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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)

Salim Alani Director, OUA

Donna Beyea ORPA

Gunta Liders Director, ORPA

Mary Jo Lyke Manager, ORACS

Michael Ritz Manager, OUA

Douglas Wylie University Controller

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HOW DO YOU FIT INTO AN EFFECTIVE STEWARDSHIP ROLE?

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

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FAILURE TO MANAGE COMPLIANCE RISKS HAS RESULTED IN REPUTATIONAL DAMAGE TO SOME OF

THE WORLD’S MOST RESPECTED INSTITUTIONS

Public Demandfor

Improved Control

Thomas Jefferson UniversityMedicare over-billing

$12 mil

University of MinnesotaMisuse federal grants

32 mil

New York University Medical CenterInflated research grant costs

$15.5 mil

Stanford UniversityInflated research overhead costs

$1.2 mil

University of TexasUnderpayment of royalties

whistle blower$12 mil

Duke UniversitySexual harassment

$0.5 mil

University of ChicagoResearch fraud and abuse

$650,000

Yale UniversityMedical over-billing

$5.6 mil

Miscellaneous Scientific MisconductJohns Hopkins

Harvard (2)Yale

University of MichiganChief Urologist charged with

Conflict of Interest$100,000 penalty1 year probation

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ISSUES & PERSPECTIVES

ISSUES GOVERNMENT ENFORCEMENTPERSPECTIVE

UNIVERSITY PERSPECTIVE

OUTCOMEINSTITUTION

MINNESOTA •Effort Reporting Irregularities

•Failure to obtain informed consent in Clinical Trial

•Scientific Misconduct

•Direct Costs-supplies not related to Grant were charged to Grant

Violations of:

•Civil False Claims Act

•Federal Food Drug & Cosmetic Act

•Anti-Kickback Act

•Scientific Misconduct

•Public Health Service Act

•Title XVII Social Security Act

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.

32 Million Dollar Fine

Loss of Expanded Authority

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ISSUES & PERSPECTIVES

GOVERNMENT ENFORCEMENTPERSPECTIVE

UNIVERSITY PERSPECTIVE

OUTCOMEINSTITUTION

Wisconsin Madison

ISSUES

Overstating # of Sponsors on Grant Application

Fraud Mere Puffery - Listed on his grant application in hopes that they actually would become sponsors

10K Fine 3 months imprison-ment for PI

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Current Internal Investigations Indicate

Benign neglectOutdated and/or ineffective standards, policies,

proceduresLittle or no faculty and staff trainingLittle or no assignment of roles and

responsibilities

Resulting in….

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oConfusion

oUncertainty

oMistakes

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One Solution ….

CLASP Program

Continuous Learning for Administrators of Sponsored

Programs

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What is one solution?CLASP

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

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CLASPWhat is the goal?

A mandatory, classroom-based educational program for all administrators having functional responsibility on grants

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

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CLASP What is the curriculum?

Initial Certification Overview Session (all-encompassing) Proposal preparation, review and approval Effort reporting and cost sharing Post-award administration/accounting for

sponsored programs Project closeout Utilization of MI$ER software or other

expenditure tracking software

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CLASP What is the curriculum?

Subsequent years Annual Update Monthly administrator meetings Subrecipient administration and monitoring Clinical trials administration Training grants Agency specific sessions Responsible conduct of research

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CLASPWho will receive the training first?

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

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CLASP How will it be administered?

Initially through ORPA

Database of administratorsListing of training sessions, dates, locationsOn-line registrationTracking of individual progress

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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