Each compliance area committee, board, or office is responsible to develop, implement, distribute, and update its policies and procedures related to research, grants, and other sponsored programs.

	Work with University oversight committees, boards, and offices responsible for specific elements of compliance to ensure compliance with all regulatory requirements.
	Identify and assist in the development and implementation of such additional policies and procedures as are needed to address specific management and administrative processes required for compliance.
	Ensure that appropriate training programs are developed and delivered.
	Implement a process necessary to monitor compliance program elements.
	Ensure that policies and procedures related to research compliance are established, implemented, distributed, reviewed, and dated.
	Review and ensure disposition of matters of alleged noncompliance in consultation with the Director of Research, the Faculty Research Committee and the General Counsel. TO TOP

Office of Research Services will

	Implement and interpret sponsor and University policies and procedures for compliance with applicable regulations.
	Train research personnel in preparation of grant/contract application and managing sponsored research.
	Propose policies and procedures to senior administration in compliance with grants and contracts management regulations.
	Coordinate with other University research and sponsored programs oversight committees, boards, and offices to ensure that specific proposals and projects have been reviewed and approved for compliance.
	Advise Institutional Review Board for the Protection of Human Subjects (IRB), Institutional Animal Care and Use Committee (IACUC), Institutional Biosafety Committee (IBC), and Faculty Research Committee on compliance issues.
	Provide administrative support to IRB, IACUC, IBC, and Faculty Research Committee.
	Conduct pre-submission compliance review of proposals for external funding, except those submitted by the Director of Corporate and Foundation Relations. TO TOP

The Grant Accountant will

	Make Project Directors/Investigators, and others involved in a project, aware of financial commitment and reporting requirements.
	Communicate the University’s Policies and Procedures requirements of grant accounting.
	Complete OMB A-133 audit required schedules in a complete and timely manner.
	Notify the Office of Internal Audit regarding any unusual circumstances/events. TO TOP

All grants, research, and sponsored program activities at the University will be conducted in accordance with the highest professional and ethical standards.

Policies, procedures, and records assuring compliance with all laws, governmental regulations, and the University policies and procedures will be maintained on all compliance related areas, including but not limited to

Assure compliance with all laws, governmental regulations and University of Scranton policies and procedures governing research and sponsored programs.

Research Activities

	Human Subjects Protection
	Animal Welfare
	Hazardous Agents
	Environmental Health and Safety
	Radiation Safety

Research Integrity – Responsible Conduct of Research

	Authorship
	Copyright
	Plagiarism
	Patent
	Data Management
	Research Misconduct
	Peer Review

Fiscal Stewardship

	Research and Sponsored program funds management and accounting
	Conflict of Interest
	Tax Issues

Human Resources and Public Safety

	Equal Opportunity Employment
	Diversity Statement
	Non-smoking
	Alcohol and Chemical Substance Abuse Policy
	Sexual Harassment Policy
	Policy on Violence in the Workplace

Other

	Records Retention
	Academic Code of Honesty
	Code of Responsible Computing TO TOP

EDUCATION AND TRAINING

The goal of the Education and Training Program is to build compliance consciousness into the daily actions of employees, students, and other persons affiliated with the University and its activities, assuring that they are aware of their duties and responsibilities.

All current employees of the University will be given a copy of the GRASP Compliance Plan and offered opportunities for orientation sessions. The GRASP Compliance Plan will also be referenced in the Student Handbook. The Plan will be included in orientation for new employees.

Areas requiring implementation of specific education and training programs include, but are not limited to

	Allowable Costs
	Animal Subjects Research
	Biohazard Safety
	Chemical Safety
	Compliance with OMB Circulars and Grant Contract Provisions
	Educating for Conflict of Interest
	Educating for Responsible Conduct of Research
	Effort Reporting
	Grant and Sponsored Program Financial Accountability
	Human Subjects Research
	Occupational Health and Safety
	Radiation Safety

The Compliance Officer, with assistance from University committees, boards and offices, will identify areas requiring or needing education and training to ensure compliance and will make certain that appropriate education and training programs are available for University faculty, administrators, staff, and representatives.

University policy under the GRASP Program requires that principal investigators (PI’s) and project directors (PD’s) receive mandatory grant/contract administration training provided by the University at the time a PI or a PD is hired or at the time an existing University employee assumes the position of a PI or PD. Subsequent training is required for each new award.

A website will provide links to all compliance areas and their relevant regulations, policies, procedures, and guidelines.
TO TOP

University personnel are expected to report any known or suspected noncompliant conduct related to grants, research, or sponsored programs. No person will be retaliated against by the University or any of its employees or agents for making a good faith report of suspected noncompliant conduct in research, grants, or other sponsored program activities.

A number of resources (Appendix I) are available to assist employees who have questions, concerns, or would like to report or concerns about compliance issues or possible non-compliant conduct.  Employees may report any noncompliance, including suspected fraud, anonymously to the Internal Auditor through the University’s Fraud and Waste Hotline at the following link http://matrix.scranton.edu/resources/re_auditor.shtml. Employees may also report any noncompliance to the Compliance Officer.

Reports of research noncompliance as defined in the University Policy on Research Misconduct must be reported to the Director of Research. Research misconduct includes fabrication, falsification, plagiarism; misappropriation of others’ ideas; failure to meet University and/or federal policies regarding use of human or animal subjects in research; failure to meet legal requirements governing research; or retaliation of any kind against a person who has reported or provided information about suspected or alleged misconduct and who has not acted in bad faith. Reports of research misconduct will be investigated and written notice of the final decision will be made to the Compliance Officer.

Correcting Noncompliance

Anyone who fails or refuses to comply with the Plan shall be subject to appropriate corrective action. Corrective action will consist of the immediate (1) termination of the noncompliant activity and (2) notification of appropriate University officials. The University will (1) make or seek any restitution necessary because of the noncompliance and (2) take any remedial steps to ensure future compliance.

Action by the University related to noncompliant conduct may include:

	Providing additional education and training programs,
	Modifying policies and procedures,
	Increasing monitoring activity, and/or
	Taking any other action necessary to comply with appropriate laws.