Creating Successful Research Projects: Navigating the Process (New Faculty Orientation 12/16/10)
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Transcript of Creating Successful Research Projects: Navigating the Process (New Faculty Orientation 12/16/10)
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Creating Successful Research Projects:
Navigating the Process
---New Faculty Orientation---December 16, 2010Walker Ames Room
Kane Hall
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WELCOME
David Eaton, PhDInterim Vice Provost for Research
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NEW UW FACULTY
• 1st new faculty orientation
• 375 new faculty in 2009-2010– Transfers from other institutions– First faculty position
• “…we are partners in a shared future.” (Interim President Phyllis Wise, December 2010)
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WORLD LEADERS IN RESEARCH
We have grown into the most successful public research university in the nation in attracting support for our research.
Ours is a proud culture of innovation, collaboration and discovery that has
transformational impact.
From the UW Mission Statement
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WE ARE:
• World leaders in research
• One of the most successful public research university in the nation in attracting support for our research
• Innovative & collaborative
• Impacting our community, nation and the world
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IMPACT
• UW research makes far-reaching impacts
• Locally, nationally, and globally
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WE ARE HERE TO HELP
• Offices presenting today are part of the central oversight and support for your research enterprise.
• We will work with you to ensure your projects meet sponsor requirements, state & federal law, and UW policy.
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TODAY’S WORKSHOP
• Introduction to the central research support offices
• Learn how to navigate the UW Processes
• Maneuver through the multiple regulatory and compliance considerations within the grant lifecycle
• Manage the pre and post award process at UW
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Successful acquisition & management of grants requires
many partners• Individual faculty, and their departmental and Dean’s office
support staff
• Office of Research – all components
• Grant and Contract Accounting
• Management Accounting & Analysis
• Human Resources
• Purchasing
• Facilities Management
• Environmental Health & Safety
• Animal Welfare
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OR - MAJOR ADMINISTRATIVE UNITS
• Office of Sponsored Programs (OSP)Director of OSP & Assistant Vice Provost for Research, Lynne Chronister
• Human Subjects Division (HSD)Director of HSD & Assistant Vice Provost for Research, Karen Moe
• Office of Research Information Services (ORIS) Director of ORIS & Assistant Vice Provost, Jim Kresl
• Office of Research - Central (OR)Interim Vice Provost for Research, David Eaton Associate Vice Provost-Compliance and Operations, Jeff Cheek Associate Vice Provost-External Relations, Mani Soma
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TODAY’S SPEAKERS
• Office of Sponsored Programs - Lynne Chronister• Office of Research Information Services - Patti
McClure• Grant & Contract Accounting - Tami Sadusky• Management Accounting & Analysis - Mike
Anthony• Center for Commercialization - Linden Rhoads• Environmental Health & Safety - Jude Van Buren• Office of Animal Welfare - Nona Phillips• Human Subjects Division - Karen Moe• Internal Audit - Zenaida Shattuck• Conflict of Interest – Jeffrey Cheek
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RESOURCES AVAILABLE
• A resource table is set up at the back of the room. Please stop by and collect materials you feel can assist you in creating successful research projects.
• This PowerPoint deck will be posted on the OSP website tomorrow.
• Evaluation form – please tell us how we did!
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OFFICE OF SPONSORED PROGRAMS (OSP)
Lynne Chronister, Assistant Vice Provost for Research & Director OSP
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OSP MISSION The Office of Sponsored Programs, a unit in
the Office of Research, supports and advises the entire academic community in securing external support for sponsored projects and collaborations.
We review, negotiate, approve, and provide
administrative oversight related to proposals and establishment of awards on behalf of the University of Washington in accordance with all applicable policies, and regulations.
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OSP RESPONSIBILITIES
What do we do?• Review and approve proposals• Submit electronic proposals• Negotiate and sign awards and subcontracts• Liaison with sponsor for award life• Coordinate close-out of awards• Implement Grant & Contract policies (financial,
legal, and regulatory)• Provide customer support to UW faculty and
staff
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OSP STRUCTURE
• Each unit on campus assigned to Team A or Team B
• Team C reviews all Industry-Sponsored Clinical Trials
• Subcontracts Team manages all outgoing subcontracts and required reporting
• Team Structure: – Administrator– Grant & Contract Coordinator– Program Coordinator
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Business Sections• Face Page• List of Personnel• Biosketches• Budget• Budget Justification• Checklist• Required Additional Information
Scope of Work• Description of the Research• (The Science)
Final Version by Day – 7
Draft Version by Day – 7
Final Version by Day - 3
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PROPOSAL BUSINESS PROCESS
1. Identify sponsor & complete applicationHints: read & follow instructions, contact your OSP
admin if you have questions
2. Fill in SAGE eGC1, attach application & route for
internal approvals
3. Review & approve by OSPOSP will work with PI & Dept to ensure the best
application can be submitted to the sponsor
4. Submit application per sponsor instructions
o Application is submitted by OSP/PIo Via electronic, paper, web formats
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AWARD BUSINESS PROCESS
• Sponsor may notify PI or OSP that application is fundable
• Award documents arrive
• OSP negotiates & accepts award (exceptions)
• OSP creates eFA and sends to GCA
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• Advanced Budgets (if allowed by sponsor)
• Modification to an award (PI, dates, re-budgeting, etc.) must be processed by OSP and may require sponsor approval
• No-Cost Extensions• Sub-Awards are made through OSP
ADMINISTRATIVE BUSINESS PROCESS
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SPONSORED PROGRAMPOLICY
GIMs (Grant Information Memoranda)
• Provide policy and guidance on submitting and managing awards
• Linked from the OSP Home page
• Currently “Under Construction”
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• Contact your OSP Administrator early in the process with questions.
• What does the PI sign?Nothing that will create liability or
commitment
• What does OSP sign?Anything that commits the institution
OSP HINTS
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New Facilities and Administrative (F&A) Rates
LocationNegotiated Rates (FY 2010-
2014)
On-campus54% -- FY 2010-2012
54.5% -- FY 2013-2014
Off-campus 26%
South Lake Union66% -- FY 2010; 68% FY 2011;
72% -- FY 2012; 73% -- FY 2013;74% -- FY 2014
Regional Primate Center42% (A)/
78% (A+B)/83% (A+B+C)
Applied Physics Lab 17%
Other Sponsored Activity33.8% (on-campus)26% (off-campus)
Vessel 25% (S&W)
Instruction53.0% (on-campus)26% (off-campus)
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• Grants Information Memoranda (GIM)
• OSP Web Page
• Researcher’s Guide
• Monthly Research Administration Meetings (MRAM)o Subscribe to List Serve - get meeting announcements &
email updateso MRAM Web siteo Monthly in-person updates to campus
OSP RESOURCES
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CLINICAL RESEARCH• School of Medicine – Clinical Research• Richard Meisinger, PhD, Ass’t Dean for
Planning and New Initiatives, Office of Research and Graduate Education, School of Medicine, [email protected]
• Ella Mae Kurashige, Director, Clinical Research Services, [email protected]
• Office of Clinical Research Budget & Billing (CRBB)
• Clinical Trial start-up and web resources
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OFFICE OF RESEARCH INFORMATION SERVICES (ORIS)
Patti McClure – Educational Outreach SpecialistTiffany Austin – Learning Specialist
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SAGESystem to Administer
Grants Electronically
Research Road Map
Hosted Services
Research Road Map
Hosted Services
Web Services Data ReportingWeb Services Data Reporting
Serving UW's research community through IT
solutions
Serving UW's research community through IT
solutions
OFFICE OF RESEARCH INFORMATION SERVICES (ORIS)
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SAGE(System to Administer Grants
Electronically)
• Create, route, and manage the electronic routing form (eGC1) required for all UW grants and contracts/research applications
• Centrally store and share grant proposal information
• Access grant proposal information from any internet-connected location
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WHEN TO USE SAGE?Activity in SAGEActivity in SAGE
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SAGE BUDGET
An easy-to-use budget worksheet customized to comply with Research and UW Accounting Rules
• Supports UW object code accounting• Provides up-to-date salary & benefits information• Identifies correct F&A rate(s) for your budget• Attaches to eGC1
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eGC1 APPROVALS
• Routes your eGC1 to the appropriate parties for online review and approval
• Enables you to check on routing status of your eGC1
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GET STARTED WITH SAGE
• Request access from your department• Practice on the training server• Enroll in SAGE 101 training course
www.sage.washington.edu
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CONTACTS & QUESTIONS
• SAGE Learning – Email: [email protected]
• SAGE Help Desk– Email:
[email protected]– Telephone: 685-8335
• Questions?
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GRANT AND CONTRACT ACCOUNTING/EQUIPMENT INVENTORY OFFICE Division of Research Accounting & Analysis within Finance & Facilities
Tami Sadusky, Executive Director
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Finance & Facilities
RESEARCH ACCOUNTING & ANALYSIS (RAA)
RAA Mission: We help people who change the world
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GCA RESPONSIBILITIESWhat do we do?
• Set up grant and contract budgets in the University’s Financial Accounting System (FAS)
• Prepare and submit required invoices and financial reports to sponsoring agencies
• Manage grant and contract cash transactions and payments
• Provide oversight and guidance on compliance issues
• Coordinate financial close-out of budgets
• Monitor grant related transactions on a sampling basis
• Work with Internal Audit on all grant related audits
• Provide customer support to UW faculty and staff
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EIO RESPONSIBILITIES• Prepare Closing Inventory Reports• Facilitate State, Federal, and Agency inventories• Assist departments with equipment fabrications • Print and distribute asset tags to departmental inventory
contacts• Train departments on General Inventory Procedures,
OASIS Access, and Inventory processing • Assist PI’s taking equipment out of the country• Review and approve transfers of equipment out of the
University• Facilitate annual depreciation for the University’s
financial statements
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GCA/EIO Structure• ‘Streams’ of Fiscal Analysts handle core
processes:– Budget set up - Invoicing– Reporting - Closing
• Cash Team handles grant related cash transactions and applications
• Grant Analysts handle all campus communication including outreach and training
• Complex Grant Analysts handle complex grants and contracts
• Equipment Team handles all equipment processes
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POST AWARD PROCESS
Academic Dept/Office of
Sponsored Programs
Proposal & Award
Process
Assignment of Budget Numbers
Receipt and processing of eFA (Electronic Funding
Action)Active Grant Period
Expenditure Allowability Payment requests to
sponsors
Closing
Fiscal ReportingAudits
External to Grant and Contract Accounting
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AWARD LIFECYCLEAward Step Responsible PartyIdentify funding PIPrepare proposal PI & Department StaffReview and submit proposal PI & Office of Sponsored
Program (OSP)Negotiate and accept award OSPSet up award Grant & Contract Accounting (GCA)Perform work PI Financial management PI, Department Staff, GCATechnical reporting PI Monitor activity PI & Department StaffInvoice and collect payments GCA Monitor accounts receivable GCA & Department StaffClose-out award PI, Department Staff, GCA & OSP
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THE BUDGET• Provides the framework for financial
compliance• GCA creates a budget number for an
award to accumulate costs associated with the project.
• The budget is allocated in the financial accounting system (FAS):– Direct costs– Facilities and Administration (F&A or
indirect costs)
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DIRECT COSTS
Costs that should be directly charged to sponsored agreements when they can be specifically identified to the work performed under those agreements.
- Salaries, Wages, and Fringe Benefits
- Supplies and Materials- Equipment
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INDIRECT COSTS
Cost that are normally considered administrative,
infrastructure or benefit multiple projects
– Administrative and Clerical salaries– Basic local phone service– Office supplies– Routine copying charges
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POLICIES Federal, State, University & Sponsor
Award Terms
Departmental
PoliciesUniversity Policies &
ProceduresSponsor Policies
Federal Policies and Governmental
Law
Accounting & Financial
Policies
NIH - GPS
A-21, A-110,FARs
Learn How to Apply the Policies
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PI/DEPARTMENT RESPONSIBILITIES
• Assistance in grant and contract reporting/closings
• Separation of (high risk) duties, such as payroll or petty cash
• Deficit resolution• Program Income• Cost Sharing/Faculty Effort Reporting• Unexpended balances• Records retention• Faculty Effort Certifications (FECs)• Address problems related to fiscal
activities promptly
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HINTS
• Take a proactive approach to grant management
• It’s critical that all parties work together• Adhere to University, State, Federal and
Sponsor policies and regulations• Establish proper financial accountability
structure• Ensure proper financial management with
attention to data integrity
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GCA RESOURCES• GCA Web Page
• GCA email/phone: [email protected] 206-543-8454
• Grant Tracker
• Researcher’s Guide
• Monthly Research Administration Meetings (MRAM)
• Grants Information Memoranda (GIMs)
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MANAGEMENT ACCOUNTING & ANALYSIS (MAA) Division of Research Accounting & Analysis within Finance & Facilities
Michael Anthony, Executive Director
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Finance & Facilities
RESEARCH ACCOUNTING & ANALYSIS (RAA)
RAA Mission: We help people who change the world
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MAA – OFFICE RESPONSIBILITIES
What do we do?• Calculate and negotiate the University’s
Facilities and Administrative (F&A) rates
• Review and approve Recharge Center/Cost Center/Program Income rates
• Provide oversight for the Federally mandated effort reporting process
• Provide support to UW faculty and staff
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MAA - STRUCTURE
Major Department Activities/MAA Units:
• F&A rate calculation and negotiation
• Recharge/cost center and program income rate review and approval
• Effort reporting training and oversight
All units participate in customer service to faculty and staff
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F&A RATE CALCULATION & NEGOTIATION
F&A (Indirect) Costs
• Infrastructure costs necessary to support the UW’s research mission
• Represents ‘real’ institutional costs
• Incurred for common or joint objectives
• Cannot be identified specifically with a sponsored project or other institutional activity
• Recovered through the application of the F&A rate to funded sponsored agreements
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CURRENT F&A RATES (effective 7/1/09)
• 54% On-campus Research
• 26% Off-campus
• 33.8% “Other Sponsored Projects” (New rate for UW will be used for non-research and non-training or education)
• Other special rates (e.g., Applied Physics Lab; South Lake Union; Regional Primate Center)
• http://f2.washington.edu/fm/maa/fa/rates
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RECHARGE /COST CENTERS
• Recharge/Cost Centers - units or activities providing goods/services primarily to internal university operations
• Recharge Centers - charge more than $125,000 annually to federally sponsored agreements OR more than $1,000,000 in total charges
• Cost Centers - charge less than $125,000 annually to federally sponsored agreements AND less than $1,000,000 in total charges
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PROGRAM INCOME• Income generated as a result of a research
activity
• Tied to a specific grant or contract, usually Federally funded
• Income may be internal and/or external
• These types of activities require prior approval from the agency that sponsored the original research
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PROGRAM INCOME RATES
• MAA– Reviews rates to ensure they are
compliant with Federal costing principles– Verifies costs are not being recovered
through other means, e.g., through the F&A rate process
• GCA– Establishes program income budgets– Ensures program income is netted from
reimbursement requests
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EFFORT REPORTING• Federally mandated compliance requirement
• Requires periodic certification that percent salary charged to sponsored project represents a reasonable reflection of percent effort devoted to the project
• Includes committed cost shared effort
• Faculty – Accomplished through Faculty Effort Certification (FEC)
• Non Faculty – Accomplished via Grant and Contract Certification Report (GCCR)
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EFFORT REPORTING• Faculty Effort Certification (FEC)– Done every 6 months
– SOM/Dentistry/Public Health/Pharmacy• January 1 – June 30• July 1 – December 31
– All other schools/colleges• September 16 – March 15• March 16 – September 15
• Grant and Contract Certification Report (GCCR)– Done on the calendar quarter
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MAA - RESOURCES• GIM (Grants Information Memoranda) – GIM 13: Indirect Cost Rates– GIM 22: Facilities and Administrative
Costs: An Explanation– GIM 35: Effort Reporting Policy for
Sponsored Agreements
• MAA Web Page
• MRAM (Monthly Research Administrators Meeting)
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CENTER FOR COMMERCIALIZATION (C4C)
Linden Rhoads, Vice Provost
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ENVIRONMENTAL & OCCUPATIONAL HEALTH & SAFETY (EH&S)
Jude Van Buren, Director
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EH&S - MISSION To support the University of Washington’s
teaching, research, and service missions, the Environmental Health and Safety Department assists organizational units in meeting their responsibility to:
– protect the environment – provide a safe and healthful place of
employment and learning
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EH&S Functional Org ChartHow we are organized to support you
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Conducting UW research has many parallels to running a successful
business• You have employees to protect and supervise
• You have materials (biologicals/ chemicals/ radiation)
• You may have animals or plants under your care
• You have procedures, methods and protocols for your processes
• You have approvals and laws that govern your practices
• You have a facility you need to maintain
• You have neighbors you must consider
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Local, State and Federal laws that address your research:
EH&S has responsibilities and authority provided in UW Admin. Policy Statements (APS) to meet those regulations
State and Federal Worker Health &
Safety Laws
UW APS & Your
ResearchState and Local Public
Health /Fire Safety Laws
Fed. laws: Select Agent, Agriculture,
Animals
Hospital Operational/ Facility Laws
State and Federal
Environmental Pollution Laws
Hazardous materials laws
Federal sponsor
requirements
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5 questions on SAGE that will engage EH&S involvement in your
research1. EHS-1: Any Pathogenic Agents, Potential Biohazards, recombinant DNA, human tissues or cells, hazardous materials in animal studies or highly toxic chemicals? If YES – then:
2. EHS-2: Any involvement of acquisition, possession, use transfer or shipping of Select Agents, Exempted Select Agents or Toxins?
3. EHS-3: Generate hazardous waste without disposal options or mixed waste (radiation + Hazardous components) or multi-hazard waste (biological /hazardous /radiological components)?
4. EHS-4: Involvement of uses of radiation: transuranics, gaseous alpha-emitters or intentional release of radionuclides to atmosphere?
5. EHS1-A: Does Sponsor require Institutional (UW EH&S) Safety Review of facility prior to submission to the sponsor.
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MUST HAVES – for working with biological material and/or recombinant DNA1. Biological Use Authorization (BUA)
Institutional approval from EH&S and the Institutional Biosafety Committee
(IBC). All work with Recombinant DNA, pathogenic organisms, human or non
human primate tissues (including all cell lines) or other biohazardous agents.
http://www.ehs.washington.edu/rbsresplan/rpha.shtm
2. Biological Safety Manual use required and made available to staff http://www.ehs.washington.edu/rbsbiosafe/bsmanualindex.shtm
3. Biological Safety Training required by NIH for all of above research prior and annually for work with biohazards
In person class offered monthly – soon to be on-line
4. Bloodborne pathogen training (BBP) required when working with human blood, blood byproducts and human tissue – (new and annual trainings – in person and soon on-line)
ALL EH&S trainings can be found on our webpage.
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MUST HAVES – for working with animals and/or hazardous
materialsOccupational Health Reviews:• All researchers and staff working with Animals
• Must complete EH&S Animal Use Medical Screening (AUMS) Form - receive medical clearance. Review required prior to initiation (IACUC approval) and every 3 years.
• All Animal Research using hazardous materials• IACUC approval requires Occupational Health Nurse
(OHN) review of research involving biohazards, chemical hazards
• OHN sends PI letter and IACUC recommendations about these hazards in their protocol
• PI must review OHN recommendations with staff and adhere to vaccinations requirements where indicated and work safety practices including protocols and personal protective equipment
• Highly hazardous chemicals are referred to EH&S Occupational Hygienist for follow up – possible lab visit and changes to protocols and SOPS to address hazards
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MUST HAVE – engineering controls when working with
chemicals• Appropriate room ventilation
• Functional safety shower and eye wash
• Fume hood with recent EH&S performance test
• Appropriate chemical storage cabinets
• Spill kits/secondary containment
• Appropriate ventilation if using chemicals in a certified biosafety cabinet
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MUST HAVE administrative controls for chemical use
• Chemical management training• Health Hazards from exposures• Operations
• Use/storage/Personal Protective Equipment• Waste/ Spills• Standard Operating Procedures
• Chemical inventory, MSDSs (material safety data) and emergency contacts (MyChem)
• Training for shipping hazardous materials
• Fire Department hazmat permit
• EH&S approval for toxic gases
• All EH&S trainings at http://www.ehs.washington.edu/psotrain/corsdesc.shtm#initialbloodborne
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If you are working with radiological materials you MUST have:
• Been granted Authorized Investigator (AUI) status by the EH&S Radiation Safety Office or be working under an existing AUI.
• X-ray and laser generating equipment must registered with the Radiation Safety Office. • Training must be verified and inspection schedules
established for x-ray producing equipment. • Disposal of these items must be done properly.
Users must notify the RSO prior to disposal.
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Responsibilities you must address for your employees welfare:
1. Report employee accidents Employee must inform boss and EH&S http://www.ehs.washington.edu/ohsoars/index.shtm
2. Inform employees of what they are working with: Worker Right-to-Know Communications http://www.washington.edu/admin/rules//APS/12.05.html Identify & label hazardous chemicals appropriately Access Material Safety Data Sheets (MSDSs)
http://www.ehs.washington.edu/epomychem/msds.shtm
3. Review current Lab Safety Manual, keep it in your lab & available to staff http://www.ehs.washington.edu/manuals/lsm
4. Report chemicals used in MyChem – chemical inventory database http://www.ehs.washington.edu/epomychem/index.shtm
As a business person you have employees that you must protect, mentor and govern
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5. Identify hazardous procedures and describe employee protective measures
“Chemical” Lab http://www.ehs/washington.edu/manuals/lsm/lsm6.pdf “Physical” Lab http://www.ehs.washington.edu/rbsresplan/ppe.shtm
6. Know your Emergency Procedures/Plans Ask your Department for their Health and Safety Plans and your
building’s Emergency Evacuation and Operations Plan
7. Staff Training- required trainings plus trainings to educate new researchers and staff
Ensure all training is documented, keep training current, train all new staff
http://www.ehs.washington.edu/manuals/lsm/lsm7.pdf
As a business person you have employees that you must protect, mentor and govern
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• Fines/Restrictions
• Health Impacts
• Unable to do research/Nega-tive Publicity
• UW Mission at risk
Operating a Research Lab is like running a business –
What are the risks?
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Examples of costs of not following procedures/protocols/regulations
• Failure of researcher to properly dispose of hazardous waste (>$10,000 fine -2010)
• Violation of air operating permit from EPA resulted in a $350,000 fine (Negotiated to $30,000 fine with program initiation - .5 EH&S FTE)
• Pending appeal of $66,000 fine to UW for explosion and violation of FAA shipping regulations (2010)
Costs for “dumpster
diving” = $800Costs for “dumpster
diving” = $800
Cost of fine >
$10,000 to MetroCost of fine >
$10,000 to Metro
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It depends on you----• Know and follow the policies• Know SOPs • Prepare and practice• Protect self & employees • Perform compliance Checks• Promote worker health and safety and
environmental stewardship
Questions? Contact EH&S at 206.543.7262 or at [email protected]
What YOU can do to ensure accidents, injuries, citations, fines and loss of research doesn’t occur
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OFFICE OF ANIMAL WELFARE (OAW)
Nona Phillips, Director, Office of Animal Welfare
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Office of Animal (OAW) - Mission
The Office of Animal Welfare provides support to the University’s Institutional Animal Care and Use Committee (IACUC) and provides support and advice to researchers utilizing live vertebrate animals for teaching and research.
We review IACUC protocols, grants involving live vertebrate animals, and provide oversight and compliance on behalf of the IACUC in accordance with applicable laws, policies and regulations.
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OAW - RESPONSIBILITIESWhat do we do?• Process and review IACUC protocol
submissions• Review grants and provide IACUC approval
information for sponsors• Provide courses including species-specific
procedure labs• Provide personal one-on-one post-approval
assistance to researchers via our “Post-Approval Monitoring” program
• Coordinate IACUC semi-annual site visits to animal housing and use locations
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OAW - STRUCTUREAdministrative Team: Processes IACUC submissions andinforms PIs of upcoming protocol and training expirations.
Scientific Reviewer Team: Reviews IACUC submissions andgrants involving live animals.
Training Unit: In conjunction with Department of Comparative
Medicine veterinary staff, courses are provided includingspecies-specific labs, surgery, etc.
Site Visit Team: Coordinates all aspects of IACUC semiannual site visits and tracks deficiencies and corrections.
Post-Approval Monitor Team: Each PI is assigned to anindividual who will meet with them to review protocols andplans, and advise/assist them as needed.
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IACUC Protocol Business Process
1. PI submits new IACUC protocols, renewals, and changes to protocols.
2. IACUC members receive items semi-monthly.
3. Members have 1 week to review and submit questions/comments. (Members may request Full Committee Review of any item)
4. IACUC questions/comments forwarded to PI.
5. PI responds back to committee with answers & protocol revisions.
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6. OAW scientific reviewer reviews PI answers/ protocol revision.
7. Reviewer works with PI on any outstanding issues and then either:• approves the protocol or • assigns it for the next monthly
convened meeting if Full Committee Review was/is requested by any IACUC member.
IACUC Protocol Business Process
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Grants & Contracts• Competing proposals– Just-in-Time (after submission to sponsor but
prior to award) – Copy of the proposal + eGC1
• Non-competing proposals– At time of proposal submission– Automatically routes to OAW during SAGE
eApprovals
• IACUC approval info must be included for animal work at other institutions, if applicable.
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Grant/Contract ReviewBusiness Process
1. OAW reviews grant and associated UW protocol(s) to assure concordance and if applicable, assures that approvals from other institutions are documented.
2. OAW provides letter to sponsor re IACUC approval based on sponsor requirements.
3. Other documents provided as required by the sponsor.
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TRAINING OPPORTUNITIES• Courses are offered on-line and in-person
• Courses include:– general laws and regulations– species-specific labs – facility orientations
• Training specific to non-human primates is offered by the Washington National Primate Research Center
• See the Animal Use Training web site for details and registration instructions
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POST APPROVAL MONITORING
• Each research group is assigned a compliance advisor.
• The compliance advisor meets once or twice yearly with the PI (and lab manager and/or others per PI’s preference).
• Visits include review of protocols, operating procedures, and planned changes, and advice regarding IACUC review requirements.
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IACUC SITE VISIT – BUSINESS PROCESS
1. The IACUC conducts semi-annual site visits to animal housing and use rooms during January-April and July-October.
2. OAW requests available times, in advance, from research groups and then schedules a visit accordingly.
3. The PI or facility supervisor receives a written report after the visit.
4. If there are deficiencies a reply with correction plan and completion date(s) is required.
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IACUC POLICIES
Policies reviewed and approved by the
IACUC can be viewed and/ordownloaded.
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HINTS FOR SUCCESS
• Contact OAW whenever you have questions regarding your use of animals, including when you may be unsure of whom to contact.
• We will help you or refer you to the appropriate office or department.
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Consult with OAW when…
• Changing the scope of grants (i.e., adding use of animals when that was not originally planned and approved by the sponsor, or adding a foreign component).
• Contracting with outside institutions/ companies for animal work (e.g., custom antibodies) to assure that an acceptable institution is chosen.
• When consulting with OAW regarding either of the above, please visit our website and e-mail a scientific reviewer.
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OAW RESOURCES
• OAW/IACUC Web Pagehttps://depts.washington.edu/iacuc
• Animal Use Training Web Pagehttp://depts.washington.edu/auts/
index.html
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HUMAN SUBJECTS DIVISION (HSD)
Karen Moe, Asst Vice Provost for Research & Director HSD
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HSD - MISSION
The Human Subjects Division (HSD)is a unit within the Office of Research (OR).
HSD staff support and facilitate the review of human subjects research by the Institutional Review Board (IRB). HSD staff and IRB members partner with researchers to safeguard the rights and welfare of human subjects in UW research.
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HSD - RESPONSIBILITIESWhat do we do?
– Provide oversight, administrative support, and assistance for research subjects and for researchers
– Support the IRBs in their review of research
– Make determinations about whether an activity is human subjects research, or qualifies for exempt status
– Post-approval monitoring
– Assure compliance with federal regulations, state laws, and university policy governing human subjects research
– Develop, deliver, and facilitate access to education and training in the protection of human research subjects
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HSD - STRUCTURE
3 Biomedical IRBs:
3 Social/Behavioral IRBs:
1 Combined IRB:
4 Subcommittees:
(Subcommittees review research that is Exempt or Minimal Risk.)
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REVIEW BY NON-UW IRBs
• Western IRB (WIRB)Reviews industry-sponsored and -initiated clinical trials.
• Cancer Consortium IRB (CC-IRB)Reviews cancer research from consortium members.
• Cooperative Agreements (Affiliated Institutions)Reviews conducted by Seattle Childrens, Group Health, Swedish Hospital, etc. and accepted by the UW IRB.
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IRB BUSINESS PROCESS
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IRB APPROVAL CRITERIA
1. Risks are reasonable relative to benefitsAnticipated benefits include the importance of the knowledge that may be expected to result.
2. Risks to subjects are minimized•Procedures are consistent with sound
research design and do not unnecessarily expose subjects to risk.
• If possible, the research uses procedures already being performed on subjects.
3. Protection of subject privacy & confidentialityThere are adequate provisions to protect the privacy of subjects and to maintain the confidentiality of data.
4. Adequate safety monitoring planThe research plan has adequate provisions for monitoring the data collected, to ensure the safety of subjects.
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IRB APPROVAL CRITERIA5. Written informed consent obtained From each prospective subject or the subject’s legally
authorized representative, unless the IRB, per federal criteria:– Waives the need for written consent.– Waives the need for consent.
6. The consent process provides all required and appropriate information
Unless waived by the IRB per federal regulatory criteria.
7. Subject selection is equitable Taking into account:
– The research purpose and setting, and– Any special issues associated with vulnerable
populations.
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IRB APPROVAL CRITERIA8. Additional safeguards for protected & vulnerable
populations– Additional safeguards are included to protect
subjects who may be vulnerable to undue influence or coercion.
– Includes: children, prisoners, pregnant women, neonates.
– May also include decisionally-impaired, or economically or educationally disadvantaged subjects.
9. Other ethical & compliance issues– Researcher conflict of interest.– Involvement of non-UW institutions and individuals.– Other compliance requirements.
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HINTS FOR SUCCESS
• Allow sufficient time for both preparation of the IRB application and its review.
• Go to the HSD website to download a new application each time (things may have changed).
• Don’t leave anything blank on the application – at least write-in NA, as appropriate.
• Contact HSD with your questions or as issues arise . . . we’re here to help.
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HSD RESOURCES• HSD Website:
• Get Started >> The IRB Process & IRB Guides• Policy & Procedures• Announcements
• eNews from HSD and the IRB (please subscribe)
• Contact HSD:• [email protected] – general inquiries• [email protected] – question or suggestion with a
form• [email protected] – request assistance or a session
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INTERNAL AUDIT DEPARTMENT
Zenaida Shattuck, Associate Director
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• Federal and state auditors
• Private/non-government sponsors
• Local government auditors
• Financial statement auditors
• Internal Audit
WHO AUDITS YOU?
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• Determine the purpose of the call
• Immediately notify your department administrator
• If the auditor asks for information, request for time to consult with staff
WHEN AN AUDITOR CALLS
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You may have a University representative present when meeting with an auditor.
– School/Department Administrator– Internal Audit Liaison
WHEN THE AUDITOR ARRIVES
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–Make sure both you and the auditor understand the audit objective.
–Make sure you understand the question.
–Answer honestly and openly.
WHEN THE AUDITOR ARRIVES
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Limit conversation to internal controls and:
–How you are directly involved with your grant
–How expense benefited the grant
–Do not bring in funding issues or departmental politics
WHEN THE AUDITOR ARRIVES
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• Understand state and federal guidelines
• Know who is tracking your grant activity
• Review and initial paperwork on a regular basis
• Know your department administrator and the Internal Auditor and ask for help
• Remember, you can ask for time to consult with the staff responsible for the work
SUGGESTIONS FOR PIs
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Conflict of Interest (COI)
Jeffrey Cheek, Associate Vice Provost for Research Compliance& Operations, Office of Research
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Conflicts of financial interest occur “whenever financial considerations may have the potential to compromise or have the appearance of compromising an investigator’s professional judgment and independence in the design, conduct, or publication of research.”
- Public Health Service
FEDERAL RESEARCH STANDARD
Potential conflicts of interest occur in all human processes and are not inherently “bad” if they are appropriately managed.
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• Money – cash, salary, fees, royalties, honoraria; any monetary right or obligation (both creditors and debtors have monetary interests), liabilities
• Property – any physical asset with monetary value or burden; intellectual and intangible property
• Equity/ownership – stock, partnership, etc.
• Imputed interests – spouse, family, partnership, joint ventures, other legal relationships
Bottom Line: Anything with economic value
COMMON FINANCIAL INTERESTS
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•Applies to all research (sponsored and unsponsored) and tech transfer license transactions
•Addresses conflicts and appearances of conflicts
•Goal is to prevent - • Bias in research• Harm to human subjects• Misuse of UW and state resources• Violations of state ethics act
UW SIGNIFICANT FINANCIAL INTEREST DISCLOSURE POLICY (GIM
10)
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GIM 10
Purpose:• Ensure no research or tech transfer
activities at UW are adversely affected by outside financial interests of persons involved in those activities
• GIM 10 Policy complies with PHS and NSF requirements for policy pertaining to financial conflicts of interest of research investigators
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GIM 10
Disclosure:• Prior to participating in research or tech
transfer activity, anyone having a significant financial interest related to the activity must disclose details
• Can occur: when research proposal submitted to OSP; when application submitted to HSD; when SFI arises during the course of research; or prior to concluding technology licensing transaction
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• Outside salary, honoraria, consulting fees
• Compensation for speaking engagements
• Stock, stock options, other ownership interests
• Intellectual property rights (patents, licenses)
• Invention royalties (UW distributed royalties and equity not considered SFI for license transactions)
• Imputed interests (spouse, etc.)
TYPICAL SIGNIFICANT FINANCIAL INTERESTS
(SFI)
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1. For a Clinical Trial, any Financial Interest.
2. For Human Subjects Research other than a Clinical Trial (i) any Financial Interest exceeding $5,000 in value, (ii) any Equity Interest; or (iii) any Intellectual Property Interest.
3. For all Research other than Human Subjects Research and all Technology Transfer Transactions, (i) any Financial Interest (including a Compensation Interest, an Equity Interest and an Intellectual Property Interest) exceeding $10,000 in value, or (ii) any Equity Interest representing more than a 5% ownership in any single entity. (PHS/NSF definitions)
NOTE: PHS/NIH currently revising guidelines (and perhaps definitions of SFI); new
regulations and/or guidance anticipated by Fall of 2011.
UW DEFINITION OF “Significant Financial
Interest”
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UNIVERSITY OUTSIDE PROFESSIONAL WORK
POLICY• Pre-approval required (chair, dean, Office of the Provost)
• Subject to pre-approval, faculty may engage in outside work for compensation
• Policy (and accompanying form) requires disclosure of days and nature of work, not compensation (not true for SOM faculty)
www.washington.edu/admin/acadpers/forms/approval_compensation.pdf
• Approval for up to 13 days per quarter
• Annual report listing all outside professional activities, whether or not compensated, must be filed
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•UW policy supports approved outside work
•Advance approval required
•Form not required for some non-profit work
•Requests involving potential conflicts of interest are scrutinized
•SoM Supplement form required
•De minimis use of UW resources permitted
OUTSIDE WORK SUMMARY
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• Alternate compliance system for “University Research Employees” at state universities (research faculty/employees engaged in research/tech transfer – not other employees)
• Universities allowed to adopt administrative processes, with the approval of the Governor, that apply in place of obligations otherwise imposed by Ethics Act
• Ethics board retains authority to enforce violations of alternative compliance system
• Liberalization of permitted de minimis uses
• See our FAQs on Office of Research website
2005 STATE ETHICS ACT CHANGES- Effect -
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1. Faculty who own 50% or more of a company may be required to take a whole or partial leave to do work for it.
2. Faculty member cannot be an investigator in a clinical trial involving faculty member’s invention or product.
3. The UW will not conduct a clinical trial of a UW invention or for a company in which it has a substantial equity position.
4. Except for allowed de minimis uses, UW resources and facilities can only be used to support a company through established processes (sponsored research, contracts, etc).
5. UW intellectual property cannot be transferred through consulting or other “backdoor” methods.
LIMITATIONS TO KEEP IN MIND
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Wrap-Up
Lynne Chronister, Assistant Vice Provost for Research & Director OSP
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UNIVERSITY OF WASHINGTON
• Leaders in research and education
• Positively impacting our community, nation and the world
• It Takes a Village:–We are all partners in this successful
research enterprise
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TODAY’S WORKSHOP
• Introduction to the central research support offices
• Learn how to navigate the UW Processes
• Maneuver through the multiple regulatory and compliance considerations within the grant lifecycle
• Manage the pre and post award process at UW
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WE ARE HERE TO HELP
• Offices presenting today are part of the central oversight and support for your research enterprise.
• We will work with you to ensure your projects meet sponsor requirements, state & federal law, and UW policy.
• Contact us with your questions.
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RESOURCES AVAILABLE
• A resource table is set up at the back of the room. Please stop by and collect materials you feel can assist you in creating successful research projects.
• This PowerPoint deck will be posted on the OSP website tomorrow.
• Evaluation form – please tell us how we did!
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THANK YOU