Policies, Process and the PUI

Julie Cole, Director of Compliance, Duke UniversityPeggy Lowry, OSP Director (Retired)

Oregon State University Pam Whitlock, OSP Director (Emeritus)

UNC-Wilmington

Thoughts to PonderSetting the Stage: The Empty Room

Risk Analysis: Tone at the Top for Accepting Institutional Risk

Categories of Polices and Procedures : What do You Need

Roles and Responsibilities (and Why This is Important)Communication and Commitment : Who are the

Stakeholders?

The Empty Room….You are a newly hired director of sponsored programs at a regional university that has aspirations to expand a relatively small funded portfolio and to successfully compete for students, talented faculty and increased national regard for its teaching and student research programs. When you arrive, you discover that grant management policies and procedures are either very dated or don’t exist. Your only resource: a faculty handbook and a state policies and procedures that are not specific to federal funding.

Welcome to the Empty Room.

Tone at the Top

• Preparing to Fill the Empty Room: Understand Your Institution’s Culture and Perspective– Does the institution have an expectation for

extramural funding to support scholarship/research?– Does culture support expectation?– Does the institution understand commitments that

come with sponsored programs?– What is the institution’s risk tolerance level?

• Risk tolerance in research activities• Risk tolerance in budget management

Tone at the Top

Institutions ToleranceFor Risk

Most Typically Cost Based

Most Typically Defined by Finance

Compliance

Institution Policies

Inte

rnal

Con

trols

Insti

tutio

nal P

ostu

re

Risks Acceptable in Research Activities

Defined Methodology; Flexibility as Needed

Academically Defined: Sponsor/PI Engaged in Research Adjustments

Research

Research MethodologySponsor Expectations

Nature of Research

Tone at the Top

• Does culture promote sponsored programs?

• Understanding of Risk? Policies? Regulations?

• Who determines?

• What level?

• Expectation for research/ scholarship?

Institution’s Expectations

Risk Tolerance

CultureUnderstanding of Sponsored

Program Commitments?

Policy

Tone at the Top

What Do You Need?

• Circulars• Account Setup and Management• Purchasing• Allocability, Allowability, Reasonableness• Closeout

Financial

• Human Subjects• Animal Use and Care• Biosafety

Research Protections

• Proposal Submission• Internal Review• Eligibility to Submit

Process

General• Certs and Reps• Conflict of Interest• Institutional Authority

What Do You Need?

• Core Questions:– Subject to A-21 and A-110, plus certain FAR clauses?– State or private governance?– Subject to A-133?

– Financial management systems allow for segregation of funds?– System of internal controls?– Allowability, allocability and reasonableness guidance and

process?– Reconciliation process?

– Human Subjects, including student research?– Animal Use, including demonstration, housing, unique centers?– Biosafety or hazardous materials?– International Travel and Collaborations?

– Who may submit and internal review process?– Cost sharing?– Who can accept an award?– Who can sign for the institution?

– Certifications and Representations

What Do You Need?

What Do You Need?

• Elements:– Steps to be taken– Related forms and procedures– Navigation Tools– Quick reference to contact list– Roles and responsibilities

Handouts

What Do You Need?

Roles and Responsibilities

Why Defined Roles and Responsibilities

• Ensure necessary tasks are being performed• Accountability to sponsors• Professional development• Smoother processes• Communication• Improved collaboration and work environment

R&R’s

Types of Responsibilities

• Initiate• Plan• Implement• Monitor• Controlling• Closure

R&R’s

Defining Roles• Define parameters of each process• Detail all tasks required for successful

execution of process• Review workflow process• Assign tasks/processes• TEST to ensure workable

R&R’s

Issues with Unclear Roles and Responsibilities

• A critical task is not performed• Lack of ownership• Finger pointing• Blame• Mistaken expectations• Unhappy surprises

R&R’s

Communication

• Communication: Understand their primary focus– Credibility– Needs, wants

and wishes constitutes motivation

Faculty Office StaffProvost-

President- Deans

Finance-Controller

Advancement

Communication

• Faculty – Students– Teaching– Publishing

Faculty

• Staff

Office Staff

managing risk providing service to faculty keeping knowledgeable about sponsors improving skills implementing best practices enhancing communications between research administrators providing transparency enhancing connectivity between functions updating policy overseeing a financial compliance program informing leadership refining business process improvements retaining your sanity Communication

Finance-Controlle

r

• Provost – Academics– Community– Students– Retention– More…….

• Finance– Risk– Budget– Audits

Provost-President- Deans

Hiring

Trustees

Grants

P&TStudents

Buildings

Accreditation

UnionGov Rel

Retention

Communication

Advancement

• Advancement– Donors– Gift Totals– Foundation relations– Capital campaigns

Communication

• Knowing the stakeholder needs/ expectations, helps answer– priorities of the stakeholders? – existing knowledge?– level of language to use?

– communication method? – tone and style? – who else to involve?– “competition?”

Peggy S. LowryCommunication

• Communication

MESSAGE

Communication

• Frame Message– Relate content to • What you know about the stakeholder• What you know about the stakeholder needs

– Build a base of content that can be mixed and matched for future communications

Peggy S. LowryCommunication

Step 5: Assess policy implementation/understanding

Step 4: Distribute policy via multiple mechanisms; provide opportunities for discussion/questions

Step 3: Craft the message(s)

Step 2: Obtain stakeholder feedback on implementation, impediments, grandfathering

Step 1: Define order of discussions; discuss policy need with key stakeholders; listen carefully to their concerns/thoughts

Five Key Steps for Policy Communication

Communication

Policy and Procedure Resources• NCURA Regulation and Compliance

https://www.ncura.edu/online/cgi-bin/msascartlist.dll/ProductList?ONWEBFLG=y&SORT=UDEF1QTY

• Tufts University Policy Model• Policies: You Gotta Have Them, Federal Grant News, April 2011 (1st article)• 13 Common Mistakes about Communicating Policies and Procedures Informationwww.urgoconsulting.com• University of Santa Cruz: Guide to Writing Policy and Procedure Documents

http://policy.ucsc.edu/pdf/guide.pdf• Murray State Policies and Procedures Guidehttp://www.murraystate.edu/SponsoredPrograms.aspx

Concluding Thoughts