Federal Compliances and Assurances
James Madison University complies with all federal and related sponsor
requirements concerning the funding and management of sponsored programs.
In recent years the complexity of regulatory oversight has increased dramatically,
and the potential liability of both the faculty member and the University
has likewise increased. Additional information concerning these items
is available from Sponsored Programs Administration. Specifically, faculty should be
aware of the following issues:
OMB Circulars-
Federal Guidelines regarding the submission and procurement of external
funding.
Conflict of Interest:
Faculty should be aware that federal restrictions limit the extent to
which personal financial interests can be related to the conduct of federally
funded research. NIH and NSF have issued rules governing the disclosure
of potential conflict. The University has developed a policy which will
provide further advice and systematic review of potential conflict issues.
(See Policy 2203
Investigator Significant Financial Interest Disclosure Policy for Sponsored
Programs)
Debarment and Suspension:
In submitting applications to the federal or state government, the faculty
member certifies that he/she is not currently debarred or suspended from
conducting business with the government.
Delinquency in federal debt :
The faculty member certifies that he/she is not currently delinquent
in federal debt, including outstanding student loans or IRS delinquencies.
Drug free:
To comply with the Drug-Free Workplace Act of 1988, the Commonwealth of
Virginia has developed a "Policy on Alcohol and Other Drugs."
In addition to the Drug-Free Workplace Act of 1988, the University, as
an institution of higher education receiving federal funds, must comply
with the requirements of the Drug-Free Schools and Communities Act Amendments
of 1989. (See
Policy 1110 Alcohol and Other Drugs)
Lobbying:
The faculty member certifies that he/she has not attempted to influence
any member of Congress in support of the proposed activity, nor has paid
another party to lobby on behalf of the proposal.
Student Unrest:
The faculty member certifies that he/she did not engage in any impediment
of access to educational facilities or otherwise impede academic personnel
from performance of their duties after August 1, 1969. This policy is
the so called "sit-in" legislation that prohibits individuals
from receiving federal funds if they have actively engaged in "sit-in's"
after the August date.
Retention of Data:
Research data must be permanently recorded and appropriately authenticated
by the investigator at the time the research is conducted. These data
will be retained by the investigator for at least ten years (or for a
longer period, if specified in a federally funded project). When the investigator
leaves the institution, a copy of the research data records will be retained
by the institution; the records to be kept will be those considered appropriate
by the investigator and the department head or school director.
Research,
Biohazards, Recombinant DNA:
Institutional committees meet regularly to review and approve projects
that conduct research involving animal subjects, biohazards, or recombinant
DNA. (See
Policy 2204 for Institutional Biosafety)
Human Subjects:
The Institutional Review Board (IRB) provides oversight for all projects
involving research with human subjects. It is important to note that the
IRB reviews all projects, not just externally supported activities. These
reviews include student research as well. (See
Policy #I:01:06 The Institutional Review Board on the Use of Human Subjects
in Research)
Acknowledgment
of Federal Support:
All federal funding must be acknowledged in publications, press releases,
and any other external distribution of information concerning federally
funded projects. Please contact Sponsored Programs for assistance or clarification.
Purchasing:
Federally funded projects are restricted by law to comply with purchasing
standards. These standards may include documentation of bid, Fly American,
Buy American, utilization of women/minority owned businesses, compliance
with Labor Standards, etc. While the principal investigator is the first
line of review for expenditures, the compliance requirements of purchasing
are best reviewed by the Purchasing Office. Likewise, any contractual
work should be approved by Purchasing. |
