Compliance

Procurement and Business Services Statement of Compliance

Stephen F. Austin State University will comply with OMB Circular A-110 Procurement Standards as defined in Subpart C, Post-Award Requirements, Section .40-.48 for all federal grant funded procurement until September 1, 2016.  Effective September 1, 2016, Stephen F. Austin State University will comply with applicable procurement standard as defined in 2 CFR 200, “Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.”

See also:

• Procurement and Business Services Federal Grant Funded Purchases for Uniform Guidance Implementation
• Procurement policies

CITI Research Ethics Training Programs

SFA subscribes to the CITI Program which provides research ethics education courses in the areas of Human Subjects Research (HSR), Health Information Privacy and Security (HIPS), Responsible Conduct of Research (RCR), Financial Conflict of Interest (FCOI), and Animal Care and Use (ACU), and other areas of interest. All SFA faculty, staff and students are encouraged to create a CITI account and register for applicable CITI courses for the purpose of their research, activities and coursework.

As stated in policies 7.19 Misconduct in Scholarly or Creative Activities and 8.7 Misconduct in Federally Funded Research, SFA strives to create a climate that promotes faithful adherence to high ethical standards in the conduct of scientific research, scholarship, and creative activities without inhibiting the productivity and creativity of the academic community

Faculty scholars and other personnel at SFA are expected to adhere to the highest ethical standards for all research and scholarly work. It is the responsibility of every research investigator to maintain the integrity of research projects, including maintaining an auditable record of experimental protocols, data, and findings.

Conflicts of Interest (FCOI) (financial and nepotism)

It is the responsibility of all employees to disclose anything that is, or may appear to be, a significant financial interest that could directly or indirectly affect the design, conduct, and/or reporting of research and/or affect professional judgment in the conduct of sponsored activities. Note that FCOI disclosures apply to all external awards. See policies 8.2 Financial Conflicts of Interest in Sponsored Activities and 11.16 Nepotism.

Whistleblower Protection

This statute provides expanded protection for employees that report evidence of wrongdoing to specific officials, which includes mismanagement of funds, abuse of authority, a danger to the public health, and a violation of law.

Report Suspected Fraud, Waste, and Abuse and Research Misconduct

The University's portal for anonymous reporting is called EthicsPoint. See policies 2.6 Ethics and 2.7 Fraud.

Drug-Free Workplace

Each employee that participates on a federal grant or other federal award must comply with the SFA's Drug-Free Workplace policy and must make the proper notifications to SFA as a condition of employment. See policy 13.11 Illicit Drugs and Alcohol Use.

Protection of Human Research Subjects (IRB)

The Institutional Review Board for the Protection of Human Subjects (IRB) is charged with the responsibility for reviewing and approving research involving the use of human beings as subjects of research activities in accordance with the Department of Health and Human Services (DHHS) guidelines. Note that most agencies require that the IRB review and approve protocols prior to proposal submission. See policies 8.4 Human Research Subjects Protection and 8.8 Payment to Human Research Subjects.

Animal Care and Use (IACUC)

University policy requires that all projects involving the use of live vertebrate animals must be reviewed by the Institutional Animal Care and Use Committee (IACUC) prior to the initiation of research. Note that most federal agencies now require that protocols using animals be reviewed and approved by the IACUC prior to proposal submission. See policy 8.6 Institutional Animal Care and Use Committee, IACUC.

Export Control Regulations

Export control regulations are federal laws that prohibit the unlicensed export of certain goods, products, or information for national security and to protect trade. Project directors should review this section prior to hiring non-US citizens, traveling to a foreign country, or shipping items to a foreign country.

Biosafety and Select Agents

Research involving biohazards, such as novel recombinant DNA, blood-borne pathogens, and carcinogens requires protocol review in compliance with National Institutes of Health guidelines prior to the submission of a proposal or the start of the research. See policy 8.9 Recombinant DNA and/or Infectious Biohazards in Teaching and Research.

Environmental Safety and Health/Radiation

The University Radiation Safety Officer is responsible for ensuring the effective use of safety measures relating to radioactive materials and radiation devices, consistent with the Radiation Control Program of the Texas Department of Health, the Texas Radiation Control Act, and the Federal Radiation Control for Health and Safety Act of 1968. See policy 13.17 Radioactive or Radiation-Producing Materials of Equipment.

See 41 U.S.C. 4712 and Federal Register/Vol. 78, No. 189.

The federal government provides almost $450 billion annually in Federal Assistance Agreements to support national infrastructure programs, scientific research, and cultural enrichment activities. Most of these dollars are awarded in the form of grants.

If you are involved in a federally funded grant, you have a responsibility to the government and to the university to be a good steward.

How can you be a good steward of federal funds and protect SFA?

• Use the funds entrusted to you to carry out the goals and objectives identified in your grant.
• Be sure that you keep thorough, accurate records, so you can account for costs and justify what you have spent.

Misuse of grant funds constitutes theft and is subject to criminal and civil prosecution.

Five most common federal violations resulting from misuse of grant dollars:

1. Embezzlement
2. Theft or bribery
3. False statements
4. False claims
5. Mail fraud and wire fraud

Four most common offenders:

1. Grant recipients, company officers, business partners, board members, managers
2. Bookkeepers, financial staff, and employees
3. Contractors and subcontractors
4. Consultants

Three most common fraud scenarios:

1. Claiming personal expenses as grant expenses
2. Billing for costs that have not been incurred or are not tied directly to the grant
3. Inflating labor costs/hours or charging for fictitious personnel, contractors, or consultants

How can you help detect and prevent grant fraud, waste, and abuse at SFA?

• Learn what is permissible on your grant, as some grant regulations vary by program.
• Become familiar with and follow university policies related to ethics, fraud, purchasing, accounting, human resources, and records retention. University Policy Manual
• Seek training for yourself and any coworkers.
• Access SFA’s system to report suspected grant fraud, waste, or abuse.
• Use SFA’s Office of Research and Sponsored Programs as a resource. We offer practical grant management training/tips and can advise you when you encounter difficult issues.
• Ask yourself whether an action would stand up to the scrutiny of reporters and auditors.

Reference: Grant Fraud: A Message from the National Procurement Fraud Task Force