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.
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.
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
Daniel Morris,(x8314) Institute Reviewer, to seek this approval. Researchers are also encouraged to reference Human Subject Research at RHIT for further guidance.
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
fulfills the requirements of grantee institutions as put forth in the
Institute of Health guidelines and the
National Science Foundation's conflict of interest policies. Our
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, "Investigators" (all
personnel responsible for the design, conduct or reporting of research under
the terms of a federal grant or contract) will be asked to certify their
familiarity with the policy, and to disclose any "significant financial
interests" associated with their institutional responsibilities not
previously disclosed in the annual process.
The new rules now mandate that
investigators on NIH or other Public Health Service (PHS) affiliated
agencies must complete training covering the Institute's policies,
Investigator's responsibilities under that policy and the federal
regulations. Below is a link to the NIH tutorial specific to the
2011 final rules. To fulfill this training requirement RHIT has added
a Conflict of Interest
training module to the CITI program.
NIH Training of Financial Conflict of Interest
(required prior to undergoing NIH Funded Research)
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.
Frequently Asked Questions - NSF
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.
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.
further information regarding the Bayh-Dole Act, please see
The Bayh-Dole Act A Guide to the Law and Implementing Regulations.
For questions regarding invention disclosure, please contact Sponsored
TRAINING - CITI
To assist with the training requirements for the various federal agencies
policies, RHIT has selected the on-line training modules offered by the CITI
The CITI Program is a subscription service providing research ethics
education to all members of the research
community. Participants will need to
register and create a user name and
password to gain access to the CITI site.
Select Rose-Hulman Institute of
Technology as the participating Institution to
view the course offerings. Upon
completion of these various modules, the
participant will be able to print a
completion report that can be used to confirm
successful completion of the training.
available modules for training include: Lab Animal Research,
Conduct of Research, Export Controls and Conflicts of Interest.
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:
Financial and technical reporting requirements
Scope of project
Involvement of animals or human subjects
Identification of Principal Investigator
Identification of performance site(s)- subcontract
Level of Effort of key project personnel