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
Reporting
Cost 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