Procedures for Implementing
and Administering the
OVERSIGHT
POLICY FOR EXTERNALLY SPONSORED PROJECTS
ROCHESTER
INSTITUTE OF TECHNOLOGY
1.0 Purpose
This document specifies
administrative procedures to ensure compliance with the Oversight Policy for Externally
Sponsored Projects (the Policy) and to enable the Oversight Committee (the
Committee) to discharge its responsibilities.
These procedures are designed to dovetail as smoothly as possible with
RIT’s general procedures for the administration, accounting, and management of
agreements with external sponsors, taking advantage of technological
innovations when appropriate.
The procedures use the following terms (defined
in paragraph 5.0): Agreement, Classified
Information,
2.0 Implementation
2.1 General
Except as provided in Section 3.0, these procedures apply to
all Agreements between RIT or its subsidiaries and external entities for any
study, services, or research performed by RIT and managed in a restricted
project account.
2.2 Onset of Oversight
Principal Investigators and directors of
2.3 Public Record for the RIT Community
2.4 Participation List and Notification
When RIT receives a notice
of funding, SRS shall send the Principal Investigator (PI) a request for the Participation
List, a listing of all persons engaged in the project (whether paid or unpaid) noting
their status (student, faculty, or staff) and their email addresses. SRS shall use electronic media to inform all
persons working on the project, whether paid or unpaid, of the public record of
funded projects. The PI shall provide the
Participation List within two weeks of the release of the PI letter. For those projects that do not have PI
letters, SRS will determine the two week due date based on the paperwork
received. Participants are required to
acknowledge their acceptance of the project pertinent details within four weeks
of the release of the PI letter.
2.5 Revisions to the Project Participation List
An amended Participation
List must be filed after the original filing if participants change or if the sponsor
or project scope changes significantly. SRS
shall send PIs quarterly reminders to update the Participation List. If there are changes, the PI must inform SRS.
2.6
Oversight Committee Review Process
At its meetings, the
Committee shall:
(a) review Pertinent Details of new
projects;
(b) review and recommend action
on outstanding Participation Lists and quarterly reports;
(c) conduct prior reviews (as
explained in paragraph 2.7); and
(d) review and recommend action
on projects deemed to be in conflict with the Policy.
2.7
Situations Requiring Prior Review
The Committee shall review
projects prior to a signed Agreement whenever any of the following situations
arise:
(a) if the PI requests a limited
level of disclosure of Pertinent Details;
(b) if the project includes a
publication delay beyond the standard 90-day period; or
(c) if the project creates or
makes use of Classified Information;
2.8
Sponsor Notification
Where possible, SRS shall
include a clause that informs sponsors of the Oversight Policy and the record
accessible to the RIT Community
2.9
Audit
RIT internal auditors shall audit financial accounts and oversight procedures to ensure that all Externally Sponsored Projects follow the Oversight Policy. The audit shall be conducted every other year.
3.0 Procedures for Certain
Projects within Enterprise Centers
3.1 General
Enterprise Centers at RIT
perform a large volume of customized non-credit training and fee-for-service
projects, often with an established and relatively unchanging community of
participants who typically work concurrently on multiple projects, which
involve routine and repetitive processes. Many sponsors of these Center projects fund
multiple projects within the same fiscal year.
For such projects, the creation of separate financial accounts for each
project and project-specific notification to participants would create a
tremendous administrative burden. Therefore,
special procedures for non-credit training and fee-for-service projects at
Enterprise Centers are authorized and replace sections 2.4 and 2.5 above.
3.2 Accounts
Enterprise Centers may use single special project
accounts for all of their Agreements that are for non-credit training or
fee-for-service projects. Other projects
of Enterprise Centers shall follow the procedures explained in Section 2.0.
3.3 Participant Notification
Within 15 days of the end of
each fiscal quarter, Enterprise Centers shall send SRS a quarterly Participation
List as described in Sections 2.4 and 2.5 and shall physically post a quarterly
updated list of sponsors in a prominent place where it can be clearly seen by
all Center participants. This posting
shall inform participants of the nature of the work being conducted for specific
sponsors, thereby necessitating multiple sponsor lists based on the types of work
performed in the Center. SRS shall
notify participants on the quarterly Participation List of these postings.
3.4 Quarterly
Reports and Reconciliation Reports
Within 15 days of the end of
each fiscal quarter, Enterprise Centers shall send SRS a quarterly report listing
all Pertinent Details for all projects conducted during the preceding
quarter. SRS shall reconcile this list against
SRS project records. SRS and the Center shall
work together to seek timely resolution, with input from the Committee as
needed. Quarterly and reconciliation
reports shall be reported to the Committee on a regular basis.
4.0
Changes to Procedures
Changes to procedures shall
be considered and approved by the Committee and reported in the Committee’s
annual report and in other appropriate vehicles to ensure full knowledge by the
RIT Community. Significant changes shall
be presented to the RIT Board of Trustees for their ratification. Such changes shall be put in writing and
reported in annual reports.
5.0
Definition of Terms
Agreement means any contract or grant for any study, services, or research between an external funding source and the Institute or any Institute Subsidiary.
Classified Information is any information or material that has been determined by the US Government to require protection against unauthorized disclosure for reasons of national security.
Enterprise Centers are designated by colleges and centers with
confirmation by SRS. Enterprise Centers
as of September 1, 2006, include: Printing
Applications Lab and Image Permanence Institute in CIAS; Center for Quality and
Applied Statistics in
Externally Sponsored Projects are studies, services, and research performed by Agreement with RIT involving non-Institute funds or resources. Gifts and resources transferred with charitable intent are not considered Externally Sponsored Projects.
Institute Subsidiary means any organization which is a wholly-owned subsidiary of the Institute or one in which the Institute has majority controlling interest.
Participation List is a listing of all persons engaged in a project (whether paid or unpaid) noting their status (student, faculty, or staff) and their email addresses.
Pertinent Details include all of the following:
- name of the Principal Investigator,
- title of the project,
- abstract of the proposal,
- name of the sponsor and original source of funds (if different),
- amount of the project funding,
- project’s duration, and
- existence of any publication restrictions, Classified Information, and/or Proprietary Information.
Proprietary Information is information designated at time of disclosure as private property, including but not limited to trade secrets, patents, or trademarks. Receivers of Proprietary Information may use it only with the permission of its owner and may not disclose that information without permission.
RIT Community refers to persons with email accounts maintained by RIT.