Procedures for Implementing and Administering the
OVERSIGHT POLICY FOR EXTERNALLY SPONSORED PROJECTS
ROCHESTER INSTITUTE OF TECHNOLOGY
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, Enterprise Activities, Externally Sponsored Projects, Institute Subsidiary, Participation List, Pertinent Details, Policy, Proprietary Information, and RIT Community.
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 tracked by Sponsored Research Services (SRS).
2.2 Onset of Oversight
Principal Investigators and directors of units with Enterprise Activities and Institute Subsidiaries shall follow Institute-approved proposal development and approval processes. The procedures included in this document become operative when notice is received of an award and are integral to Agreement negotiation and project implementation.
2.3 Public Record for the RIT Community
Sponsored Research Services (SRS) shall maintain internet-based records that are accessible to the RIT Community. As required by the Oversight Policy, the records shall include Pertinent Details and thus shall replace the library repository that served the original Research Oversight Policy. The public record shall be available for five fiscal years following the end of the fiscal year in which the NOA was filed. After five years, records will be provided to the RIT Archivist.
Oversight meeting agendas, topical minutes including official decisions, fiscal year listings of NOAs, and annual reports will be available to the RIT Community through the RIT Digital Medial Library (DML) and through the Committee's website. New documents will be made available annually or by request to Sponsored Research Services (SRS).
2.4 Participation List and Notification
At the onset of oversight, the Principal Investigator (PI) or their representative will submit the current list of participants involved in the project. Although the Participation List may be compiled by a representative, it must be approved by the project PI. 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 confirmation of the Participation List within two weeks of the award being entered into the SRS database. Participants are required to acknowledge their acceptance of the project pertinent details within four weeks of the award being entered into the SRS database.
2.5 Revisions to the Project Participation List or Project Scope
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 to the participants, the PI must update the Participation List. If there are changes to the Project Scope, the PI must inform SRS.
At its meetings, the Committee shall at a minimum:
- review Pertinent Details of new projects;
- review and recommend action on outstanding NOAs and quarterly reports;
- review a summary of all projects that have undergone a prior review throughout the current fiscal year (as explained in paragraph 2.7); and
- review and recommend action on projects deemed to be in conflict with the Policy.
The Committee shall review projects prior to a signed Agreement whenever any of the following situations arise:
- if the PI requests a limited level of disclosure of Pertinent Details;
- if the project includes a publication delay beyond the standard 90-day period; or
- if the project creates or makes use of Classified Information;
Where possible, SRS shall include a clause that informs sponsors of the Oversight Policy and the record accessible to the RIT Community
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.
In addition to RIT's internal auditors, SRS will perform reconciliations or other reviews as necessary to ensure that NOAs and other award data are accurate. SRS will report to the Committee regarding significant findings at the quarterly meetings.
On an annual basis, SRS will obtain from the Office of Legal Affairs (OLA) an updated listing of institute subsidiaries. Each subsidiary will be contacted regarding their level of externally sponsored projects for review by the Committee.
In accordance with RIT's Records Management Policy C22.0, the records of the Committee must be retained indefinitely. The following Committee documents will be retained:
- The pertinent details of each project (from the NOA);
- Committee meeting agendas and topical minutes, including official decisions;
- Quarterly Reports to the Committee;
- Annual Reports; and
- Committee membership listings
3.0 Procedures for Enterprise Activities
Some units at RIT perform a large volume of externally sponsored work that is routine and repetitive (with examples being 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. Many sponsors of these Enterprise-type 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 pose a tremendous administrative burden. Therefore, special procedures for non-credit training and fee-for-service projects at certain units are authorized and replace sections 2.4 and 2.5 above.
Units with approved enterprise activities may use single special project accounts for all of their Agreements that are for non-credit training or fee-for-service projects. All non-Enterprise-type projects conducted by these units shall follow the procedures explained in Section 2.0.
3.3 Participant Notification
Units must provide 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 Enterprise-Activity participants.
Within 30 days of the end of each calendar month, each unit conducting approved enterprise activities shall send SRS a report listing all Pertinent Details for all projects invoiced during the preceding month. On a quarterly basis, such units must also confirm the posting of an updated sponsor listing in their area.
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. The Committee will review the procedures document annually to confirm that it accurately reflects current processes.
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.
An Enterprise Activity is a set of externally sponsored projects that are similar enough that a single scope of work or job description applies accurately to the whole set. Usually the work involves routine analysis, evaluation, or non-credit training. In addition, the number of such projects is usually sufficiently great that it become much more efficient to prepare a single scope of work or job description than a series of separate NOAs.
Anyone desiring an updated list of units which conduct Enterprise Activities can consult the SRS website at: http://www.rit.edu/research/srs/compliance/roc/index.html.
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.
NOA is an acronym for Notice of Award and is the record of pertinent details for a specific awarded project and the project personnel verification.
Participation List is a listing of all persons engaged in a project (whether paid or unpaid) noting their status (student, faculty, or staff).
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.