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 management 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the university Provosts and grant directors to address areas where required university policies and procedures were outdated or lacking.
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 universities to have a policy on the responsible conduct of research and responding to allegations of misconduct. Indiana University has a university policy that was submitted and approved by the Office of Research Integrity. The National Science Foundation supports an on-line resource in ethics education: The Online Ethics Center. Shippensburg University has developed a Research Training and Oversight Program, which is available as a model for all State System 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 research. In most cases the appearance of a conflict, or an actual conflict, can be managed by adopting some simple precautions. With extensive input from the universities, the Chancellor's Office developed Procedure/Standard 2016-22 Management of Financial Conflict of Interest that complies with the Uniform Guidance and most, if not all, federal agency requirements.
Employee Compensation for Sponsored Activities
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. Procedure/Standard 2018-32 provides a framework, consistent with collective bargaining agreements, for university administrators when reviewing/approving faculty and staff time commitments.
Technology Transfer & Commercialization
The State System provides services to support universities and faculty in protecting and commercializing intellectual property, specifically inventions and discoveries. A partnership with the Penn State Research Foundation makes this possible and financially feasible. Procedure/Standard 2018-37 allows universities to utilize the Penn State partnership or develop their own staff capacity. It also adopted an Inventor’s Guide for faculty, employees, students and guest researchers. (See more about technology transfer)
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 economic competitiveness. With extensive input from universities, the system developed 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. Procedure/Standard 2012-14-A provides procedures as well as Supplemental Information for the universities to assist in compliance with these laws. Web resources are available on the System's intranet, including a summary of the regulations, campus training sessions, newsletters and more.
Subrecipient (Subaward) Management & Monitoring
When a State System researcher collaborates with a researcher from another institution and the university awards a portion of the grant to the other institution (i.e., 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. The Uniform Guidance requires the university, as the pass-through entity, to monitor its subrecipients. There are several other significant requirements as well. A committee of grant directors developed system-wide Procedures/Standards which was issued as Procedure/Standard 2015-19 for Subrecipient Management and Monitoring.