Transcript UPHSorientation - University of Rochester

Continuous Learning for
Administrators of Sponsored
Programs (CLASP)
A Joint Initiative of the Office of Research and Costing
Standards (ORACS), Office of Research and Project
Administration (ORPA) and Office of University Audit
(OUA)
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
Salim Alani
Director, OUA

Donna Beyea
ORPA

Gunta Liders
Director, ORPA

Mary Jo Lyke
Manager, ORACS

Michael Ritz
Manager, OUA

Douglas Wylie
University Controller
HOW DO YOU FIT INTO AN EFFECTIVE
STEWARDSHIP ROLE?
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
As Principal Investigator or business manager, you set the
tone at the top

Evaluate operational impact that non compliance may
have on the University, the school and you individually

Public relations impact potential impact that public
disclosure of non-compliance would have on reputational
risk of institution and your professional reputation

Effective managers have to be an active part of the
solution

Compliance is everyone’s responsibility
FAILURE TO MANAGE COMPLIANCE RISKS HAS RESULTED
IN REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S
MOST RESPECTED INSTITUTIONS
University of Michigan
Chief Urologist charged with
University of Minnesota
Conflict of Interest
Misuse federal grants
$100,000 penalty Thomas Jefferson University
Medicare over-billing
32 mil
1 year probation
$12 mil
Miscellaneous Scientific Misconduct
New York University Medical Center
Johns Hopkins
Inflated research grant costs
Harvard (2)
Public Demand
$15.5 mil
Yale
Yale University
Medical over-billing
$5.6 mil
for
Improved Control
Stanford University
Inflated research overhead costs
$1.2 mil
University of Texas
University of Chicago
Duke University
Underpayment
of
royalties
Research fraud and abuse
Sexual harassment
whistle blower
$650,000
$0.5 mil
$12 mil
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ISSUES & PERSPECTIVES
INSTITUTION
MINNESOTA
ISSUES
•Effort Reporting
Irregularities
•Failure to obtain
informed consent
in Clinical Trial
•Scientific
Misconduct
•Direct Costssupplies not
related to Grant
were charged to
Grant
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GOVERNMENT
ENFORCEMENT
PERSPECTIVE
Violations of:
•Civil False
Claims Act
•Federal
Food Drug &
Cosmetic Act
•AntiKickback Act
•Scientific
Misconduct
•Public
Health
Service Act
•Title XVII
Social
Security Act
UNIVERSITY
PERSPECTIVE
Asserts that the
United States was
specifically aware of
wrongful conduct for
nearly two decades,
which it failed to
communicate to the
University, and
concerning which it
deliberately chose not
to take action,
thereby itself causing
the results which it
pleaded in the
Complaint.
Answer to amended
complaint 2/23/98
attorneys from
regents of U of Minn.
OUTCOME
32 Million
Dollar Fine
Loss of
Expanded
Authority
ISSUES & PERSPECTIVES
INSTITUTION
Wisconsin
Madison
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ISSUES
Overstating # of
Sponsors on
Grant
Application
GOVERNMENT
ENFORCEMENT
PERSPECTIVE
Fraud
UNIVERSITY
PERSPECTIVE
Mere Puffery Listed on his
grant
application in
hopes that
they actually
would become
sponsors
OUTCOME
10K Fine 3
months
imprisonment for PI
Current Internal Investigations Indicate

Benign neglect

Outdated and/or ineffective standards, policies,
procedures

Little or no faculty and staff training

Little or no assignment of roles and responsibilities
Resulting in….
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o Confusion
o Uncertainty
o Mistakes
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One Solution ….
CLASP Program
Continuous Learning for Administrators
of Sponsored Programs
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What is one solution?
CLASP
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
Trained and educated staff work more efficiently and
with fewer mistakes

Interface with central A&F offices creates a working
partnership

The minimal costs of initiating an educational program
for administrators far outweighs the fines and penalties
arising from the improper administration of federal
awards

Administrators are the “front line” of defense, expected
to know requirements of sponsors and to inform the
faculty
CLASP
What is the goal?
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
A mandatory, classroom-based educational program for
all administrators having functional responsibility on
grants
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Initial and continuing certification as a requirement of
retaining job position

In time, change Proposal Sign-Off Form to require a
CLASP-certified individual to be identified as
administrative oversight before submitting proposals to
sponsors
CLASP
What is the curriculum?
Initial Certification
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
Overview Session (all-encompassing)
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Proposal preparation, review and approval
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Effort reporting and cost sharing

Post-award administration/accounting for sponsored
programs
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Project closeout

Utilization of MI$ER software or other expenditure
tracking software
CLASP
What is the curriculum?
Subsequent years
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Annual Update

Monthly administrator meetings
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Subrecipient administration and monitoring
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Clinical trials administration
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Training grants

Agency specific sessions

Responsible conduct of research
CLASP
Who will receive the training first?
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
Administrators with functional responsibility in
sponsored programs having less than two (2) years
experience

ORPA, ORACS, OUA request the authority to jointly
identify respective personnel whose performance
demonstrates a more urgent need for the training.
Feedback from the Deans’ Offices will be considered in
the process.

Objective measures will also be utilized to the greatest
extent possible
CLASP
How will it be administered?
Initially through ORPA
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
Database of administrators
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Listing of training sessions, dates, locations
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On-line registration

Tracking of individual progress
CLASP
How will it be evaluated?

Subjective measures
Participant evaluation forms

Objective measures
Cost transfers
Effort reallocations
Timeliness of close-out reports
Revised financial reports
Investigative audits
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Proactiveness Counts!
Certain peer institutions have developed, or are
developing, similar educational programs.
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CLASP
Continuous Learning for Administrators
of Sponsored Programs
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