OCRO Handbook for Sponsored Programs

 

GW SUPPORT FOR RESEARCH

I. GW SUPPORT FOR RESEARCH  

Section 1: The Vision: GW’s Research Policy, Mission, Strategic Goals and Guiding Principles on Integrity and Compliance

This Section provides a broad perspective on GW’s vision of the purpose of research and its value and promise for benefiting the University community as well as providing service of local, national and international interest and importance. Included are discussions regarding how GW’s research enterprise is to be further enhanced and the guiding principles of integrity and ethics in conducting research at GW. A summary of the roles and responsibilities of those individuals and organizations involved in supporting and developing research at GW is provided. For further information on research-related policies at GW, refer to http://www.policy.gwu.edu

1.1. RESEARCH MISSION

The George Washington University is a comprehensive university with broad responsibility for education at both the undergraduate and graduate levels. The inextricable link between teaching and research comes to the fore in two ways as the university carries out its educational mission: the professor/researcher transmits new knowledge to students, and students participate in and learn about research with guidance from the professor/researcher. This synergy is manifest in the statement of the research mission of GW:

The research mission of the University is to create and synthesize knowledge at the frontiers of our understanding and to use that knowledge to address issues of increasing complexity in our world, while strengthening the necessary ties between teaching and research.

For further information on the mission of GW as a University, see The George Washington University Faculty Handbook, Section 1-3, Mission Statement, http://www.gwu.edu/~academic/OfficeVicePresident/pdf/Faculty_Handbook.pdf.

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1.2. RESEARCH GOALS

To realize its research mission, GW must focus its attention on and commit its resources to the achievement of certain goals. GW's broad research goals remain those articulated in the 1994-1995 and 1997-98 versions of the Strategic Plan for Research.

Goal 1.

Attract high-quality faculty and students to GW.

Goal 2.
 

Enrich through research the quality of graduate and undergraduate scholarship and education.

Goal 3.

Develop a more supportive research culture and environment at GW.

Goal 4.

Increase the quality and quantity of research by both faculty and students.

Goal 5.

Increase the amount of sponsored research at GW.

Goal 6.

Enhance the reputation of GW as a research-oriented University.

In addition, GW now states as one of its University-wide goals "To move GW into the ranks of the top-tier research institutions through continued and enhanced facilitation of scholarship and research growth." GW is pursuing the specific goals above and this overarching goal of becoming a top-tier research university through a strategy of selective and multidimensional excellence, as expressed in the specific objectives and strategies as further discussed in the University’s Strategic Research Plan, http://www.gwu.edu/~academic/OfficeVicePresident/pdf/Strg_GWBook.pdf.

GW’s increasing focus on becoming a national center for research excellence is reflected in the significant growth in sponsored research programs at the University from approximately $54 million in expenditures in 1997 to approximately $125 million in 2004. Along with this growth in research activity is the investment in people and resources necessary to enable GW to conduct research in accordance with the highest standards of ethics for academic scholarship, personal integrity and business conduct.

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1.3. UNIVERSITY GUIDELINES ON RESEARCH

The University’s Guidelines on Research are set forth in The George Washington University Faculty Handbook, Section 5-1., http://www.gwu.edu/~academic/OfficeVicePresident/pdf/Faculty_Handbook.pdf, as follows:

Scholarly Activity is expected of all faculty members. The University does not attempt to influence the kind of research undertaken, but it may regulate the proportion of effort invested in research relative to teaching and other academic professional duties, depending on the mission of the department and the choice of the faculty member.

The University recognizes that the scholarly achievements of its faculty form an extremely important element in the University’s academic reputation and hence its ability to attract and retain the best faculty and students. The following guidelines have been adopted to help promote faculty research while ensuring that the University’s own integrity is preserved.

  • The University encourages both sponsored and non-sponsored research. The collegial involvement of graduate and undergraduate students in faculty scholarship is strongly encouraged.
  • The University supports no research that involves the destruction of human life or the impairment of human capacities and abides by federal regulations concerning the protection of human subjects in all research, both sponsored and non-sponsored, whether conducted primarily by faculty or by students.
  • The University requires the proper and humane treatment of all animals involved in research, both sponsored and non-sponsored, whether conducted primarily by faculty or by students, and will fulfill all necessary local and federal requirements for their housing and maintenance.
  • The academic program of any student working towards any degree may not be classified or restricted from access by other members of the academic community.
  • Agencies that sponsor research are not permitted to influence the selection or promotion of faculty members engaged in research or to influence the nature or direction of the research being sponsored. The development and execution of a sponsored program, once approved by the sponsoring agency, is the responsibility of the principal investigator. It is understood that this may involve the University in contractual obligations with the sponsoring agency.
  • University policy does not allow faculty to pursue research programs that restrict the freedom of the investigator to reveal the purpose, scope, or findings of the research, without the prior approval of the Chief Research Officer. The University does not engage in classified research. Private consulting activities of faculty undertaken in accordance with applicable University guidelines are not covered by this prohibition.
  • In certain instances, if research is funded by an external sponsoring organization, the University may agree, when justified, to a request for delay of publication of the results for up to 60 days.

1.3.1. Research Policy on Classified Research
Classified research, research for which knowledge of methods and/or results is restricted to individuals who have U.S. government security clearances, may play a critical role in serving the public interest. However, it is not compatible with open communication of knowledge within the academic community because it places restrictions on which faculty and students can access research data, the facilities required to carry out research, and/or research results. For more information regarding the University’s Policy on Classified Research, see http://my.gwu.edu/files/policies/PolicyonClassifiedResearch.pdf. The University Guidelines on Research as stated in the Faculty Handbook has been elaborated upon and reaffirmed in the post-September 11 context as set forth in the University’s Policy on Classified Research, http://my.gwu.edu/files/policies/PolicyonClassifiedResearch.pdf.  

1.3.2. Proprietary Information Considerations
Proprietary research sponsored by industry may also raise issues concerning restrictions on the open communication of information. It may involve the desire on the part of a company to keep secret a research discovery by a GW researcher or a company's trade secrets, sensitive business information, or intellectual property. The sponsoring company may request to review publications in advance to verify that such proprietary information is not revealed. The company may also seek delay of publication while a patent application is being filed.

GW's policies and practices regarding proprietary research are expressed in the "Policy on Research Agreements with Industry" (1999; see www.gwu.edu/~research/resagree.htm). Consistent with the University Guidelines on Research, it allows sponsors a 60-day review period in which to review draft publications or presentations in advance of their release where there is a possibility that they may disclose sensitive, proprietary information or scientific discoveries. As with all sponsored program agreements, the specific terms of agreements with industry sponsors are negotiated by the Office of the Chief Research Officer within the framework of University policy.

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1.4. DEFINING SPONSORED RESEARCH AND DETERMINING PI ELIGIBILITY

1.4.1. Sponsored Research Projects

As defined in the Research Grants and Contracts Definition Policy,  http://my.gwu.edu/files/policies/Grants&ContractsDef.FINAL.pdf, “Sponsored Research Project” is a specific research, training, service, or similar activity for which funding is provided by an external sponsor under an agreement with the University.   Proposals meeting any of the following criteria are treated as a Sponsored Research Project and must be reviewed and endorsed by OCRO before submission to a sponsor. 

  • The award requires a line-item financial report to the grantor/sponsor at any time during the life of the project.
  • The award has a cost-sharing component (University, school, or department matching funds).
  • The award is one of several to a project for which there is a project-wide financial reporting requirement (i.e., any of the granting/sponsoring entities require a financial report for the entire project).
  • The grantor/sponsor controls the scope of the project and/or requires scientific or technical reporting of specific milestones as a condition of the grant/award.
  • The award includes funds that will be re-granted or subcontracted by the University to non-GW entities.
  • The award includes indirect costs recoveries.
  • The award involves an Intergovernmental Personnel Act (IPA) agreement that places GW personnel on assignment to a Federal agency.
  • The grantor/sponsor states in its award letter that it maintains the right to perform a detailed financial audit of the award expenditures.
  • The proposal indicates a conflict of interest;
  • The proposal contains the use of animals, human subjects, or hazardous agents requiring the review of OHRCTT;
  • There are conditional obligations of the funding indicated in the award document or solicitation (e.g., time and effort, space, budget restrictions, return of unused funds, contingent payments, employment requirements);
  • The award or solicitation contains intellectual property provisions, indemnification, hold harmless, provisions containing restrictions on publication of research results and other contractual provisions that place risk on the University.

The Advancement Office may well be involved in proposals meeting one or more of these criteria, and the Advancement Office will work with OCRO to facilitate the proposal effort. Proposals not meeting any of these criteria are considered requests for Gifts and should be coordinated through the Advancement Office.  Note that proposals to federal sponsors or the District of Columbia almost always go through OCRO, and in the event of any doubt about the nature of the proposal or any required approvals, it is always best to check any questions out with the appropriate Research Services Coordinator within the OCRO.  For further information regarding proposals requiring approval by OCRO, please see the Research Grants and Contracts Definition Policy, http://my.gwu.edu/files/policies/Grants&ContractsDef.FINAL.pdf

1.4.2. Eligibility

A regular or research faculty member, Research Scientist, Senior Research Scientist, or Senior Research Staff Scientist may serve as “Principal Investigator” on an award. For those drawn from the "research" professor ranks, it is usually spelled out in the appointment letter that such appointees must raise funds for their salary from external sources, or such.  Otherwise, GW does not permit Limited Service appointees to serve as Principal Investigators and one does not simply change someone's status for this purpose. The same categories of personnel eligible to serve as Principal Investigator may serve as a “Project Director” (PD). The PD term is sometimes used to describe the Principal Investigator; more often, the PD is the next person in charge of a program. The University looks to the Principal Investigator as the individual with the primary responsibility over the Project. 

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1.5. RESEARCH INTEGRITY AND COMPLIANCE

1.5.1. Research Integrity

GW research must be responsible and trustworthy in all respects. In this regard, the University has a broad range of policies governing research activities including those in the Research and Finance Sections of the University’s Policies, http://my.gwu.edu/mod/upolicy/index.cfm?thisTab=2 It is the responsibility of everyone associated with research at GW to comply with federal, state, local laws, regulations and University policies in all aspects of any research conducted for or on behalf of the University.  GW has a number of Policies fundamental to research integrity that support the overriding effort to verify that  GW research is conducted in a manner that is honorable in all respects. These Policies include those covering conflict of interest/commitment and allegations of scientific misconduct; those required to maintain GW’s responsibilities as a proper steward of sponsor funds, such as effort certification and various cost accounting policies including Identification and Treatment of Unallowable Costs and Reporting Financial Irregularities; and those essential to the preservation and safety of everyone involved in research, such as those involving the protection of human and animal subjects, lab and environmental safety requirements and the like.

1.5.1.1. Conflict of Interest and Commitment: The complex relationships among universities, government and industry require attention to standards of procedure and conduct in research. While the Faculty Code states, “faculty shall have a primary responsibility of devoting their time, thought, and energy to service of the University, of no less importance is a faculty member’s responsibility to further her or his own professional development and the goals of her or his professional discipline. Conflicts of interest may occur when there is a divergence between a faculty member’s private interests and professional service to the University. Under the University’s “One-day-a-week” rule, a full-time faculty member (except for research and medical faculty) may spend the equivalent of up to one day a week on outside consulting and other professional activities, as long as it does not interfere with University obligations.

It is expected that any member of the University staff will inform University management as appropriate of any outside obligations that may represent conflicts of interest. Trust is advanced by appropriate disclosure and discussion. The importance of avoiding Conflicts of Interest/Commitment is reflected in the University’s Policy on Conflict of Interest and Commitment For Faculty and Investigators, http://my.gwu.edu/files/policies/ConflictofInterestandcommitment.pdf. This Policy provides for an annual disclosure of reportable actual, potential and apparent conflicts of interest by faculty including research faculty. The scope of “managerial” personnel required to submit the annual officer’s and managers’ conflict of interest disclosure includes all research staff with the title of “Research Scientist” and above. Additionally, a separate Financial Interest form identifying any such conflicts or confirming that there are none must accompany all research proposals submitted for approval at GW.  Avoiding undisclosed conflicts of interest/commitment is essential in order to: maintain integrity in research, education and service; fulfill responsibilities to the federal government, the sponsor, and to the University; and to prevent damage to reputation as well as potential civil or criminal charges to the University or the individual involved. GW’s Conflict of Interest and Commitment Policy, as approved by the Faculty Senate and the Board of Trustees, covers not only Faculty but also Investigators, i.e., anyone responsible for the design, conduct, or reporting of externally sponsored research. Examples of such conflicts include:

  • Depriving the University of appropriate (compensated) time due to excessive external commitments (such as exceeding the limitations of the “one-day-a-week” rule for outside consulting activities;
  • Making substantial use of GW human and material resources for non-University purposes (inappropriate use of University employees or assets);
  • Allowing outside financial involvements to affect, or appear to affect, academic responsibilities (hiring a spouse on a grant, purchasing equipment for a sponsored program from a close relative, or accepting funds from a private company to investigate a new drug while owning a substantial amount of stock in that company);
  • Depriving GW of appropriate potential financial gain (failing to disclose an invention conceived or first reduced to practice under a sponsored program and then seeking a patent on it).

As part of their responsibilities for managing research programs, Principal Investigators are responsible for ensuring that research staff disclose perceived or actual conflicts of interest. Conflicts of interest that arise in conjunction with specific proposals need to be disclosed to the department chair and dean and be addressed as part of the proposal review process. The form for reporting conflicts or confirming that there are none associated is set forth in Appendix E. Conflicts must also be disclosed on annual disclosure forms, applications to the Institutional Review Board (IRB) for human subject approval, and anytime they arise. Forms for such reporting are also provided in Appendix E. The Office of the Chief Research Officer maintains an electronic listing of potential conflicts of interest identified from three sources: (i) annual faculty conflict of interest reports, (ii) agreement specific faculty Financial Interest Disclosure forms, and (iii) annual staff conflict of interest disclosures. If a potential conflict of interest arises involving a sponsored program, the matter is escalated right away to the Managing Director Research Support and Analysis level to evaluate as to whether there is a conflict and if so, whether the matter may proceed pursuant to an approved conflict of interest management plan. For more on Conflict of Interest/Commitment, see www.my.gwu.edu/files/policies/ConflictofInterestandcommitment.pdf.

1.5.1.2 Allegations of Scientific Misconduct: In pursuing the GW’s Research Mission, the University attempts to promote and conform to the highest standards of ethical scientific conduct. In furtherance of this effort, and in accordance with the scientific misconduct regulations of the Office of Research Integrity of the U.S. Department of Health and Human Services, GW maintains a policy and procedures regarding allegations of scientific misconduct. “Scientific Misconduct” is the fabrication, falsification, or plagiarism, in proposing, performing, or reviewing research or in reporting research results, or other practices that seriously deviate from those that are commonly accepted within the research community for proposing, conducting, or reporting research. This does NOT include honest errors, differences in opinion or interpretation of data. University policy requires all employees or individuals associated with GW to report observed, suspected or apparent misconduct in science to the Associate Vice President for Health Research, Compliance and Technology Transfer, or if not available, to the Vice President for Health Affairs. Procedures are provided to verify that any such allegations are promptly reviewed and properly investigated in a matter that is fair and protects both the individual and the person against whom an allegation of scientific misconduct is made. For more information, see http://my.gwu.edu/files/policies/ResearchMisconductPolicy.pdf.

1.5.2. General Compliance Considerations

In addition to all University policies related to research integrity, there are many government and general compliance standards that apply to conducting research at GW as referenced in GW’s Employee Compliance Guide http://my.gwu.edu/files/policies/ComplianceAwarenessGuideFINAL.pdf.This Guideemphasizes the need for and responsibility of all GW employees to perform their duties and responsibilities in compliance with applicable federal, state and local laws and regulations and the Policies of the University.  Although the Guide addresses a number of specific laws, policies, rules and regulations, it is not intended to be a comprehensive list of legal and ethical standards.  Rather, it provides employees information about some of the laws, policies, rules, and regulations that have a direct effect on the daily University activities and operations, including research. 
The University maintains a Compliance and Ethics program to enable it to exercise due diligence in preventing and detecting improper and criminal conduct and to otherwise promote a culture that encourages ethical conduct and a commitment to compliance with the law. When any employee accepts external funding for a program, she or he accepts responsibility for complying with sponsor and University requirements for its use – and for ensuring that any staff does as well. Specific ethics or employee compliance questions should be directed to supervisors first and then to the Compliance and Privacy Office.  The Compliance and Privacy Office is located at 825 21st Street N.W., Washington, DC, and can be contacted at 202-994-3386 or by e-mail at comply@gwu.edu.

1.5.2.1. The Compliance Program:  The Compliance Program reflects the University’s commitment of maintaining the highest ethical standards and of complying with all applicable laws, regulations, policies, and procedures. The Assistant Vice President for University Compliance and Privacy is responsible for the administration of the University's Compliance Program.  Usually, compliance issues should be addressed through normal administrative channels.  However, a reporting procedure has been established as a way for employees to report instances of suspected non-compliance outside the normal chain of command.  This method is intended to preserve confidentiality to the extent possible under University policy. There is a "Regulatory Compliance Help and Referral Line” (“Compliance Line”) to provide a way for employees to report instances of suspected non-compliance with laws, rules, regulations and policies.  Employees who call the Compliance Line may remain anonymous if they so choose.  Of course, depending on the allegation, the investigation may be restricted if the caller cannot be contacted for additional information.  If the caller requests anonymity, no attempt will be made to identify the caller.  Information provided by the caller will be treated as confidential and privileged to the extent permitted by University policy.  The Regulatory Compliance Help and Referral Line is administered by the University Compliance and Privacy Office. The telephone number for the Regulatory Compliance Help and Referral Line is toll free  (888) 508-5275.  E-mail may be sent to Comply@gwu.edu.

1.5.2.2. Statement of Ethical Principles:

The George Washington University has adopted a Statement of Ethical Principles that sets forth the University’s core values, and guides the actions of anyone acting on behalf of the University.  The Statement is supported by numerous University codes and policies that tell us what to do. However, when the “right” answer is not clear from published University codes and policies, then the broad ethical principles in the Statement should be followed to make the right decision.

Integrity and Respect

The University community is diverse -- in race, background, age, religion, and in many other ways. The personal actions of each community member establish and maintain the culture of tolerance and respect for which we strive. The University is committed to free inquiry, free expression, and the vigorous discussion and debate on which the advancement of its educational mission depends.  At the same time, trustees, senior officials, faculty, principal investigators, staff, student employees, and others acting on behalf of the University should respect the rights and dignity of others regardless of their differences, and must conscientiously comply with nondiscrimination policies adopted by the University.

 

 

Responsibility and Accountability

University trustees, senior officials, faculty, principal investigators, staff, student employees, and others acting on behalf of the University should assume and exercise responsibility appropriate to their positions and roles. We are accountable to each other, to the University, and to ourselves for our actions and our decisions not to act. When roles or responsibilities are unclear, we should take it upon ourselves to obtain clarity. We should exercise sound professional judgment in the performance of our responsibilities, to the best of our ability.

 

 

Conflicts of Interest and Commitment

All trustees, senior officials, faculty, principal investigators, staff, student employees, and others acting on behalf of the University hold positions of trust, and should conduct their activities accordingly.  Activities that impair or appear to impair the ability to perform our duties or affect independence and objectivity of judgment in the discharge of our responsibilities to the University should be avoided.  We should demonstrate sensitivity in identifying potential conflicts of interest, whether of a financial, personal, or professional nature.  Conflicts of interest must be disclosed, reviewed, and appropriately managed or eliminated in accordance with the reporting and other provisions of applicable University policies.

 

 

Harassment and Abuse of Power

The University supports an environment in which harassment of others is not tolerated.  Trustees, senior officials, faculty, principal investigators, staff, student employees, and others acting on behalf of the University may not use positions of authority to violate or to influence others to violate laws, regulations or University policies. 

 

 

Stewardship

As stewards of University resources, all trustees, senior officials, faculty, principal investigators, staff, student employees, and others acting on behalf of the University have a responsibility to ensure that all University resources are used prudently, ethically, and for their designated purposes. We have a responsibility to contributors to the University, including federal, state, and local governments, to treat University property with care, and to expend funds prudently. We should avoid waste and improper use, and should not use tangible or intangible University assets, funds, property, or facilities for our personal benefit or for the benefit of a non-University organization without proper approval. Our acts should reflect the recognition of a special obligation to use University property responsibly and consistent with the tax-exempt status conferred on the University in light of its educational, research, and service missions. It is imperative that those with access to confidential, proprietary, or private information not make unauthorized disclosures or use of this information.

 

 

Reporting

All trustees, senior officials, faculty, principal investigators, staff, student employees, and others acting on behalf of the University are expected to report violations of laws, regulations or University policies to appropriate University officials, e.g., the employee's dean, department chair or other supervisor, senior University administrator, University Compliance & Privacy Office, or Office of General Counsel. Confidentiality of individuals reporting violations of these standards will be maintained to the extent possible.


These ethical principles require our personal commitment to: 

•           Become familiar with and comply with relevant University Policies;

•           Become familiar with and comply with relevant University Policies;

•           Obey laws and regulations;

•           Be responsible and accountable for our actions;

•           Exercise sound professional judgment;

•           Use University resources with care and prudence and avoid waste and improper use;

•           Disclose only that information that is authorized and protect that information which is confidential, proprietary or private;

•           Treat people with respect and dignity and promote an atmosphere in which equal opportunity is extended to every member of our             diverse community;

•           Create a safe University community, free from harassment or physical and environmental threats;

•           Avoid activities that impair, or appear to impair, our ability to perform our duties or affect our independence and objectivity.             Conflicts of interest between our work and personal affairs must be disclosed, reviewed, and appropriately managed or             eliminated;

•           Sustain a culture in which ethical conduct is recognized, respected and promoted; and,

•           Report instances or non compliance with these ethical principles or violation of University policies. 

The Statement of Ethical Principles is available on the University central policy web page at http://my.gwu.edu/files/policies/StatementofEthicalPrinciplesFINAL.pdf.

1.5.2.3. Office of Research Training and Compliance: In a further effort to reinforce the importance of complying with all applicable laws, regulations,  rules and University Policies as they pertain specifically to sponsored research programs, a dedicated compliance office has been established focused on sponsored research. This Office, which reports to the Chief Research Officer, is the Office of Research Training and Compliance (ORT&C). It is responsible for centralizing and enhancing research-specific compliance monitoring and providing appropriate training programs for central office staff as well as Principal Investigators, Departmental personnel and others in the University’s research community.  In addition to a variety of internal reviews or processes and procedures as well as transactional testing for compliance purposes, , this Office performs fiscal responsibility training for GW faculty who serve as Principal Investigators on sponsored research programs. This training, which covers federal regulations and GW Policies applicable to sponsored programs including conflict of interest, subcontractor and vendor selection, property management, allowability and stipends, among other things, is mandatory for all PIs as well as those on their awards who have substantial ability to influence financial transactions on the program. For further information about this Office including contact information, please refer to Section 2.2.8.

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Section 2: Roles and Responsibilities:

The People and Resources Supporting Research at GW
GW’s commitment to furthering its research policy, mission and goals is reflected in the support and services provided at all levels throughout the University. The following summarizes the roles and responsibilities for conducting research at GW. These roles and responsibilities are further defined and highlighted in each Section of this Handbook as appropriate. For further information on Roles and Responsibilities, see The George Washington University Faculty Handbook, Section 1-6, Administration, http://www.gwu.edu/~academic/OfficeVicePresident/pdf/Faculty_Handbook.pdf.

2.1. DEPARTMENTS & SCHOOLS / RESEARCH CENTERS & INSTITUTES

2.1.1. Principal Investigators

The Principal Investigator (Principal Investigator) is responsible for the overall management of the scientific, technical, financial, compliance and administrative aspects of the sponsored research program in accordance with relevant regulations, University Policy, the Faculty Handbook and this Handbook. The Principal Investigator may delegate many of the administrative tasks to staff members but has primary responsibility for the grant, contract or cooperative agreement.  The Principal Investigator prepares the technical narrative and develops the budget to support the proposed activity. The Principal Investigator identifies the need for subcontracts, collaborators and additional space or funding requirements.  The Principal Investigator prepares all proposal forms and required regulatory forms and verifies that the proposal conforms to sponsor technical and administrative requirements.  If an award is funded, the Principal Investigator reviews and approves the scope of the program given the funded terms and conditions of the award. In addition to reviewing the terms and conditions of an award, the Principal Investigator also reviews the sponsor’s policies, particularly those pertaining to the expenditure of funds. The Principal Investigator is then responsible for conducting and managing the technical, scientific and programmatic aspects of the sponsored program within those parameters, including reviewing monthly expenditure reports, satisfying submission requirements for technical and administrative reports, and verifying that all expenditures are reasonable and allocable to that specific program. The Principal Investigator also verifies that periodic after-the-fact effort reporting and certification requirements are met, and that all award close-out requirements are achieved in coordination with OCRO and GCAS. The Principal Investigator must also adhere to institutional policies regarding intellectual property.

2.1.2. Department Administrators

The Departmental Administrator (DA) provides administrative support for one or more Principal Investigators and programs.  The DA supports the Principal Investigator, as needed, with the proposal submission process.  Once an award is made the DA prepares certain financial and administrative documents for submission and approval as appropriate and the DA maintains administrative files/databases for the programs.  The DA Works with central administrative offices to assist in efficient administration of the program.  See also the section on School Research Administrators, Section 2.2.7.5.

2.1.3. Research Centers/Institute Directors (where applicable)

The Research Center or Institute Director reviews the technical aspects of the proposal to verify it represents a program that will further the goals of the center.  The Director will also review the proposal to assess its impact on the center’s operating budget and any associated space or salary constraints.  The Director provides technical guidance for the program as necessary. For further information about research support and assistance available from Research Center and Institute Directors, including contact information, please refer to the list of GW Research Centers and Institutes provided in Appendix B.

2.1.4. Department Chairs

The Department Chair is responsible for establishing and maintaining high standards of ethical conduct and fiscal responsibility in the unit and for fostering a culture of compliance with regulations and policies pertaining to sponsored research.  The Department Chair reviews and approves the proposal being submitted to verify that the Principal Investigator can effectively manage the program given other academic and administrative commitments, as well as to confirm that proposals and programs are in accord with department/school objectives.  The Chair assesses the adequacy of the budget and how it will impact departmental finances and reviews for any additional space or cost sharing requirements given the scale of the program. In signing a proposal, the Chair also accepts financial responsibility for the department for any eventual overruns and/or cost disallowances. The Chair also approves certain expenses or actions related to the program such as stipend payments, tuition, new hires, and cost sharing commitments. Where possible, the Chair provides departmental assistance in preparing and submitting appropriate documentation for financial and other administrative transactions. For further information, The Chair’s Roles and Responsibilities for Oversight of Sponsored Projects at GW, http://www.gwu.edu/~research/files/chairresponsibilites.pdf

2.1.5. Deans of Schools

The Dean’s Office reviews the proposal to verify that the faculty member is eligible to be a Principal Investigator and can effectively manage and properly conduct the proposed program. The Dean’s Office also reviews budgets, gives official approval to any cost-sharing commitments or provisions for additional resources, and confirms that proposals and programs are in accord with department/school objectives. The Dean’s Office will accept financial responsibility for any eventual overruns and/or cost disallowances, and will often provide local administrative support for the program once funded.

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2.2. CENTRAL ADMINISTRATION

2.2.1. President

The President strategically guides the University and, in conjunction with the Board of Trustees, commits resources to support GW’s research mission including actively cultivating relationships with industry and government.

2.2.2. Executive Vice President for Academic Affairs (EVPAA)

The Executive Vice President for Academic Affairs (EVPAA) is responsible for the oversight of GW research, Deans and Faculty.  The EVPAA promotes relationships with external sponsors and fosters research collaborations across the University’s academic community.  The EVPAA oversees research policy formulation, education, and compliance.  The EVPAA is directly involved with the resolution of any non-compliance issues that may arise from research and acts as a liaison with federal regulatory agencies during external reviews.

2.2.3. Executive Vice President and Treasurer (EVP&T)

The Executive Vice President and Treasurer (EVP&T) provides guidance in the development of institutional policies and education for financial management in sponsored programs in accordance with federal regulations and sponsoring agency policies and procedures.  The EVP&T oversees the preparation and negotiation of the Facilities and Administrative and fringe benefit rate proposals and is responsible for coordinating and responding to external audits.

2.2.4. Provost and Vice President for Health Affairs (Provost/VPHA)

The Provost and Vice President for Health Affairs (Provost/VPHA) cultivates the research mission at the Medical Center by fostering new health related research initiatives. The Provost/VPHA translates policies across the four entities of the Health Center: the School of Medicine and Health Sciences, the School of Public Health and Health Services, the Medical Faculty Associates, and the University Hospital.  The Provost/VPHA is also responsible for the oversight of the Office of Health Research, Compliance and Technology Transfer. 

2.2.5. Chief Research Officer

The CRO has broad responsibility for advancing the research enterprise. The CRO collaboratively generates the strategic plan for the research in collaboration with the faculty, Chairs, Deans, Associate Vice-President for Health Research and EVPAA. The CRO provides seed funding for research, coordinates technology transfer matters for the University and has direct responsibility for research compliance and training to address federal and state regulatory requirements associated with sponsored programs.  The CRO provides oversight and direction to the Office’s Managing Directors, Managers, Team Leaders, Research Service Coordinators, School Research Administrators and Staff of the Office of the Chief Research Officer and the Office of Research Training and Compliance (ORT&C). The CRO is responsible for approving any cost sharing on behalf of the University or additional space requirements in a proposal, as well as any proposal or award that meets certain dollar thresholds or complexity factors.

2.2.6. Executive Research Oversight Committee (EROC)

The Executive Research Oversight Committee facilitates coordination and strategic consideration of GW research topics and responses to research issues that may arise. To enable visibility of these issues at the highest levels, the EROC members are the Executive Vice President for Academic Affairs, the Executive Vice President and Treasurer, the Vice President for Health Affairs, the Chief Research Officer and the Deputy General Counsel.

2.2.7. The Office of the Chief Research Officer (OCRO)

The Office of the Chief Research Officer (OCRO) was created to increase accountability by consolidating and centralizing the leadership and coordination for research through a single individual. OCRO supports the efforts of the GW community to generate and manage external awards in support of research, training, instruction, and public service activities. It works with Principal Investigators in every University component to adhere to University and sponsor regulations. OCRO has been designated to represent the University in providing the final institutional signature on proposals, in negotiating terms and conditions for grants, contracts, subcontracts, and other award mechanisms, and in dealing with administrative representatives of external sponsors on issues related to sponsored programs. OCRO also assists faculty members in finding sources of funding appropriate to their research.  The office reviews proposals for the accuracy of all financial and institutional information, conformity with sponsor requirements, and verifies that all necessary institutional approvals have been obtained. OCRO is responsible for creating award accounts in the Oracle Grants Management System. OCRO provides significant post-award assistance to Principal Investigators, including expenditures approvals, subcontract modifications, and input in the award closeout process.

OCRO also administers several GW-funded programs as further described in Section 4, Sources of Research Funding, which are designed to foster research, scholarship and creativity. These programs include the University Facilitating Fund and Dilthey Fellowships, the Research Enhancement Fund, and REIA (exclusive of Medical Center).
For further information about research support and assistance available from OCRO including contact information for OCRO, please refer to the GW Research Webpage, http://www.gwu.edu/~research/.

2.2.7.1. Directors:  Reporting to the CRO are the:

  • Managing Director for Research Support and Analysis, who approves proposals and awards as well as overseeing the Contract Pre-Award Mangers, Awards Managers and specialists;
  •  Managing Director for Research Services and Operations, who oversees research operations as well as managing the Research Service Coordinators (RSCs) and School Research Administrators (SRAs),
  • Director of the Office of Research, Training and Compliance, who oversees research training and compliance, and
  • Director, Research Finance and Administration, who is responsible for overseeing OCRO department financial matters, providing financial and administrative support to OCRO’s research support requirements, and serving as a Procurement Officer for Sponsored Programs to assist in implementing University policy and procedures related to procurement of goods and services on sponsored programs.

These Directors play a significant role in addressing and resolving a wide range of complex research-related issues including interpreting sponsor and University rules, regulations, requirements, policies and procedures. These Directors are also substantially involved in training, policy formulation, process improvement and related activities necessary to providing effective services to the University’s research community. Additionally, these Directors are also responsible for ensuring that this Handbook for Sponsored Programs is updated as needed including at least once per year, for ensuring that these changes are incorporated as necessary in the OCRO Department Desk Procedures and for ensuring that these changes are effectively communicated to GW’s research community.

2.2.7.2. OCRO Managers: OCRO has Contracts Managers, who negotiate terms and conditions of sponsored awards, and Awards Managers, who review and approve award set-ups, expenditures, and close-outs. These Managers are involved in managing the research process for the applicable portion of the research cycle within their respective areas.

2.2.7.3. Team Leaders: Team Leaders oversee the Research Service Coordinators and School Research Administrators for the respective Schools and Colleges. These Team Leaders play a vital role in improving communications, providing leadership to the OCRO team supporting the respective Schools and Colleges and facilitating prioritization of support and process improvement in OCRO research services. Team Leaders also maintain a research portfolio of their own.

2.2.7.4. Research Service Coordinators: RSCs are the Principal Investigator’s primary point-of-contact for handling “cradle-to-grave” responsibilities associated with sponsored research administration. Working under the guidance of a Team Leader, RSCs are proactively involved in anticipating requirements, addressing potential issues before they develop into problems, and supporting Principal Investigators, Chairs and Deans in their collective efforts to verify that GW achieves its objective for each sponsored program within their assigned portfolios. Among other things, RSCs provide assistance to Principal Investigators and staff in: reviewing sponsor solicitation requirements, preparing proposal budgets, reviewing and submitting proposals packages, explaining award requirements, reviewing and approving various award expenditures, submitting appropriate reports, assisting in the award close-out and  resolving any program or close-out issues including supporting post-award audits.

2.2.7.5. School Research Administrators: SRAs (or Grant Management Coordinators) are part of the respective teams providing a variety of financial, administrative and general support to certain Schools and Colleges.

2.2.8.  Office of Research Training and Compliance (ORTC)

The Office of Research Training and Compliance (ORTC), also reporting to the CRO, is responsible for centralizing and enhancing research-specific training and monitoring activities. The ORTC monitors research compliance and trains personnel on sponsored research programs. The ORTC is responsible for maintaining awareness of the rules and regulations related to sponsored research across the University. The ORTC develops training materials to educate researchers and administrative staff on a wide range of sponsored research requirements and compliance considerations under the OMB Circulars and the Code of Federal Regulations, among other sponsor guidelines and rules.

2.2.8.1. The Director of the ORTC: The Director of the ORTC plans and oversees the training of faculty and research staff on aspects of research administration, from proposal development and submission to award management and closeout to proper support for audit and Effort Certification requirements. The Director maintains awareness of general and emerging trends in research compliance matters to include federal regulatory and enforcement initiatives, and is responsible for providing notice of anticipated and actual changes in regulations affecting the GW research community.
The Director also oversees research-related compliance reviews in coordination with the Office of Health Research, Compliance and Technology Transfer (OHRCTT), the Compliance and Privacy Office, the Office of the General Counsel, Internal Audit, and other departments as appropriate.

2.2.8.2. The Compliance Monitor: The Compliance Monitor is responsible for compiling reports and supporting compliance monitoring and training.

2.2.8.3. The Training Coordinator: The Training Coordinator is responsible for ensuring that all mandatory and other research-related training is presented in a manner that is as accurate, convenient, efficient and comprehensive as possible. 

2.2.9. Office of Health Research, Compliance and Technology Transfer (OHRCTT)

The Office of Health Research, Compliance and Technology Transfer (OHRCTT) is responsible for administration and support of research safety and health related programs at the University. OHCRTT is responsible for compliance and education for the entire University in areas including laboratory safety, human subjects, animals, radiation, and recombinant DNA.
OHRCTT manages Medical Center research-related endowment funds and prepares annual reports to foundations and other donors on the use of these funds. Also, the Office coordinates the administration of internal research grant programs, i.e., Snyder Cancer program and the Faculty Research Enhancement Fund (FREF) program, in conjunction with Medical Center committees and officials.
OHRCTT is responsible for the administration of the Annual GW Health Sciences Research Day, bringing together colleagues from The George Washington University and Medical Center, The Institute for Genomic Research, the Children's National Medical Center and the Veterans Administration Medical Center to share ideas and research.
OHRCTT is headed by the Associate Vice President for Health Research, Compliance and Technology Transfer. For further information about research support and assistance available from OHRCTT including contact information, please refer to http://www.gwumc.edu/research.

2.2.10. Comptroller’s Office

The Comptroller's Office is responsible for management of the University's administrative financial operations which include the accounting, payroll, student accounts, grants and contracts, and administrative financial systems.  The Comptroller’s Office works closely with OCRO to review, manage and address a wide-range of research-related support activity.. For further information about research support and assistance available from the Comptroller’s Office, including contact information, please refer to http://www.gwu.edu/~gwco/contact.html.

2.2.11. Grants and Contracts Accounting Services (GCAS)

Grants and Contracts Accounting Services (GCAS) is located within the Comptroller's Office. It is responsible for sound financial management of sponsored program funds. GCAS is responsible for all post-award accounting including program close-out activities pursuant to the Identification and Treatment of Unallowable Costs Policy, http://my.gwu.edu/files/policies/Identification&TreatmentUnallowableCostsFINAL.pdf. GCAS also prepares and submits financial reports and invoices to sponsors.  The office processes sponsor payments in the forms of checks and electronic fund transfers from federal agencies including under financial instruments such as letters of credit. GCAS is responsible for monitoring accounts receivable, effort reporting and certification, program income if any derived from the program, such as proceeds of sales of supplies, equipment or research materials, and the financial closeout of grants and contracts. GCAS is also the primary office responsible for coordinating and responding to external financial audits and reviews and assists in the negotiation of the Facilities and Administrative (indirect costs or “F&A” rate) and fringe benefit rate proposals with the federal government. Responsibilities also include establishing and administering financial policies and procedures and coordinating the annual OMB Circular A-133 audit. 
The GCAS staff is organized into teams assigned to support specific schools and departments. The teams work closely with the appropriate Research Service Coordinators in OCRO to improve service to faculty and research administration staff. Each team consists of a Research Administrator (RA) and a Billing Reporting Specialist (BRS). The RA is responsible for the financial management of each award as it moves through its life cycle, for managing work load to contract requirements and for meeting the specific financial reporting terms of the agreement. The BRS provides billing and cash management services and our collection experts take an active role in preventing bad debt loss by working with GCAS staff, the Principal Investigator and the sponsor to monitor account activity.
GCAS is headed by the Director of GCAS. For further information about research support and assistance available from GCAS including contact information, please refer to http://www.gwu.edu/~gcas/gcasindex.htm

2.2.12. Research Operations Committee (ROC)
The Research Operations Committee (ROC) has been established to coordinate daily operating issues and tasks associated with GW’s research mission and operations. The ROC is chaired by the CRO and includes the leaders of each of GW’s research administration units.    

2.2.13 Supply Chain
The Supply Chain Organization is responsible for purchasing goods and services for the University including for all sponsored research programs. Supply Chain manages procurement including promoting competition as required by applicable sponsor requirements and provides a variety of related supporting services including materials management, administrative support and records management. Supply Chain also oversees GW’s P-card program. For further information about research support and assistance available from Supply Chain including contact information, please refer to http://www.gwu.edu/~supchn/Who_responsible.htm

2.2.14. Compliance and Privacy Office

The Compliance and Privacy Office assists in formulation and dissemination of policies and assists in the education of University employees in federal, state and local regulations.  The office also investigates allegations of non-compliance and recommends appropriate corrective actions, if necessary.  The Compliance and Privacy Office is headed by the Assistant Vice President for Compliance. For further information about research support and assistance available from the Compliance and Privacy Office including contact information, please refer to http://www.gwu.edu/~comply/privacy/privacy.html

2.2.15.  Office of Risk Management

The Office of Risk Management serves the University community by providing support, training and the leadership necessary to maintain a safe and healthy campus, to minimize liabilities and to protect University assets. The Office of Risk Management is run by the Director of Risk Management, http://www.gwu.edu/~riskmgnt/directory.cfm.

2.2.1.6.Office of the General Counsel

The Office of the General Counsel (OGC) provides advice and counsel to GW’s Board, Management, Faculty and Staff regarding matters related to research activities including interpretation of law and regulations as well as grants, contracts, cooperative agreements and other terms and conditions, rules and requirements associated with research at GW. The Office of the General Counsel is headed by Vice President and General Counsel.

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2.3. THE ADVANCEMENT DIVISION

The Advancement Division’s Corporate and Foundation Relations Office pursues grants from corporate and foundation sources. The Office works closely with the Office of the Chief Research Officer and Grants and Contracts Accounting Services to coordinate all proposals through a Research Services Coordinator as required by GW’s   Research Contracts and Grants Definition Policy , http://my.gwu.edu/files/policies/Grants&ContractsDef.FINAL.pdf.

The mission of the Advancement Division is to promote and sustain a philanthropic culture at GW through the engagement of individuals, corporations, foundations and other entities in common interests to produce partnerships that support the University's mission to provide excellence in education, research and scholarship.

Corporate and Foundation Relations personnel are available to help faculty and staff with the overall development of their proposal and submission, including assisting with the identification of potential funding sources, transforming program ideas into proposals to be submitted through a Research Service Coordinator in the Office of the Chief Research Officer and providing other support.

The Office also initiates approaches to corporate and foundation prospects, acts as a liaison with corporate and foundation program officers, acknowledges all corporate and foundation grants received by the University, works with faculty and staff to facilitate adherence to grant reporting requirements, and acts as the central office for coordination of approaches to foundations and corporations. The Corporate and Foundation Relations Office is another source of expertise for faculty and staff to utilize along with ensuring that all programs that seek funding from external sources are discussed with a Research Service Coordinator in the Office of the Chief Research Officer.

The Vice President for Advancement leads the Advancement Division.  

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2.4. FACULTY COMMITTEES

2.4.1. Faculty Senate Committee on Research

The Faculty Senate Committee on Research represents and advocates the point of view of all University faculty who engage in research activities in those matters that relate to these activities. For a list of current members, consult the Faculty Senate website, http://www.gwu.edu/~facsen/

2.4.2. Advisory Council on Research

The Advisory Council on Research is composed of faculty members and administrative representatives appointed each academic year by the Chief Research Officer, in consultation with the Deans. The ACR is the main research advisory group to the Chief Research Officer. The Council also collaborates with the Faculty Senate Committee on Research. The ACR administers the Research Enhancement Fund and is responsible for chartering and rechartering GW-affiliated centers and institutes, as well as for developing long-term planning strategies and for improving GW research policies. For a list of current members, consult the GW Research website, http://www.gwu.edu/~research/acr.htm

2.4.3.  University Committee on Research

The University Committee on Research, which advises the Chief Research Officer in the administration of the University Facilitating Fund (UFF) and Dilthey Faculty Fellowships, is a faculty panel of twelve voting members divided into three broad disciplinary divisions:

  • Humanities, Fine and Performing Arts;
  • Natural Sciences, Mathematics, and Engineering; and
  • Social Sciences, Education, and Business.

Committee members serve three-year terms on a staggered rotation basis and are not allowed to submit proposals for the UFF or Dilthey Fellowship during their service.  For a list of current members, consult the GW Research website, http://www.gwu.edu/~research/ucr.htm

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