instances, exceptions for the individuals listed above may be granted. This exception request must stated in the
notes section of the PRF and approved by the Department Head, Dean, and Vice
President for Research
Research Services (SRS). SRS reports
to the Office of the Vice President for Research. SRS is responsible for the pre-award and post
award non-financial administration and coordinating compliance issues that
arise in connection with Externally Sponsored Projects. In addition, within SRS are Senior Research Administrators (SRA),
who are assigned to each Operational Unit and responsible for assisting PIs with
the pre-award process. See http://www.rit.edu/research/srs/about/
for a detailed account of the support SRS
Program Accounting (SPA). SPA is a
department within the Controller’s Office hierarchically reporting through the
Sr. Vice President for Finance and Administration. SPA is responsible for the fiscal administration of Externally Sponsored Projects.
SPA assists primarily with post award financial compliance duties, which
include financial reporting, invoicing, effort reporting, cash management
requirements, and financial audit coordination of sponsored projects. See http://finweb.rit.edu/controller/sponsored/
for a detailed account of the support SPA
Advisory Group. This informal group consists
of faculty representatives from across the Colleges, directed by the RIT Vice
President for Research, which provides feedback and comment on the strategic
vision and implementation challenges of RIT’s research goals as requested.
Committee For Externally Sponsored Projects (OCESP). The OCESP is created by RIT
Policy C1.0 for the limited purpose of implementing and administering the Oversight
Policy for Externally Sponsored Projects and balancing RIT’s commitment to
openness in scholarship with competing requirements of the sponsors of
externally funded projects at RIT. Pursuant to RIT
Policy C1.0 the OCESP is responsible for conducting review of certain externally
funded research projects (as set forth in Section
3.5.2) prior to their execution when there are particular limits on open
President for Research (VPR). The Office of the Vice President for Research
is responsible for sponsored research and research administration across the
university. The VPR collaborates with
all deans and research center directors and works closely with other university
administrators to develop and carry out RIT’s strategic research agenda in
compliance with applicable laws and regulations. The Vice President for Research oversees and
approves changes to this policy for pre-award and post award non-financial
President for Finance and Administration The Finance and Administration
(F&A) division is organized and operated to provide service to the
university in the stewardship of its human, physical, financial, and
informational resources. The Sr. Vice President for Finance and Administration
oversees this policy and approves substantive changes for post award financial
pre-award processes are the steps necessary for the acquisition of a grant or
contract by a PI. The process includes the actions leading up to the notice of
award or announcement of funding.
of technical proposal and budget.
The PI shall consult with his or her designated SRA, as needed, in order
to prepare the technical proposal, an appropriate budget for the research
project that takes into account the administrative and substantive needs of the
project, and the PRF. The budget
creation for the proposal should be performed simultaneously with PI’s completion
of the PRF. During this pre-award process
it should be determined whether any prior approvals (as set forth in Section 3.4.3) must be obtained before submission
of the PRF and proposal application to SRS, or receipt of the notice of funding,
or award or execution of the agreement itself.
SRS must approve the final budget prior to submission of the proposal to
a sponsor. For details regarding preparation of the budget see http://finweb.rit.edu/controller/accounting/docs/manual/04.pdf.
of the PRF. A fully completed and approved
PRF (by all applicable signatories) is required before RIT can commit any
resources noted in the PI’s proposal, and before any proposal can be sent to an
external sponsor. The PI is responsible
for completing and routing a PRF. The completed PRF will contain the specific
approvals of the PI and his/her operational units, Department Head, Dean, SRS,
and ultimately the Vice President for Research.
Any required signatory on the PRF may seek additional information on the
project prior to granting their approval. Any changes of 10% or more of the total budget
amount during (a) the proposal process, or (b) the award process will require
the re-routing and re-approval of the revised PRF to ensure that proper RIT supervisors
of the PI, and the research, approve the revised commitment of RIT resources to
the proposal before (a) the proposal is sent to a sponsor, or (b) the contract
or grant agreement is executed.
required for specific proposal characteristics. Prior to submission of the proposal, if
the following specific features are a part of the proposal, then additional
approvals are required as set forth below and in the PRF. The approval is a representation that the
proposal is in full compliance with RIT's policies and necessary to meet
22.214.171.124 Cost Sharing. Cost
sharing should not be included in a research proposal unless required by the
external sponsor. If any cost sharing is
involved in a proposal, approval from the VPR, Dean and/or Department Head
affected shall be obtained on the cost
sharing approval form, which is part of the PRF. The PI will be responsible for initiating and seeking
Department and Dean approval for cost sharing.
The VPR may consult SPA and approval will be consistent with OMB
of RIT’s approved Facilities and Administrative (F&A) rate. A reduction in RIT’s approved F&A
rate cannot be included in a proposal unless it is a statutory, program, or
policy requirement of the sponsor. If such
a requirement exists, it must be documented and accompany the PRF submitted to
SRS. The VPR may consult SPA in
reviewing these issues, and any approval of a reduction in F&A shall be
consistent with OMB Circular A-110 section (c)23.
126.96.36.199 Tuition Remission. If student tuition remission
will be used to meet a cost share commitment, the department responsible for providing
funding must provide approval on the cost sharing approval form, which is part
of the PRF.
188.8.131.52 Sharing of Returned F&A across Colleges
or Operational Units. If Colleges or
Operational Units have agreed to share or divide returned project F&A (see section 3.7.4), then that sharing
agreement shall be documented in the PRF.
3.4.4 Signatory Approvals for Proposals and PRF.
If a proposal will be funded with federal, state, or local government funds,
then in addition to applicable Department, Dean, and operational unit, SRS
approval and VPR approval is also required for the PRF and proposal prior to
submission to the sponsor no matter the dollar amount. (a) If the project is under $5,000 and not
federal, state, or local government sponsored, no SRS or VPR approval is
required prior to submission of the proposal.
(b) If the project budget is
greater than $5,000 and less $50,001, does not involve federal, state, or local
government monies, then the research project requires SRS approval of the PRF, and
the proposal may be submitted to the sponsor after approval of the Director of
Sponsored Research Services. (c)
However, the Director of CIMS may approve non-government proposals of $50,000
or less by CIMS staff, provided the PRF for the project is approved by SRS. (d)
All projects over $50,000 require proposal and PRF approval of SRS and
Compliance Issues SRS shall work with the PI to become
aware of any compliance issues that arise at the pre-award stage. The PI shall be responsible to designate any
relevant project compliance issues on the PRF, and SRS shall assist the PI in
coordinating with the applicable RIT office to plan for project compliance in
these areas (e.g., use of human subjects, use of animals, hazardous materials,
etc.). See also section 3.9. In addition, SRS shall review the proposals
for compliance with the Procurement Integrity Act, and will work with SPA to
coordinate compliance with any additional sponsor legal and regulatory
requirements, and RIT procedures as necessary.
3.4.6 Submission of Proposal to Sponsor. Each PI is responsible for preparing a
complete proposal and PRF in time for PRF approval, and submission of the
proposal to the sponsor. The PI shall work
with the SRA and SRS representatives to submit proposals in accordance with
sponsor instructions and requirements. All proposals submitted through SRS are logged
in an SRS database.
Award Process. These are the steps followed after a
communication from a sponsor that an award will be made.
of Agreement. SRS representatives negotiate the contract terms with the
sponsor, not the PI. If there are non-standard terms of the contract, SRS
confers as applicable with Academic Units and the PI, Development, Risk
Management, SPA, the Office of Legal Affairs,
the Intellectual Property Management Office (IPMO), and/or any other
relevant Operational Unit of the RIT.
Required by the OCESP. If SRS
identifies research agreement terms that (i) request a limited level of
disclosure of RIT
Policy C1.0 required project Pertinent Details; (ii) if the project
includes a publication review delay beyond
the accepted 90-day period, or a publication approval; or (iii) if the project
creates or makes use of Classified Information; then SRS will work with the PI
to prepare a prior review request and present it to OCESP for approval pursuant
Policy C1.0 and OCESP procedures (http://www.rit.edu/research/srs/compliance/roc/oversight_policy_procedures.htm
Interest Review. As part of the
Project Initiation Meeting (see 3.6.1) SRS shall direct each PI to update their
disclosure, if necessary, to remain in compliance with the RIT Policy
C4.0 (Individual Conflict of Interest and Commitment Policy) as a condition
of accepting the terms of the award. If
any conflict of interest concerns are raised by the PI, any supervisor or
administrator of the RIT Conflict of Interest Policy, or any other source, SRS
shall coordinate with the Office of Legal Affairs (or any Administrator of RIT’s
Individual Conflict of Interest and Commitment Policy) for an expanded conflict
of interest review prior to RIT’s commencement of the research project.
Control Review. The PI shall consult
with SRS and the Office of Legal Affairs to complete all required documentation,
export review checklists, and comply with the RIT Export Control Compliance
Program, and assist in the review of the proposal's implications for export
controls (e.g., foreign nationals involved in the Project) in accordance with the
RIT Export Control Compliance Program. See http://finweb.rit.edu/legalaffairs/docs/export_compliance_program.pdf.
Processing of Award. SRS is responsible for obtaining final approval and
authorization on project agreements from the applicable signatory consistent
with RIT’s Signature Authority Policy. Upon complete acceptance of an award, SRS
shall update the proposal record in its electronic database as funded, and then
send an account request to SPA if a project is sponsored by a federal, state or
local government entity, or the project is valued at $5,000 or more, in
preparation for the Project Initiation Meeting (PIM) (discussed in Section 3.6.1). However, separate project accounts are not
required for Enterprise Activity that is non-government funded and $5,000 or
more. The PI will receive notification
the account request has occurred. At
this time, the PI will automatically receive electronic notification of their
obligations under RIT Policy C1.0 and the NOA process discussed in 3.6.2.
Financial Account Established. SPA
sets up a new sponsored project account in the Oracle general ledger to record
the financial transactions for the award. SPA will review the account request
from SRS, may seek further information from the PI or SRS, prior to setting up
a new project number in the Oracle general ledger. Upon completion of project set-up, SPA will send
to the PI a letter with the established account information.
Post-Award Process. RIT's post award process sets forth the
steps to follow after the execution of the final agreement and during the
administration of the award. During this
time, the PI will commence the substantive research required by the Project as specified
in the award agreement. In addition, the
PI shall work with SPA to facilitate the appropriate and compliant
administration of the agreement in accordance with sponsor and RIT’s policies
Initiation Meeting (PIM). After an
award notice is received by RIT and the financial account is established for
the sponsored project, SRS is responsible for holding a PIM with the PI, his/her
project administrator, SPA representative and others as appropriate. The
purpose of the PIM is to review the award terms and conditions as well as the
legal, regulatory, sponsor, financial and compliance requirements associated
with the administration of the award.
Specific topics discussed during the PIM include reporting requirements,
sponsor terms and conditions, utilization of personnel, RIT procedures on use
of project accounts, budget and cost share, project compliance issues, and the
Notice of Award (NOA) process. At the
conclusion of the meeting, the PI signs
the Terms and Conditions document to confirm in writing that he/she had an
opportunity to review the information in detail and ask questions. The signed Terms and Conditions document is
retained by SRS in the electronic project file and a copy provided to the PI.
Award (NOA) Form. Within 28 days of
an account request made to SPA, the PI and all project participants shall
complete an electronic acknowledgement
of project pertinent details within the
RIT Rapid database and set forth on the OCESP portion of the SRS website at http://www.rit.edu/ research/srs/compliance/roc/.
SRS shall use electronic media to inform
all persons working on the project, whether paid or unpaid, of the Pertinent Details
(as defined in RIT
Policy C1.0) of funded projects. Once
submitted, SRS receives automatic notification and regularly provides the NOA summary
information to the OCESP for review.
Effort / Changes in Effort. PIs and
project participants shall take diligent steps to ensure accurate reporting of
effort in accordance with federal regulations (OMB Circular A-21 – Cost
Principles for Educational Institutions) and other award requirements. PIs and project participants shall promptly
notify SRS if a significant change in the corresponding work activity is
expected to occur. OMB Circular A-21
defines significant changes as three months of no effort or a 25% differential
from what was reported to the Sponsor.
However, individual sponsors may have more stringent or specific
requirements. PIs are required to review
and certify a Quarterly Monitored Workload Report (QMWR) for each RIT employee
whose salary or wage costs are charged to a federal grant or contract during
the reporting period. The effort report
certification provides after-the-fact confirmation of employee activity
allocable to each Federal award as required by OMB Circular A-21. If during
review the PI determines that adjustments are needed, he/she is responsible for
contacting Sponsored Programs Accounting so corrected effort reports can be
Procurement and Monitoring. Principal
Investigators may purchase equipment by completing a purchase requisition as
described in the Procurement Manual – Requisition Process of Capital Equipment
found in the Procurement Services website: http://finweb.rit.edu/purchasing/policies/manual.html#requisition6.
If the project is funded by a government entity, the procurement process will
comply with the regulatory requirements outlined in OMB Circular A-110 –
Uniform Administrative Requirements for Grants and Agreements with Institutions
of Higher Education, Hospitals and Other Non-Profit Organizations and any additional
sponsor and program-specific requirements.
Fixed Assets Department in the Controller’s Office is responsible for
maintaining accurate equipment records in the Oracle Fixed Assets module that
contain identifier information, such as description of the equipment, serial
number, source of equipment, whether title vests with the federal government,
acquisition date, location, and payment source.
the PI or designee shall complete the University’s fixed asset physical
inventory by verifying the existence, location and continued need for the
equipment. The results of the inventory
shall be reconciled to the information contained in the University’s fixed
asset system and the inventory reports returned to the Fixed Asset Analyst with
appropriate notations of changes in location and retirements. The Fixed Asset Analyst will follow-up on any
discrepancies noted between the University’s records and the physical
inventory, as required.
Disclosure and/or Copyright. As
discussed at every PIM, if during the course of the project, a PI believes that
he / she has invented or created intellectual property that is patentable or
copyrightable, information pertaining to that potential intellectual property needs
to be promptly disclosed to RIT's Intellectual Property Management Office using
the RIT Invention Disclosure process.
The PI will be required to complete RIT disclosure forms to start any
required notifications sponsors and funding agencies. The disclosure forms and information
pertaining to RIT's Intellectual Property Policies are available at http://www.rit.edu/research/ipmo/internal/forms.php.
/ Vendor Determination. If a PI seeks to subcontract with a sub-recipient,
the PI shall work with SRS to develop the potential subcontract. If a PI wishes
to secure goods or services from a vendor, he/she should follow procurement
procedures as outlined in the RIT Purchasing
Manual. If the PI needs assistance in determining if an outside party is a
subawardee or a vendor, he/she should work with SRS and SPA staff to make the
appropriate determination and develop a procurement method, i.e. a subaward or
Reporting and Deliverables. The PI
is responsible for timely submission of all technical reports and deliverables
on a research project. The PI will receive
e-mail reminders from SRS in advance of known report due dates. In the event that SRS becomes aware that a
sponsor technical report is overdue, a series of escalating reminders and
notifications will be sent to the PI, and eventually, his/her department chairs
and/or supervisors, and ultimately the Vice President for Research as well as
Publicity. The PI is responsible for complying with all
sponsor terms and conditions regarding project publicity. In addition, the PI should always coordinate
any publicity involving a sponsored project with the VPR’s Director of Research
Communications and the applicable office of the RIT University News Service.
Close Out Process. The PI shall manage the close out of the
project with respect to the technical/substantive requirements, including the
final report to the sponsor. SPA is
responsible for working with the PI to process all financial requirements for
the close out of the project and any financial reporting. All other non-technical reports or
documentation required by the sponsor are coordinated with SRS, IPMO, and the
of Project End Date. The PI shall
receive a reminder notice from SPA ninety days prior to the end of the
award. The letter shall confirm the end
date and inform the PI of any actions that may be required to expedite the
close-out phase of the project and to ensure compliance with applicable sponsor
and regulatory requirements.
Financial Report. SPA shall also
send a Final Grant Statement to the PI, which reflects the expenditures that
have been recorded for the grant in the University’s financial system. The PI
is required to certify that the expenses are appropriate and in accordance with
the provisions of the award.
Invoice. Once all final expenses have been processed, SPA shall send a
final invoice to the sponsor, if one is required.
Facilities & Administrative Cost Recovery Funds. When final payment has been received from
the sponsor and all certifications and reports on the project are complete, SPA
shall distribute the recovered F&A
received from the sponsor according to the RIT procedure regarding return of
Recovered F&A Costs http://www.rit.edu/research/srs/grantsmgmt/Recovered_FA_Return.htm.
Contracts. If there is a surplus
balance remaining on the project after all charges including the budgeted
F&A costs have been posted that is 10% of the modified total direct costs
(MTDC) or $5,000 whichever is greater, SPA will request verification from the
PI that all deliverables have been met and an explanation for the variance from
the proposed budget. If all deliverables
have been met and the PI certifies the variance is a result of prudent cost
management, SPA will retain the documentation in the project files and return
the surplus to the PI’s discretionary account.
If deliverables have not been met, SPA will ask the PI to work with SRS
to resolve the situation with the sponsor.
Compliance Considerations for a Federally-Sponsored
Project. PIs, project participants,
SRS, and SPA shall be aware that if a project is federally-funded, additional
laws, regulations, and guidelines are applicable, beyond RIT policies that
restrict how the funds are expended. The
implications for violating these regulatory and legal requirements are
significant for RIT and the PI, and are addressed
in the training offered by SPA and SRS.
Acceptance / Giving of Gifts. All
members of the RIT community associated with a sponsored research project shall
refrain from giving or accepting any gift that is provided for the purpose of
influencing a decision in connection with any federally sponsored grant or
contract. Such a gift may be viewed as bribery or an illegal kickback in
violation of 41 U.S.C. § 53. The term
"gift" includes anything having monetary value, a gratuity, favor,
discount, entertainment, hospitality, loan, or forbearance.
Subject to the foregoing, members of the RIT
Community associated with a federally sponsored research project may offer or
accept a non-monetary gift or entertainment from the sponsor if the individual
gift or entertainment has a value equal to or less than $20, with a limit of
$50 in the aggregate for any calendar year.
Such non-monetary gift shall be permissible provided that it is reported
to and approved by the Office of Legal Affairs and are related to a legitimate
and identifiable business purpose.
Accuracy in Reporting. All members of the RIT Community associated with the reporting of expenditures
to a government agency or to a sponsor shall make efforts to ensure the reported
information is accurate. The government
places serious emphasis on accurate reporting, and the knowing or reckless
disregard of a false submission for payment may be viewed as a violation the
civil False Claims Act, 31 U.S.C. §
Anti-Lobbying. All members of the RIT community who have
access to government appropriated funds shall not utilize such funds to lobby any
government employee or agency. Such
activity may be viewed as violating the Anti-Lobbying
Act, 18 U.S.C. § 1913.
Wage and Hour Determinations. RIT staff
tasked with formulating wage and hour determinations shall ensure that their
guidance and instructions relating to sponsored research construction projects
is consistent with the Davis-Bacon Act,
29 C.F.R. §§ 1.5 and 1.6(b).
Allowability of Costs. The PIs, his/her designee, and/or
any other project personnel who expends or allocates costs on a sponsored
project has ready access to training and other reference materials on OMB
Circular A-21 available on the SPA website.
A-21 establishes principles for determining the allowability of costs applicable to grants, contracts, and other
cooperative agreements with educational institutions. The cost principles are intended to ensure
that each party to the agreement bears its fair share of costs determined in accordance
with generally accepted accounting principles, and as otherwise affected by law. See http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a021/a21_2004.pdf.
For example, the costs
of alcohol, RIT alumni activities, fund-raising activities and entertainment
are prohibited by law and may not be included in the direct costs that are
charged to the grant for reimbursement.
investigators and grant and contract administrators are encouraged to attend
training and made aware of the reference materials available on these issues
through regular communications from the SPA department, including but not limited
to, Project Initiation Meetings, quarterly financial review meetings,
individual outreach efforts, e-mail communications, memorandums, and
Administration of Grants. The PIs, his/her designee, and/or
any other project personnel tasked with administrative or reporting obligations
related to a sponsored project have access to training and other reference
materials relating to compliance with OMB Circular A-110 available on the SPA
and SRS websites. A-110 sets forth
standards for obtaining consistency and uniformity among Federal agencies in
the administration of grants to, and agreements with, institutions of higher
education, hospitals, and other non-profit organizations. See http://www.whitehouse.gov/sites/default/files/omb/assets/omb/circulars/a110/2cfr215-0.pdf. Examples of “grant administration” are
A-110’s requirement that RIT establish codes of conduct (which cover such
topics as conflicts of interest and gratuities) and mechanisms for research
performance reports and financial reports related to the grant.
investigators and grant and contract administrators are encouraged to attend
training and made aware of the reference materials available through regular
communications from the SPA and SRS departments, including but not limited to,
Project Initiation Meetings, quarterly financial review meetings, individual
outreach efforts, e-mail communications, memorandums, and newsletters, and
formal PI Institute and SPARC training programs for PIs and project staff.
Auditing Standards. University personnel responsible for the annual A-133 audit should be
knowledgeable of the requirements prescribed by OMB Circular A-133. A-133 sets forth standards for
obtaining consistency and uniformity among Federal agencies for the audit of States, local governments, and
non-profit organizations expending Federal awards. OMB Circular A-133 may be found at http://www.whitehouse.
gov/omb/circulars/al33/al33.html and the A-133 Compliance Supplement is
available at http://www. whitehouse.gov/omb/circulars_a133_compliance_09toc/.
Compliance with RIT's Policies and
Procedures. All PIs and project
participants are responsible for adhering to RIT's policies and procedures,
including those listed below that relate to the administration of their award
or agreement. A PI may seek further
assistance on these issues from SPA or SRS staff as applicable. Listed below
are links to the sponsored research related policies and guidance that PIs and
project participants are responsible for complying with while working on their
project. These policies are in addition to any sponsor, federal, and/or state
regulations which may also be applicable to the project, such as those
referenced in Section 3.8.
Export Control Compliance Program – Refer to the Finance
and Administration web site for detailed information about the Program: http://finweb.rit.edu/legalaffairs/export_compliance.html
Intellectual Property Policy – Refer to RIT's
Policies and Procedures Manual to obtain this Policy: http://www.rit.edu/~w-aa/Manual/sectionC/C3.html.
Non-Discrimination Policy – Refer to RIT's Policies
and Procedures Manual to obtain this Policy: http://www.rit.edu/~w-aa/Manual/sectionC/C6.html.
Policy for Protecting Human Subjects in Research – Refer
to RIT's Policies and Procedures Manual
to obtain this Policy: http://www.rit.edu/~w-aa/Manual/sectionC/C5.html. Institutional Review Board (IRB) guidance -
Refer to the Office of Human Subject Research web site for detailed information
about the IRB: http://www.rit.edu/research/hsro/
Hazardous Waste and Laser Safety Policy –
Refer to the SRS website for this guidance:
Recovery and Reinvestment Act of 2009 Process and Reporting Guidance - Refer to
SPA for RIT procedures.
SRS and SPA provide workshops and training opportunities on an
on-going basis for PIs and project administrators. The training reviews
PI project oversight responsibilities including quarterly monitored work load
reports, effort reporting, cost accounting, equipment accounting, conflicts of
interest, the approval of expenditures, and applicable legal requirements set
forth in Section 3.8.
and research administrators are strongly encouraged to attend training
workshops offered by SRS (the PI Institute) and SPA (SPARC training) throughout
the year to familiarize themselves with issues and topics related to sponsor
funding and research administration. Offerings
for prospective and current PIs are available at http://finweb. rit.
edu/ cpd/ as well as http://fineb.rit.edu/controller/training/sparc/. Information on PI Institutes and Previously
offered PI Institute session are available on http://www.rit.edu/research/srs/about/pi_institute/
Within SRS, the Director, Associate Director, and the Contracting
and Compliance Specialist, assisted by the Office of Legal Affairs and other
applicable departments, are responsible for examining and monitoring
non-financial compliance issues and tracking any non-financial reports on
sponsored projects. SPA is responsible
for examining and monitoring financial related compliance issues as well as
financial-related reports on sponsored projects. As part of this process, SPA shall monitor
the effort reports and financial certifications submitted by the PI.
review by SRS and SPA shall include an assessment of evolving and changing
risks associated with the sponsored projects.
To the extent that risks are identified, recommendations shall be made
to the appropriate Vice President to address the risk.
RIT's internal audit department shall use its regular schedule of audits
of research issues to audit financial accounts and oversight procedures, as
applicable, to ensure that Externally Sponsored
Projects follow RIT policy.
All members of the RIT community are expected to raise any
questions and report to the PI any potential or perceived violations of this
Policy, or any federal, state, local law, or regulation. If unresolved, or the matter is a complaint
that involves the PI, then the question or concern shall be forwarded to the
Vice President of Research. Violations
of this Policy or any federal, state, local law, or regulation must be reported
pursuant to RIT Policy C0.0 http://www.rit.edu/academicaffairs/policiesmanual/sectionC/C0.html
If credible evidence of a violation of a federal criminal
law involving fraud, bribery or gratuities, false claims or a conflict of
interest exists and such violation is in connection with a federal grant or
contract, then this evidence of a violation shall be reported to the applicable
AMENDMENTS TO POLICY
Substantive changes to this Policy shall be made by the appropriate Vice
President and reported in other appropriate vehicles to ensure full knowledge
by the RIT Community.