Stem Cell Research - Financial Analysis Office

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STEM CELL RESEARCH:
GETTING ALL THE DUCKS IN A ROW
Sara Bible, Dean of Research Office
Stanford University
Bill Brophy, Director of Financial Analysis
University of California, San Diego
Presented at the SRA Western Regional
Meeting
RESEARCH ELEVATED: MILE HIGH OPPORTUNITIES
DENVER, CO - JUNE 7-11, 2008
About This Session
TOPICS
 Impact of federal funding issues on administration of hESC research
Human Embryonic Stem Cell Research Special Operating
Procedures for:
 material transfer agreements
 accounting
 effort allocation and certification
 facilities
 equipment
 expendable materials and supplies
 derivatives
 research data and intellectual property
About This Session
ABOUT THIS SESSION
Session based on a tutorial for Stanford personnel, including faculty,
staff, postdoctoral scholars, students, visiting scholars and other
researchers, who will be working on research projects involving
human embryonic stem cells.
At Stanford, all personnel must complete this tutorial satisfactorily as a
prerequisite to beginning work or study associated with human
embryonic stem cells.
It is the PI’s responsibility to ensure that personnel complete both
tutorials. Tutorial includes post test that must be completed with 100%
accuracy.
At UCSD, Research personnel with responsibilities for research using
Human Embryonic Stem Cells are required to complete training in
stem cell research, policy, and ethics.
STEM CELL RESEARCH TERMS AND ACRONYMS
Human Adult Stem Cells
Stem cell = master cell that can create the more specialized human cells
Human Embryonic Stem Cells (hESC)
Pluripotent cells that are self-replicating, derived from human embryos
and are capable of developing into cells and tissues of the three primary
germ layers. Although human embryonic stem cells may be derived from
embryos, such stem cells are not themselves embryos.
Registry Lines/Registry hESC
Those included on the NIH Human Embryonic Stem Cell Registry
Non-registry Lines/Non-Registry hESC
Those excluded from the NIH Human Embryonic Stem Cell Registry
hESC lines
A population of identical cells that all originated from a single blastocyst.
Because cell lines multiply, scientists can grow the cells for their own
research and to share with colleagues.
CRITERIA FOR hESC RESEARCH FEDERAL FUNDING
Federal Announcement
On August 9, 2001, President George
W. Bush announced that federal funds
can be used for hESC research only if
they meet the following criteria:
1. The stem cells were derived from
an embryo that was created for
reproductive purposes and was
no longer needed;
2, informed consent was obtained
for the donation of the embryo,
and the donation did not involve
financial inducements; and
3. the process of derivation was
begun prior to 9 pm EDT on
August 9, 2001.
Please think of your own preferred
quotation for this picture.
FEDERAL ANNOUNCEMENT IMPACTS
FEDERAL FUNDING FOR hESC RESEARCH
Because of President Bush’s announcement, hESC lines are categorized as:
1. Registry hESC Lines
Federal funds may be used ONLY for research using registry hESC lines.
Registry hESC lines = included on the NIH Human Embryonic Stem Cell
Registry - confirms that the stem cell lines are in compliance with the
President’s criteria as stated on August 9, 2001.
2. Non-registry hESC Lines
Federal funds may not be used directly or indirectly for research using nonregistry hESC lines (or their derivatives).
Non-registry hESC lines are excluded from the NIH registry because they
do not meet federal criteria.
hESC Research Can Proceed
Although the August 9, 2001 announcement bars the use of federal funds for
research on non-registry hESC lines, it does not prevent investigators from
conducting research with non-federal funds.
GOAL
Implement Procedures:
 to ensure hESC research can proceed unimpeded,
 to ensure compliance with university, federal and state policies, laws and
regulations, and
 to ensure federal funds are not used to support non-registered hESC
research directly or indirectly.
 to ensure all faculty, staff, postdoctoral scholars, and students as well as
visiting scholars and other researchers involved in hESC are trained.
ADDITIONAL RESPONSIBILITIES
INSTITUTIONAL RESPONSIBILITIES
• Review all human stem cell protocols
• Review ownership and use restrictions for all equipment in the space
• Review and negotiate agreements for obtaining hESC lines
• Tag equipment accurately based on federal funding restriction
• Monitor space and facilities used for research on non-registry hESC
• Perform indirect cost calculation, and verify funding source of labs
ADDITIONAL RESPONSIBILITIES
RESPONSIBILITIES OF RESEARCH PERSONNEL
• Plan the Research – where, who, what (funding, equipment,
cell lines)
• Review campus guidelines, complete hESC, cell culture and
ethics training
• Obtain approval of research protocol or amendment and
material transfer for each hESC line requested.
• Establish appropriate accounting for each research activity.
• Obtain institutional biosafety approval where needed
COSTING PROCEDURES: INTRODUCTION
• The following costing procedures provide guidance to
ensure that federal funds are not used to support nonregistry hESC research.
• Remember that the costing procedures for hESC
research are in addition to existing institutional policy &
procedures.
STANFORD PROCESS
Stem Cell Research Tracking (SCRT) Form
Form must be completed for all research that involves use of all Human
Stem Cells - registry and non-registry hESC or human embryos
regardless of funding source - gifts, departmental funds, university
research or externally funded grants and contracts.
When Must the Form Be Completed?
1. At the time of proposal (for an externally - funded project)
2. 30 days prior to anticipated start date (for gift, department or
university research funded project)
3. Whenever there is a change in project location/space usage such
as room additions or deletions.
Purpose of the Form
• Inform and seek approval from cognizant personnel
• Begin Stem Cell Oversight Committee (SCRO) review of scientific
and ethical issues
• Alert PMO & your DPA so they can assess ownership of the
equipment to be used in research.
• Initiate accounting – to open a Project Task Award (PTA).
UCSD PROCESS
Before research/teaching w/human embryonic stem cells, must be
approved by:
• Embryonic Stem Cell Research Oversight Committee (ESCRO)
http://research.ucsd.edu/escro
• UCSD Human Research Protections Program IRB http://irb.ucsd.edu
• Institutional Biosafety Committee - EH&S http://www-ehs.ucsd.edu
• Conflict of Interest (IRC) http://ocga3.ucsd.edu
If project calls for use of animal subjects, must also be approved by:
• Institutional Animal Care and Use Committee (IACUC)
http://iacuc.ucsd.edu
If human embryonic stem cells provided by non-UCSD source, must have:
An MTA - Office of Contract and Grant Administration
http://ocga3.ucsd.edu, OR
A Purchase Agreement - UCSD Purchasing http://www-bfs.ucsd.edu/pur
UCSD PROCESS
If UCSD-developed cells are sent outside UCSD or transferred between
UCSD investigators, must receive an evaluation from:
• Technology Transfer - TechTIPS http://invent.ucsd.edu
Research w/human embryonic stem cells, non-UCSD fund source, must
be approved by:
• ESCRO, and campus IRB
• Office of Contract and Grant Administration http://ocga3.ucsd.edu
OR
• Clinical Trials Administrative Services & Research Compliance Office
If research or training is funded by department or gift funds, approval is
required from the department business office and/or department chair.
ACCOUNTING
STANFORD
New PTA Required
Open a new Project Task Award (PTA) for each project
utilizing non-registry human embryonic stem cells, whether it
is gift, departmental university, or externally funded research.
A research assistant prepares stem cell cultures in a lab at the Waisman Center. Photo by: Jeff
Miller, UWM-2001
ACCOUNTING
UCSD
Establish separate fund for each award - set up index, fund, and other
accounting elements that drive University's reporting/ledger processes
Prepare and manage award allocations
Approve financial transactions to be charged to the project
Ensure that award expenditures comply w/financial terms and conditions,
University/agency policies
EFFORT ALLOCATION AND CERTIFICATION
Use established policies for:
• tracking, allocating and confirming effort on sponsored projects for all
personnel to ensure that effort devoted to non-registered hESC
research is not paid with federal funds,
• monthly review and quarterly certification of expenditure statements, by
the Principal Investigator,
• proper allocation of salaries and benefits when an individual is working
with multiple sources of support.
Important!
Salary must be allocated and charged to gift and
departmental, or university accounts commensurate with
effort put forth on the projects!
EFFORT ALLOCATION AND CERTIFICATION
.
Special Operating Procedures for additional work involving hESC
research for postdoctoral fellows and students funded 100% by
federal sources.
Postdoctoral fellows and students who are funded by federal
institutional training grants or fellowships, such as National Research
Service Awards (NRSA) are required to pursue their research training
full time under the terms of the award. However, they may be permitted
under the sponsor’s policy to engage in limited or part-time work
beyond their federal commitments.
Any such additional work must be compensated as part time
employment and must be incidental to the training program.
USE OF UNIVERSITY AND FEDERAL FACILITIES
Federal funded facilities, including VA facilities, may not be
used in the conduct of non-registry hESC research.
Both Stanford and UCSD have identified their federally
funded facilities and prohibit their use for non-registry
hESC research.
FACILITIES FOR NON-REGISTRY hESC RESEARCH
Where research on non-registry hESC is conducted
• List each lab, room, and office that will be used. Obtain a
determination on whether any of the proposed spaces cannot be
used because of federal funding.
• Review all equipment in the proposed spaces to see if any have
been tagged as federally funded. If so, the items cannot be used
on the non-registry research project.
• Update and re-route the form before the project location changes.
SPACE INVENTORY CODING
Both Stanford and UCSD use their established space inventory
and inventory procedures to track the location of all hESC
research.
• Code space as organized research or departmental research,
depending on the funding of the research.
• Use the Research Explanation or Comments fields to document
non-registry hESC research
EQUIPMENT APPROVAL - STANFORD
In a facility where non-registry hESC research is performed, all new and
existing equipment regardless of funding source, must be reviewed for
federal funding restrictions, and tagged appropriately. It will be tagged as
either APPROVED for use on non-registry hESC or DO NOT USE on
non-registry hESC.
Equipment is considered to have a purchase price of $5,000 or more and a useful
life of more than one year.
• Develop a list of all equipment in a facility
where non-registry hESC research will be
performed. Once the list has been
Tags for Equipment where
completed, subsequent purchases will be
non-registry hESC is
reviewed individually.
conducted
APPROVED
DO NOT USE
FOR USE ON
NON-REGISTRY
hESC
ON NON-
REGISTRY
hESC
• Will verify ownership and use restrictions.
• Approval to use the equipment may or may
not be granted.
• All Equipment will be tagged to indicate
whether it is approved or not approved for
non-registry hESC research.
EQUIPMENT APPROVAL - UCSD
In 2007, an inventory was conducted of all academic equipment, to
identify current building and room location.
A red dot was affixed to all federally funded equipment, and a campus
procedure was published and disseminated, indicating that red dot
equipment could not be used for non-registry hESC research.
Capital Assets Accounting issues a red dot along with an inventory tag
for all equipment purchases that are federally funded.
EQUIPMENT OWNERSHIP CATEGORIES
Equipment ownership will fall into one of three categories and will
be tagged accordingly.
Equipment owned by
the federal government
Equipment purchased with federal
funds may be owned by the
University and therefore can be used
for non-registry hESC research,
if one of the following criteria is met:
DO NOT USE
ON
NON-REGISTRY
hESC
All competitive segments of the
federal grant or contract supporting
the equipment purchase has been
completed, University retains title to
the equipment without restriction;
Or
University purchases the equipment
in full, without federal restriction, and
can document such transaction.
Equipment owned by
the University
APPROVED
FOR USE ON
NON-REGISTRY
hESC
EQUIPMENT INVENTORY CONDUCTED PERIODICALLY
Laboratories where non-registry hESC research is performed are subject to
periodic inventories to ensure that only approved equipment is used to support
non-registry hESC research.
Additional detail on Stanford procedures for equipment when conducting hESC
research can be found in the Property Administration Manual, Chapter 14
“Using Equipment for Stem Cell Research”.
MATERIALS/SUPPLIES ALLOCATION METHODOLOGY
If you purchase expendable materials and supplies that benefit multiple projects,
use a reasonable allocation methodology to accurately assign costs to the
benefiting projects. This allocation methodology must be documented. When
making such purchases to support non-registry hESC research, make certain
costs are not allocated to federal projects.
To avoid risk of charging materials and supplies for non-registry hESC to federal
projects, purchase supplies for non-registry hESC research separate from all other
research where practical.
SERVICE CENTERS
Service Centers used for research with non-registry hESC must not
involve any federal resources or federal core funding.
If a service center includes equipment that is federally funded and title
remains with the federal government, some additional steps may be
needed to allow use to provide services to research with non-registry
hESC, including an increased charge rate to recognize the
depreciation of the federal equipment, and a designation of program
income for the income so produced.
DERIVATIVES FROM hESC RESEARCH
Research using derivatives from non-registry hESC lines may not be
supported by federal funds. For costing purposes they are treated just like
the lines themselves.
Use the appropriate campus procedure to record:
1. Source of the hESC lines and the hESC derivatives,
2. Whether the source is a registry line or non-registry line,
3. Funding source of your research.
Caption: Derived from human embryonic stem cells,in the lab of UW-Madison stem cell
researcher Su-Chun Zhang, 11/01
MATERIAL TRANSFER AGREEMENTS
Follow institutional policies for receiving research materials.
All hESC lines require a Material Transfer Agreement (MTA) or similar
agreement in place between the provider and University before the lines
can be transferred to investigators
Investigators requesting hESC lines, both registry and non-registry, must
fill out an MTA routing form.
The provider's agreement for transferring the cell lines will be reviewed to
ensure compliance with University policy; necessary changes will be
negotiated before the agreement is signed.
Stanford’s Instructions for obtaining hESC lines can be found at the ICO's
website: http://www.stanford.edu/group/ICO/agmts/index.htm
DATA & INTELLECTUAL PROPERTY
Researchers may use data or information obtained from either registry or
non-registry hESC research in subsequent hESC projects if:
1. the data has been published or
2. permission to use the data has been granted by the original researcher
whether the subsequent projects are federally or non-federally funded.
However, the federal government may not be charged for generating data
from non-registry hESC research, or for analyzing or manipulating data
for subsequent use in non-registry hESC research.
Data and information usage is subject to the usual considerations of thirdparty intellectual rights the as well as any specific grant or contract
conditions on data usage imposed by suppliers or sponsors of the data,
including other research institutions and federal funding agencies.
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