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The
federal government, through the Office of Management and Budget (OMB)
regulates the award and administration of federal grant and contract
funds. In addition to these high-level regulations, federal agencies
also issue terms and conditions that apply to individual grant awards.
State agencies follow a similar model. Even private foundations and
corporations often have specific terms and conditions applicable to grant
awards.
Following are a few highlighted federal compliance requirements and a list
of general grant terms and conditions. The Sponsored Programs Office assists Principal Investigators in complying
with these requirements. To ensure RHIT complies with all sponsor terms and conditions,
please
contact the Sponsored Programs Office for assistance prior to
implementing changes to an awarded grant or executed contract.
ACTIVITY DISTRIBUTION
REPORTS
(Time
and Effort Reporting)
In
order to comply with the provisions of OMB Circular A-21, in September,
December, March, and June, Rose-Hulman issues an “Activity Distribution
Report” for each employee whose time (effort) was charged to a grant or
contract during the previous quarter.
The
purpose of this report is to confirm, after-the-fact, the accuracy of the
employee’s payroll distribution by activity during the reporting period.
Each employee (or the employee’s supervisor), is asked to review the
report and certify that it reflects a reasonable estimate of their
professional effort. If the report is inaccurate, please contact
Sponsored Programs.
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ANIMAL CARE AND USE
Use of
animals in research is governed by the Animal Welfare Act and the Health
Research Extension Act of 1985.
Before
beginning any work with animals on the RHIT campus, investigators must
obtain the appropriate clearances, including an approved protocol from the
Institute Animal Care and Use Committee (IACUC).
The IACUC is responsible for the oversight of animal care and use at RHIT.
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HUMAN SUBJECT USE
Before beginning work
with human subjects on the RHIT campus, investigators must obtain
exemption certification from the Institute Reviewer or the approval of the
designated Institutional Review Board. Please contact
Robert Throne,(x8414) Institute Reviewer, to seek this approval.
Researchers are also encouraged to reference
Human Subject Research at RHIT
for
further guidance.
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CONFLICT OF INTEREST (Significant Financial Interest)
A conflict/potential
conflict of interest occurs when there is a divergence between an
individual's private interests and his or her professional obligations to
the Institute, such that an independent observer might reasonably question
whether the individual's professional actions or decisions are determined
by considerations of personal gain rather than the best interests of the
Institute.
Federal regulations require institutions to have policies and procedures
in place to ensure that investigators disclose any "significant financial
interest" that may present an actual or potential conflict of interest
related to an externally sponsored project.
RHIT Conflict of Interest Policy and Procedures
was adopted in the Spring of 2004, replacing the "Investigator Significant
Financial Disclosure Policy/Procedure (rev. 6/20/96)".
The conflict of interest policy requires all RHIT employees to disclose
conflicts or potential conflicts of interest annually. In addition,
as part of the grant/contract proposal submission process, Principal
investigators (PI) and other key project personnel will be asked to
certify their familiarity with the policy, and to disclose any conflicts
or potential conflicts associated with the proposal not previously
disclosed in the annual process.
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RESPONSIBLE CONDUCT OF RESEARCH ETHICS TRAINING
The
America COMPETES Act requires that “each institution that applies for
financial assistance from the (National Science) Foundation for science
and engineering research or education describe in its grant proposal a
plan to provide appropriate training and oversight in the responsible
and ethical conduct of research to undergraduate students, graduate
students and postdoctoral researchers participating in the proposed
research project.” As a result of this, the National Science Foundation
(NSF) effective for all proposals submitted after 1/4/10 require an
Institution to certify that it has a plan to provide appropriate
training and oversight in the responsible and ethical conduct of
research.
RHIT has developed an
Responsible Conduct of
Research Policy and now requires training for all students participating
in any sponsor funded projects. To fulfill this requirement, you must
complete the on-line CITI training module titled, Responsible Conduct of
Research for Engineers.
RCR Ethics Training Module - When registering,
select Rose-Hulman Institute of Technology as the participating
institution. Successful completion of the modules will be recorded in a
database accessible by the Office of Sponsored Programs. Participants
should print a completion report to be submitted to the Payroll Office.
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RESEARCH MISCONDUCT
Research misconduct is defined as fabrication, falsification, or
plagiarism in proposing, performing, or reviewing research, or in
reporting research results. Federal regulations state that
"research institutions bear primary responsibility for prevention and
detection of
research misconduct and for the inquiry, investigation, and adjudication
of research misconduct alleged to have occurred in association with their
own institution." RHIT adopted
Scientific
Misconduct: Policy on Allegations, Investigations and Reporting
policy to satisfy this federal requirement.
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INVENTION REPORTING
The
Patent and Trademark Law Amendment Act of 1980, more commonly known as the
Bayh-Dole Act, sets forth ownership rights, licensing, and reporting
requirements for all inventions conceived or first actually reduced to
practice in the performance of a federal grant, contract, or cooperative
agreement.
As a part of these regulations,
Institutions are required to have a policy regarding invention ownership
and disclosure.
The RHIT Policy Regarding
Intellectual Property and
RHIT Invention
Disclosure Form satisfy these requirements. The first step in
complying with invention reporting requirements is to complete and submit
the RHIT Invention Disclosure Form. RHIT is required to disclose the
the invention to the appropriate federal funding agency within two months
after the inventor discloses it in writing to the Institute. For
further information regarding the Bayh-Dole Act, please see
http://www.cogr.edu/docs/Bayh_Dole.pdf. For questions regarding
invention disclosure, please contact Sponsored Programs.
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GENERAL TERMS AND CONDITIONS
While grant and contract terms and
conditions vary by sponsor and award program, the following are routinely
stipulated and any changes to these conditions usually require prior
approval of the sponsor:
Award Period
Financial and technical reporting
requirements
Scope of project
Involvement of animals or human subjects
Identification of Principal Investigator
Identification of performance site(s)-
subcontract
Project Budget
Level of Effort of key project
personnel
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