Research
Compliance Runs from Application to Closeout
Department
administrators are at the front lines of research administration
and are the focus for communication between research and the central
administration. Central administration implements regulatory requirements,
but it is often the department administrator who must translate
and impose those requirements on faculty. That's how research compliance
gets done.
Where
does research compliance begin? Where does it end?
Some
institutions may have an office for pre-award research administration,
and another for post-award. Some would say there is a fine line
between the two. Whether an institution has separate offices for
pre-and post-award research administration and compliance, all involved
need to recognize one thing: For sponsored research programs to
work smoothly, a familiarity with the whole process-from proposal
preparation to close-out—is needed.
“We're
all engaged in this, it's a partnership,” said Patrick Fitzgerald,
director of the Office of Sponsored Programs at Massachusetts Institute
of Technology. “A research award itself is a cycle. There's a federal
agency solicitation, [then] a faculty member applies for a funding
opportunity, which originates in our office. We compose research
proposal.”
The
research process then is part scientific work (research) and part
paperwork (administration); compliance is the thread that runs through
the whole from beginning to end.
“There's
a collaboration between faculty member and department administrator,”
Fitzgerald said. He emphasized that “these awards are between the
PI [principal investigator] and the agency. These applications flow
through our office because we have been given the authority to represent
the institution.”
Compliance
is a Function of Knowledge
Fitzgerald
mentioned a young faculty member who applied for a government grant.
When the government agency informed Fitzgerald and his office that
MIT had been awarded the grant, the application itself was news
to them; they knew nothing about it. Had the government agency caught
the applicant's mistake- that this particular grants had not come
from MIT's sponsored programs office-it would have been easy to
deny the application. However, Fitzgerald worked with the PI and
the agency to move the grant under his office.
Fitzgerald
said that in the faculty member's defense, there was mention in
the solicitation about consulting, which led him to apply on his
own. “At MIT, we allow our faculty consulting privileges one day
a week.”
Fitzgerald
explained that at any step in the research process or cycle, “various
individuals are involved at various times. If someone makes a commitment
that is going to be problematic, we want to catch it on the front
end. And if there is any lack of understanding…well, that's why
we hire auditors.”
Faculty
members are experts at teaching and research, Fitzgerald said, while
the administrator should handle the application process. Compliance,
on the other hand, involves both sides.
“Research
compliance is a function of knowledge, and knowledge comes from
experience,” Fitzgerald said. “For the most part, people want to
do the right thing, but there are complexities in there.”
When
asked about scientific integrity and the recent stem-cell scandals,
Fitzgerald came down hard.
“Of
all the noncompliance issues, [fraud] is the most egregious form.
Falsification of information results gets to the heart of our mission,”
Fitzgerald
said. “It's hard to parse out when teaching stops and research begins.
…[T]here
could be some sloppiness. It's inevitable there will be some mistakes,
but fraud is intentional [and premeditated].”
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