Financial Issues, Grants & Contracts Management

Financial Issues, Grants & Contracts Management

Research and Development

Areas of Risk

Financial Issues, Grants & Contracts Management

  • ARRA Audits / reporting
  • Transfer from Pre-award to post-award
  • Cost transfers
  • Closing out of expired grants
  • Coordination of grants
  • DATA Act
  • Failure to bill all costs timely
  • Failure to follow bidding process
  • Failure to monitor grants
  • Failure to recognize or misuse of program income
  • Grant acceptance process
  • Grant commitment
  • Improper disposition of equipment
  • Inadequate grants information system / migrating to new systems (paper to electronic)
  • Inadequate institutional policies related to grants
  • Inappropriate charges to grants from service or re-charge centers
  • Insufficient post-award monitoring
  • Matching and cost-sharing
  • Monitoring of off-site grants
  • NIH salary cap
  • No cost extensions
  • Not including required clauses in grants and contracts for privacy and data protection
  • Ownership and tracking issues of equipment with sub-recipient
  • Tracking, reporting, and appropriateness of payments to protocol participants

Animal Research

  • Animal protection
  • Climate control
  • Commitment to single supplier
  • Conflict of interest
  • Containing epidemics in colonies
  • Contingency procedures
  • Controlled substances in animal research
  • Difficulty in recruiting members for the IACUC
  • Disaster recovery
  • GLP research
  • Disposal of biohazard waste
  • Failure to comply with IACUC regulations
  • Failure to protect research data
  • Inadequate veterinary care
  • Lack of adequate facilities, i.e. cage sizes
  • Lack of trained staff
  • Loss of AALAC accreditation
  • Loss of reputation due to perceived improper testing on animals
  • PETA
  • Safety of workers
  • Sanitation
  • Security
  • Unapproved research involving animals being conducted

Institutional Review Board

  • Appropriate documentation of minutes, approvals, etc.
  • Back log of protocol review
  • Conflict of interest
  • Continuing reviews not being adequately performed / timely
  • Managing and dealing with conflicting IRB feedback
  • Reliance upon other IRBs
  • Institutional specific requirements (e.g. Catholic ethical and religious directives)
  • Oversight over recruitment activities
  • Foreign language requirements (beyond just consent, but throughout the study)
  • Failure of PI to submit a change to the protocol
  • Failure to ensure privacy safeguards are in place
  • Failure to monitor and report adverse events
  • Failure to properly bill the research protocol
  • Failure to review safety bulletins
  • Improper conduct of human subjects research or unethical experimentation
  • Inadequate informed consent process
  • Inadequate or no review by the IRB
  • Inadequate protection for vulnerable populations
  • Inadequate qualifications
  • Inadequate staffing
  • Inappropriate reporting structure
  • Lack of independence of IRB
  • Payments to participants
  • Time constraints for IRB board members
  • Non-compliance with federal regulations on human subjects research (exemptions, waivers of consent, etc)
  • Not having external members
  • Protection of research data
  • Refund of residual funds when required by contract
  • Resistance to outside review
  • Too much control by one person
  • Training on IRB responsibilities (members)

Office of Sponsored Projects

  • Back log of proposal reviews
  • Budget justification for expenditures
  • Bridge funding not properly approved
  • Communication of outside audits/reviews to OSP
  • Communication between pre and post-award
  • Contract reviews
  • Contracts signed by personnel who are unauthorized
  • Inadequate communication with principal investigators
  • Inadequate staffing / time to properly review applications
  • Insufficient effort to attract research funding
  • Lack of analysis of contracts (financial, including any cost sharing)
  • Review of proposals that require new FTEs and a plan for the FTE after the project is completed (esp. in a unionized organization)
  • Over-commitment of personnel
  • PI not submitting the pre-award documentation for review before beginning research
  • Proposals with poorly developed cost budget or not including facilities and administrative (indirect) costs
  • Research interests that do not match funding availability
  • Strategic acceptance of grants

Research Integrity

  • Falsification of research data
  • Inadequate background/health checks of visiting scientists
  • Inadequate documentation of research
  • Ensuring scientific value / quality (scientific review)
  • Balancing administrative review / compliance requirements and encouraging research
  • Inadequate or inappropriate acceptance of research subjects
  • Inadequate peer review process
  • Inadequate protection of research data
  • Inadequate protection of research subjects
  • Inadequate supervision of research
  • Inappropriate action to address/investigate allegations of scientific misconduct
  • Investigators leaving and coming with data, people, materials, etc.
  • Loss of research data
  • Plagiarism
  • Policies on inquiries and investigations of researcher's conduct not in compliance with federal regulations
  • Undisclosed financial conflict of interest

Technology Management

  • Define ownership rights
  • Export controls
  • Failure to commercialize faculty research
  • Failure to properly structure agreements
  • Failure to protect intellectual property
  • Failure to pursue copyrights or patents
  • Inadequate management of patent expenses
  • Ineffective management of start-up companies
  • Infringement on intellectual property
  • Insufficient efforts in licensing and technology transfer
  • Invention disclosure
  • Lack of timely or accurate royalty distributions
  • Material transfer agreements
  • Non-compliance with invention disclosure requirements
  • Patents and royalties, tracking payments
  • Researchers leaving with intellectual property

Training in the Responsibility Conduct of Research

  • Failure to track who has taken training
  • Inadequate/ineffective training
  • Inappropriate use of real data in training
  • Lack of consequences for faculty not attending the training
  • No documentation of training

Biosafety

  • EHS failure to monitor labs
  • Emergency preparedness to ensure protection of population
  • Failure to comply with regulatory requirements
  • Failure to include external member on IBC
  • Failure to monitor personnel exposures
  • Failure to report incidences
  • General lab safety procedures
  • Inadequate inspection processes
  • Inadequate labeling
  • Inadequate management of hazardous materials
  • Inadequate public relations management
  • Inadequate staffing and under-funding of EHS office
  • Inappropriate disposal
  • Inappropriate transfer
  • Ineffective management of infectious organisms
  • Lack of documentation
  • Management of recombinant DNA
  • Physical controls over select agents and toxins
  • Physical security/theft
  • Proper reporting of incidents
  • Protection of the environment
  • Untimely or inappropriate response to accidents or other incidents

1 | Page