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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

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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? (CLASP)

  • 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

University of MichiganChief Urologist charged with Conflict of Interest$100,000 penalty1 year probation

University of MinnesotaMisuse federal grants32 mil

Thomas Jefferson UniversityMedicare over-billing$12 mil

Miscellaneous Scientific MisconductJohns HopkinsHarvard (2)Yale

New York University Medical CenterInflated research grant costs$15.5 mil

Public DemandforImproved Control

Stanford UniversityInflated research overhead costs$1.2 mil

Yale UniversityMedical over-billing$5.6 mil

University of TexasUnderpayment of royalties whistle blower$12 mil

University of ChicagoResearch fraud and abuse$650,000

Duke UniversitySexual harassment $0.5 mil


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ISSUES & PERSPECTIVES REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

GOVERNMENT ENFORCEMENTPERSPECTIVE

UNIVERSITY PERSPECTIVE

INSTITUTION

ISSUES

OUTCOME

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

  • 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

MINNESOTA


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INSTITUTION REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

ISSUES

Wisconsin Madison

Overstating # of Sponsors on Grant Application

ISSUES & PERSPECTIVES

GOVERNMENT ENFORCEMENTPERSPECTIVE

UNIVERSITY PERSPECTIVE

OUTCOME

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 REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

  • 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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Confusion REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

Uncertainty

Mistakes


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One Solution …. REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

CLASP Program

Continuous Learning for Administrators of Sponsored Programs


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What is one solution? REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSCLASP

  • 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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CLASP REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSWhat 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 REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSWhat 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 REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSWhat 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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CLASP REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSWho 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 REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSHow will it be administered?

Initially through ORPA

  • Database of administrators

  • Listing of training sessions, dates, locations

  • On-line registration

  • Tracking of individual progress


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CLASP REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONSHow 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! REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

Certain peer institutions have developed, or are developing, similar educational programs.


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CLASP REPUTATIONAL DAMAGE TO SOME OF THE WORLD’S MOST RESPECTED INSTITUTIONS

Continuous Learning for Administrators of Sponsored Programs


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