research compliance procedures
This past year has seen very dramatic changes in how sponsored research is
administered at Yale. One of the keys to success, he points out, is training and communication.
In fact, training of faculty and support staff regarding the financial administration
of sponsored research projects is one of ORA’s major initiatives, he
notes. Rudczynski and Alice Tangredi-Hannon, Yale’s research compliance
officer, in collaboration with others around campus, developed training for
both faculty and staff. According to Rudczynski, since January nearly 1,700
have already completed training.
T H I S
The University’s newly formed Office of Research Administration (ORA),
part of the Division of Finance and Administration led by Vice President Shauna
King, has embarked on the challenging mission of examining and overhauling the
broad array of systems, policies and procedures that Yale uses to manage sponsored
research grants and contracts.
All financial and administrative aspects of Yale’s research compliance
responsibilities are within the scope of this review, and some have already been
significantly upgraded, according to King. “This has been an enormously
complex and demanding process,” she says, “but no one has any doubts
about how important it is. President Levin has made it clear that our goal is
to be at the top tier of research universities in terms of these compliance issues,
and we are all committed to that goal.”
Andrew B. Rudczynski came to Yale a year ago to lead ORA as associate vice president
for research administration. Almost immediately after his arrival, he oversaw
a major revision to Yale’s policies and procedures for reporting effort
on federal projects, as well as new procedures for review and approval of cost
transfers.
“These are two of the most critical areas in sponsored research administration,” Rudczynski
says, “and we’ve been working very hard to get these processes working
effectively and efficiently.”
Training is not a one-time event, but, rather, it is a continuous process, notes
Rudczynski. To help faculty and staff to keep key research compliance principles
in mind, ORA created a convenient pocket guide summarizing the most important
principles in this area. ORA also devotes a considerable portion of its resources
to continuing education through communication with faculty and staff about research
administration policies and practices, and changes in those policies and practices
in research administration. ORA distributes a monthly newsletter, publishes periodic
updates on important research compliance subjects and holds monthly “brown
bag” sessions on a wide variety of grants administration topics.
Although effort reporting and cost transfers were at the top of ORA’s list of critical compliance topics, the office
is in the process of reviewing and updating all policies and procedures surrounding
research administration. “Those policies have to be clear and well-defined,
we have to have the right processes and tools at our disposal, and we have to
be able to monitor and measure compliance,” Rudczynski says.
It is also important to have the right organization in place, he notes. One of
the most important organizational changes made was to bring together under single
leadership the grant and contract administrative offices (GCA) on the Central
Campus and at the School of Medicine. Furthermore, Rudczynski says, a wall between
that merged office and the Office of Grants and Contracts Financial Administration
(GCFA), which administers research funding after it is received, was literally
taken down to foster greater communication between the two offices.
The integration of these organizations will help the University better manage
the complete “life cycle of the award,” rather than just the securing
of research grant funding and the “closing out” of an award, he says.
Over the next few months additional process and informational initiatives will
be announced by GCA and GCFA.
The 100-Day Plan, launched in the fall of 2006, significantly increased compliance
awareness, enhanced polices and procedures, standardized key practices across
departments, tightened controls surrounding cost transfers and began the rollout
of new tools to support research compliance.
New systems that are being implemented include a Web-based process for effort
reporting to replace the current paper process. (See related story.) A pilot
of the Web-based effort reporting system is scheduled for later this fall with
full deployment anticipated throughout the year and into the early part of next
year. The online effort certification system is a secure application for reviewing,
adjusting and certifying effort by principal investigators on sponsored projects.
In addition, SciQuest, a new electronic purchasing tool, is now the required
approach for most routine purchases by researchers and a Web-based smart form
has been introduced to facilitate the Conflict of Interest process.
All the changes have been made following consultation with senior University
administration, research faculty and support staff, Rudczynski notes, adding
that the policies and practices of GCA and GCFA offices have to ensure compliance
and accountability with regulations governing sponsored research while balancing
that with “the reality of how science is done.”
While overseeing the revamping of research administration through ORA, King — who
joined the University as vice president of finance and administration in 2006 — has
been implementing other major administrative changes in support of the teaching,
learning and research mission of the University.
In January of 2007, King established an Office of Business Transformation to
help lead the ongoing improvements of Yale’s financial and administrative
services, particularly those involving sponsored projects. What is envisioned,
she says, is an integrated set of procedures, tools and information to support
the scientific research processes at the University.
“While this will take a long-term, sustained effort to complete,” King
notes, “many improvements will be felt by the research community as time
passes. In the end, we expect Yale to truly be best in class when it comes to
research support.”
Last April, King announced that all of the University’s business managers
would report to the vice president for finance and administration as well as
to the dean, director or chair of their units. At the same time, King named Stephen
Murphy as associate vice president for business operations to oversee the business
managers and work with them to identify both common and unique needs related
to their work and to design and implement procedures and tools to meet those
needs.
“To design solutions that ensure compliance with federal regulations that
are workable at a department level and in a laboratory, require all of us to
work together,” says King. “With this new organization in place,
we can capitalize on the combined wisdom of all the support staff. While there
are many areas the new business operations group will work on, none are more
important than getting the right solutions in place to support our research enterprise.”
King last summer appointed Gwendolyn Sykes, who had served since 2003 as the
chief financial officer for the National Aeronautics and Space Administration,
as the University’s chief financial officer. In that post, Sykes is responsible
for the financial stewardship of the University, including budgeting, accounting
and transaction management, financial reporting, internal control and the integrity
of financial information.
“The accuracy of core financial transaction systems and our ability to
provide meaningful financial reporting to researchers is pivotal,” King
says, “and this piece of the overall research compliance effort will benefit
greatly from Gwen’s experience.”
For more information about Yale’s ongoing financial and administrative
initiatives, visit the website of the Office of Finance and Administration at
www.yale.edu/fa.
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Campus Notes
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