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Evaluation of Research and Compliance Plans

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  1. Evaluation of ResearchandCompliance Plans Christine C. Boesz, Dr.P.H. Inspector General National Science Foundation, USA INORMS Brisbane, Australia August 24, 2006

  2. Accountability: Who Cares????? • Taxpayers • Appropriators $$$$ (e.g., US Congress) • Funding Agencies • Scientific Community • Partners • Society

  3. Perspective As a stakeholder where do you sit? • Different levels of interest • Different understandings of science • Different views on cost-benefits • Different responsibilities in management • Different responsibilities in research • Different self-interests

  4. One Question • Accountability: How well does the research community comply with “funding requirements”? • Is the $ expended correctly? • Are necessary precautions, permits and other issues handled correctly?

  5. Two Frameworks to Consider in Addressing the Question • Compliance Plans • Why are they important? • How are they used? • What are they? • Research Evaluations • Research Institutions • Research Findings • Research Investments • Research Requirements • Researchers


  6. Compliance Plan AdvantagesWhy Important? • Avoids improper expenditures and improves grant administration • Signals importance of compliance to faculty and staff • Avoids filing of legal actions • May be considered as a mitigating circumstance when wrong-doing is discovered

  7. How are Compliance Plans Used? • Support research enterprise • Demonstrate commitment to do the right thing • Communicate facts and expectations • Educate and train • Systematic monitoring (technical assistance) • Early detection of problems and prevention of regulatory action/penalty

  8. What is a Compliance Plan? • An effective compliance program has 8 elements: • 1. Written policies and procedures • 2. Designation of compliance officer and compliance committee • 3.Education and training • 4. Hotline or other reporting mechanism • 5.Internal monitoring and audits

  9. Eight elements (continued) • 6.Enforcing standards • 7. Responding promptly to detected violations • 8. Defining roles and responsibilities and assigning oversight responsibility • Reference OIG compliance materials at http://oig.hhs.gov/fraud/complianceguidance.html

  10. Compliance Programs on the Rise • In the United States, a steady increase in the number of private companies with compliance programs (Sarbanes-Oxley) • Also, increase in the number of compliance programs at colleges and universities

  11. Evaluation of Research • Qualitative • Quantitative • Multi-dimensional • Measurement focus : • Inputs • Outputs

  12. Financial CompliancePossible Areas to Measure • Cost Sharing • Conflicts of Interests • Time & Effort • Improper Expenditures • Sub-Recipient Monitoring

  13. Research CompliancePossible Areas to Measure • Human Subjects • Animal Welfare • Radiation Safety • Biosafety • Collection Permits • Environmental Permits • PI Change/Absence • Progress/Final Reports • Export Controls

  14. Steps in Evaluating • Do a risk assessment • Focus on high risk areas • Compliance failure impedes research • Compliance failure results in penalty • Determine compliance measurement • Valid measures • Reliable measures • Establish baseline • Gather data • Track and Analyze Trends • Gather data over time

  15. Concluding Comments:Evaluation & Compliance • Compliance Measurements assess how well research practices comply, how compliance requirements are managed, how well institutions support the research enterprise, how well the structure of research is handled • Compliance plans give structure to compliance efforts over time • Structure is important to the research enterprise

  16. Challenge • Operationalize a compliance plan • Establish measurements • Collect data • Analyze results as contributions to the research enterprise • Result: Evaluating research accountability