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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?
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
Public Demandfor
Improved Control
Thomas Jefferson UniversityMedicare over-billing
$12 mil
University of MinnesotaMisuse federal grants
32 mil
New York University Medical CenterInflated research grant costs
$15.5 mil
Stanford UniversityInflated research overhead costs
$1.2 mil
University of TexasUnderpayment of royalties
whistle blower$12 mil
Duke UniversitySexual harassment
$0.5 mil
University of ChicagoResearch fraud and abuse
$650,000
Yale UniversityMedical over-billing
$5.6 mil
Miscellaneous Scientific MisconductJohns Hopkins
Harvard (2)Yale
University of MichiganChief Urologist charged with
Conflict of Interest$100,000 penalty1 year probation
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ISSUES & PERSPECTIVES
ISSUES GOVERNMENT ENFORCEMENTPERSPECTIVE
UNIVERSITY PERSPECTIVE
OUTCOMEINSTITUTION
MINNESOTA •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
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
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ISSUES & PERSPECTIVES
GOVERNMENT ENFORCEMENTPERSPECTIVE
UNIVERSITY PERSPECTIVE
OUTCOMEINSTITUTION
Wisconsin Madison
ISSUES
Overstating # of Sponsors on Grant Application
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
Benign neglectOutdated and/or ineffective standards, policies,
proceduresLittle or no faculty and staff trainingLittle or no assignment of roles and
responsibilities
Resulting in….
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oConfusion
oUncertainty
oMistakes
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One Solution ….
CLASP Program
Continuous Learning for Administrators of Sponsored
Programs
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What is one solution?CLASP
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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CLASPWhat 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 What 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 What 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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CLASPWho 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 How will it be administered?
Initially through ORPA
Database of administratorsListing of training sessions, dates, locationsOn-line registrationTracking of individual progress
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CLASP How 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!
Certain peer institutions have developed, or are developing, similar educational
programs.
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CLASP
Continuous Learning for Administrators of Sponsored
Programs