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April 21, 2015Administrators Workgroup Agenda Introductions Announcements / Updates (Raquel Espinosa) HR transactions (Sue Negro, Tanya Bernabei, Liz Walker) Innovation PD roll-out (Raquel Espinosa) Revised PI Eligibility Policy (Raquel Espinosa) Q & A – All 2 Announcements/Updates Central Pre-award Role As a follow up to discussions with senior grant administrators, preaward support will be moving to Partners Research Management. While Research Management is recruiting for the pre-award administrator position, we will continue using “RSS” (Research Support Services). These services are offered by Partners Research Management by assignment of seasoned staff that are knowledgeable, know the systems and are signing officials on behalf of McLean. For purposes of preparing for pre-award volume ahead, please create InfoEd shells in advance to ensure RSS can prioritize as needed. We thank you for your support while we work through this transition. 4 Partners Research Management Training Update Upcoming Training Courses • • Data Use Agreements Apr 13th 9AM-12PM ASSIST Proposal Submission System Apr 24th 9AM-11AM Journal Entries in Depth Apr 27th 9AM-12PM Research Cores Apr 27th 1PM-4PM An Introduction to Research Management May 4th 9AM-12PM Navigating International Collaborations May 4th 1PM-4PM Visit Research Management’s Course Catalog for course descriptions and handouts. Register for courses through PeopleSoft Self-Service. Instructions can be found at the bottom of the RM Course Catalog Home Page. RADG/BRISC/DRAW Training Update April 2015 Effort Report Summary – 2015 P1 Pre-Review 32 Certification 33 Post-Review 4 Completed 52 Total 120 6 McL FY15 Provisional Fringe Benefit Rates • New FY15 McL Fringe Benefit rates have been submitted to DHHS for approval. • When the new rate agreement has been issued, a more complete update will be given. • Until then the provisional fringe benefit rates below will be charged to all research grants. • Current Rate agreement is still dated September 13, 2012. 7 NIH Closeout Deliverables • NIH FAQ’s: http://grants.nih.gov/grants/closeout/faq_grants_closeout.htm • How to find grants that require closeout (IPF # 1876801): https://public.era.nih.gov/chl/public/search/gpc.era • All reports required for closeout must be submitted no later than 120 days after the project end date Final reports: • Financial Report must be submitted through the eRA Commons (Research Finance) • Final Progress Report submitted through eRA Commons (PI) • Final Invention Statement submitted through the eRA Commons (PI and notify Research Administration) 8 HR transactions Susan Negro, HR Director Tanya Bernabei, HR Generalist Liz Walker, HR Assistant Discussion with the group Next steps: - HR plans to join the DRAW in upcoming months to discuss HR transactions and how to modify current processes based on past experience and needs 10 InfoEd for Innovation Update Innovation PD roll-out • Go Live date: April 20, 2015!!!!! • Effective immediately on April 20, all requests for these agreements must be initiated through PD The following Innovation agreements will be handled through InfoEd a. Sponsored Research Agreements (SRA) b. Material Transfer Agreements (MTA) c. Confidentiality Agreements (CDA) for discussion of preclinical research and intellectual property 12 Tips for PD entry of Innovation agreements Sponsored Research Agreements (SRA) • • • • • PI Questionnaire embedded in PD process Must submit scope of work and budget, approved by the sponsor PD provides links to contact list w/ Innovation Associate for each chief code SRAs are automatically routed through the chief If the scope of work involves use of or transfer of human tissue, IRB approval will be required prior to final signatures 13 Continuation- Tips for PD entry of Innovation agreements Material Transfer Agreements (MTA) • • • • PD will ask if material is being received or sent PI Questionnaire embedded in PD process PD provides links to contact list with TAG Associate for each chief code IRB approval required for transfer of human tissue, clinical data Confidentiality Agreements (CDA/NDA) • Initiation of one-way in, one-way out and mutual CDAs • PI Questionnaire embedded in PD process • PD provides links to contact list with TAG Associate for each chief code 14 Innovation PD: Important Notes • Invention Disclosures – no change to the process • Effective April 20, all links to PI questionnaires for MTAs, CDAs and SRAs will be removed from Innovation website and Research Navigator, with instructions to submit through InfoEd (links provided) • Status updates for SRAs, MTAs and CDAs will be available by logging into the proposal in InfoEd. 15 Revised PI Eligibility Policy Research Compliance Update McLean Research Committee April 1, 2015 Mary Mitchell Partners Research Compliance Agenda Partners PI Eligibility Policy Revisions Research Compliance & Scientific Integrity Partners Policy on Handling Allegations of Research Misconduct 18 Policy Overview Effective date: 4/15/15 Applies BWH, MGH, IHP, McLean & Spaulding New: Partners Principally Paid – New – no less than 50% from Hospital/institute funds HMS endowment funds Harvard endowment or other funds PHS funds Sponsored research funds HHMI Hold or in process of obtaining hospital/faculty appointment New: Professor in Residence Policy Overview – continued New Requirements Training, skills & expertise for project direction determined by Chief. Able to provide regulatory oversight & meet sponsor and institutional requirements. Chief certification PI meets eligibility criteria. “Non-employee” or “person of interest” – ineligible to serve as P.I Policy Overview - continued No change No delegation of PI responsibilities Limitation of authority – cannot bind institution Continued eligibility contingent on Good financial stewardship Compliance with federal, sponsor, & Partners/hospitals requirements PI status may be revoked by Chief or SVP Exceptions Nurse/other health professions Postdoctoral fellows/graduate students Supervision by faculty member w/PI status Limited to duration of project New - PI on Partners HealthCare Award System-wide research PHS CAO and SVP approval Meet all PI requirements Other professional may be granted PI status New - Change in Employment Expectation departing PI Transfers grants to new institution. New PI appointed Request an exception Include justification & oversight plan Chief & SVP approval required prior to departure PI responsibilities Obtain regulatory approvals at new institution & Partners Work w/offices to execute agreements w/new institution IP, data transfer/sharing, publication rights Work w/Research Management on sponsor approval New – Employment Reduced to Less Than 50% Submit request 30 days in advance How effort will be adjusted How oversight will be maintained If reduction based on primary appointment at new institution, explanation of how duties will be split between institutions. Chief & SVP approval required prior to reduction PI responsibilities Obtain regulatory approvals at new institution & Partners Work w/offices to execute agreements w/new institution IP, data transfer/sharing, publication rights Work w/Research Management on sponsor approval Remaining Provisions No change Resources/space commitments New Policy limited to sponsored research projects Summary of PI responsibilities – Attachment B Research Compliance & Scientific Integrity The right to search for truth implies also a duty; one must not conceal any part of what one has recognized to be true. Albert Einstein A not-so-far-fetched scenario A postdoc meets with her PI to review her data in PowerPoint format which she has compiled into publication-quality figures using Photoshop. One of the figures she shares with her PI includes data derived from an experiment generated under different experimental conditions than those shown in her figure labels. This figure has never been inserted into a draft manuscript, published or otherwise presented outside the meeting with her PI. Is this research misconduct? Research Misconduct Defined Research misconduct (as defined by 42 CFR Part 93) Falsification Making up results and reporting them Fabrication Manipulating research materials, data, or processes; or manipulating data such that the research is not accurately represented in the record Plagiarism Appropriation of another person’s ideas, results, or words without giving that person appropriate credit) Research Misconduct: What it is, what it isn’t. Falsification Fabrication Plagiarism Significant departure from accepted research practice Proven by a preponderance of the evidence o Intentional o Knowing o Reckless - Not an honest error - Not a difference of scientific opinion - Not non-compliance related to human subjects or animal subjects - Not misuse of research funds Office of Research Integrity, 42 CFR, Sec. 93.104 Process & Key Players Research Integrity Officer (RIO) • Shelly Greenfield Complainant •Journals •Anonymous •Collaborator •Postdoc, student •Received from ORI •Retraction Watch Respondent •Anyone performing, proposing, reporting •Can be multiple respondents in a given matter •All levels of appointment can and have been respondents Office of Research Integrity •Jurisdiction over PHS funded work •Informed when review reaches Investigation •Waits for institutional finding before own review Costs of Misconduct Direct costs associated with handling research misconduct cases at the institutional level in the US exceed $110 million annually1 Estimated $525,000 per case1 Institutional reputation Investigator reputation Retraction of publications Loss of employment Debarment Jail time Dr. Scott Rueben – Tufts Dr. Eric Pohlman – University of Vermont Dr. Luk van Parijs - MIT Repayment of sponsored funds Loss of public trust Greater federal oversight/scrutiny of research/grant activities. 1Michalek et al. (2010) Not Just an Academic Issue A 2011 article in The Journal of Medical Ethics reviewed ~200 papers that were retracted due to questionable data the published research was tied to 28,000 patients, 6,573 of whom received treatment based on the research presented in the retracted papers (Steen, 2011). Evolving Academic Research Environment Junior faculty at increased risk Increase in foreign-born researchers Mentoring increasingly challenging Data storage and presentation processes changing Academic Appointment Level Early and mid-career researchers account for 2/3 of research misconduct findings (Martinson et al., 2005) Pressure to obtain external funding and federal research dollars to support one’s salary positively correlated with reports of serious misconduct (Martinson et al., 2009) Professional stressors - being overworked & pressure to complete experiments/produce data with insufficient time allotted - correlated with research misconduct (Davis et al., 2007) Foreign-born Investigators: Vulnerabilities Differing cultural norms (Davis, 2003) Lack of English proficiency (Xiguang & Lei, 1996) Fear of asking for help (Davis, Riske-Morris and Diaz, 2007) Lack of Responsible Conduct of Research training/oversight in country of origin (Okonta and Rossouw, 2012) Mentoring 62% of mentors had not established procedural standards (Wright et al., 2008) 73% had not reviewed the raw data generated by their trainees (Wright et al., 2008) “Improvement in the quality of mentoring in training programs” is the path to reducing misconduct at any given institution (Kornfeld, 2012) Research Integrity: What Not To Do Fail to review raw data prior to publication; accept summary data or prepared tables or graphs instead. Demand significant results on Friday to meet a publication or grant deadline on a project where expected results have not been achieved over several months. Hire a new postdoc who comes highly recommended but leave him or her without guidance or supervision. Tell your lab members to ask question but don’t make yourself available because you are too busy. Tell your lab tech what results you expect from the experiment and that you need the results right away. Research Integrity: What You Should Do Report all allegations to your RIO Establish Data Management Plan (DMP) Project description Roles & responsibilities of each member of group Form of data collected: imagines, lab values, measurements, electronics files, written records, combination of the above Special considerations: PHI? Limited data set Security: How will you protect from theft? Disaster retrieval? Data sharing Storage – long term & short term Research Integrity: What You Should Do Establish and maintain critical record keeping Notebooks Common language: English An accurate reflect of process Legible and understandable by others All experiments recorded not just those that work Primary data kept in or adjacent to notebook Mice breeding and housing and reagent sources recorded Reagent location recorded Date/PI initial/witness Electronic files Keep original files of primary data in a secure location – not shared Ensure systems have audit trail functionality (versioning) References Davis, M.S., Riske-Morris, M., Diaz, S.R. (207). Casual Factors Implicated in Research Misconduct: Evidence from ORI Case Files. Science and Engineering Ethics, 13, 395-414. Fang, F. C., Steen, R.G., & Casadevall, A. (2012). Misconduct accounts for the majority of retracted scientific publications. Proceedings of the National Academy of Sciences, 109(42), 17028-17033. Kornfeld, D.S. (2012). Perspective: Research Misconduct: the search for a remedy. Academic Medicine, 87(7), 877-882. Martinson, B.C., Anderson, M., & de Vries, R. (2005). Scientists behaving badly. Nature, 435, 737-738. Michalek, A.M., Hutson, A.D., Wicher, C.P., and Trump, D.L. (2010). The Costs and Underappreciated Consequences of Research Misconduct: A Case Study. PLoS Med, 7(8). Martinson, B.C., Crain, A.L., Anderson, M.S., & de Vries, R. (2009). Institutions’ Expectations for Researchers’ Self-Funding, Federal Grant Holding, and Private Industry Involvement: Manifold Drivers of Self-Interest and Researcher Behavior. Academic Medicine, 84(11): 1491-1499. Okonta, P. & Rossouw, T. (2012). Prevalence of Scientific Misconduct among a group of Researchers in Nigeria. Developing World Bioethics. Wright, D.E., Titus, S.L., & Cornelison, J.B. (2008). Mentoring and Research Misconduct: An Analysis of Research Mentoring in Closed ORI Cases. Science and Engineering Ethics, 15, 323-336. Acknowledgement Thanks to Allison Moriarty for sharing research misconduct slide decks that contributed significantly to this presentation. Questions/Discussion 43 QUESTIONS? Contact: Raquel Espinosa [email protected] 617-855-2868 44