates their policy.  Lock Haven University developed a concise yet complete version, subsequently approved by the Office of the Chancellor. Likewise Indiana University has a policy that was submitted and apporved by the Office of Research Integrity. It is available here as Research_Misconduct_Policy_Statement_3-28-11.pdf 
In August 2009, the NSF announced requirements that all Universities that apply for NSF grants must describe in the proposal a plan to provide training and oversight in the rsponsible and ethical conduct of research to undergraduare, graduate students and post docs pthat participate in the project. The following web sites are supported by the NSF as on-line resources in ethics education: Ethics in Science and Engineering and The Online Ethics Center.  Shippensburg University has developed a Research Training and Oversight Program, which is available here as a model for all PASSHE Universities.
Conflict of Interest
Researchers, and their immediate families, may not have financial interests that could bias the outcome of their research. Even the appearance of a conflict is cause for objective parties to question research results.  To avoid the appearance of impropriety researchers must disclose such interests prior to initiating their reserach.  In most cases the appearance of a conflict, or an actual conflict, can be managed by adopting some simple precautions. The Office of the Chancellor developed a model Conflict of Interest policy that the PASSHE universities are adopting. 
Compensation Policy (Time and Effort Reporting)
Researchers and project directors must be very conscientious in dividing their time among different sponsors and university duties. In addition, Federal rules require that faculty and staff be compensated for their time on sponsored projects at a rate that is consistent with their base annual salary.  Administrative procedures, approved by Legal Counsel and issued by the Office of the Chancellor, provide a framework for university administrators when reviewing/approving faculty and staff time commitments.
Technology Transfer & Commercialization
PASSHE has recently instituted services to support faculty in protecting and commercializing intellectual property, specifically inventions and discoveries. An informative web site is available at passhe.edu/techtransfer.
International Trade and Export Control
Export Control Laws are federal regulations that restrict the transfer of certain materials, technology, related technical data, and certain services outside the United States in the interest of protecting the national security and domestic economy.  A committee of grant directors is currently developing procedures for compliance with 1) Export Administration Regulations implemented by the Department of Commerce, 2) International Traffic in Arms Regulations implemented by the Department of State  and 3) Treasury Department’s Office of Foreign Assets Control economic and trade sanctions which protect foreign policy and national security goals. The Office of the Chancellor has provided Guidelines and information to the universities to assist in compliance with these laws.
 
A detailed overview presentation is available. A shortened presentation is available as well.  Resource material is also available.
Subrecipient (Subaward) Management & Monitoring
When a PASSHE researcher collaborates with a researcher from another institution and the university awards a portion of the grant to a non-federal entity to carry out work under the grant, that award is a "subaward" and the entity receiving it is a "subrecipient".  The university is responsible for ensuring that sponsor funds, including those funds that the university provides to other entities, are spent in accordance with all applicable laws and regulations. OMB Circular A-133 requires the university, as the pass-through entity, to monitor its subrecipients.
A committee of grant directors developed standard administrative procedures for meeting this requirement. The procedures  (Final Subrecipient Monitoring Procedures.pdf) were reviewed and endorsed by the Office of the chancellor, which adopted them as "official business procedures".
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