The Challenges of Compliance:

1
The Challenges of Compliance

• One Universitys approach to creating a
  comprehensive program for compliance.
• NCURA Region 1 Spring Meeting
• Portland, Maine 5/8/2006
• Patrick Fitzgerald, Director, Office of Sponsored
  Programs MIT
• Nuala McGowan, Senior Compliance Specialist - MIT

2
Compliance Misconduct

• Univ. of Connecticut January 2006 - 2.5
  Million
• Over-billed the government for research.
• Mayo Clinic - May 2005 - 6.5 Million
• Government was charged for research unrelated to
  the NIH grants it received.
• Univ. of Alabama at Birmingham - April 2005 -
  3.4 Million
• Research work overstated Medicare billed for
  research funded elsewhere.
• Harvard University - June 2004 - 2.4 Million
• Government was billed for salaries and expenses
  unrelated to federal grants.
• Johns Hopkins University - February 2004 - 2.6
  Million
• Faculty time and effort devoted to NIH grants was
  overstated.
• Northwestern University - February 2004 - 5.5
  Million
• Researchers spent less time on NIH-sponsored
  projects than they reported.

Ref Report on Research Compliance /WSJ
3
Background

• The Environment at MIT
• MIT campus had 570 million in research volume
  for FY 2005
• Estimated 1500 people involved in research
  administration related activities at least
  part-time
• Titles vary from dept to dept
• Commitment to research administration variesfrom
  small percentage of effort to 100

Includes Professors, DLC and central admin.
does not include research staff (Post-Docs,
Research Scientists, etc.)
4
Background

• Administration of research has become more
  complex and challenging at MIT
• More research volume
• Changes in funding/regulatory environment
• New major enterprise administrative systems (SAP,
  COEUS, Data Warehouse)
• Migration to Grants.Gov (electronic instead of
  paper)
• Need for improvement to help faculty,
  administrators, and MIT overall
• Improve efficiency and effectiveness (staff isnt
  increasing)
• Greater expectations regarding accountability

5
Research Administration Compliance Program (RACP)
Nuala McGowan Senior Compliance Specialist, RACP
nuala_at_mit.edu
6
Background

• Replaced traditional Department Review Audits in
  2005
• Driven by increased emphasis on research
  compliance issues nationwide
• Strong emphasis on training and process
  improvement
• Overall goal is to help Departments meet
  regulatory requirements and strengthen controls
• Partnership/Common goals

7
Research Administration Compliance Program
(RACP) Objectives

• Monitoring Program
• Designed to detect specific exceptions, identify
  potential problems and provide trend data for
  assessing the effectiveness of internal controls.
  
• Internal Control Assessment/Site Visits -
  Identify and address control weaknesses within
  the DLCs through on-site visits/assessments.
• Consultation
• Assist DLCs in process improvement initiatives
  and corrective action measures

8
Site Visits

• Control Assessment Interview
• Review monitoring reports
• Perform limited manual testing
• Focus on training and awareness
• Issue an observation memo to department
• We are here to help!

9
Site Visits Areas Covered

• Cost Allowability
• Salary Certification
• Equipment Purchased
• Cost Transfers
• Procurement Card
• Service Centers
• Cost Sharing
• Period of Availability

• Human Subject training
• Conflict of Interest Reporting (NIH/NSF)
• Monthly Statement Review process
• Federal Reporting
• Training Awareness

10
Monitoring Program

• Series of Data Warehouse Reports
• Red Flag Areas
• Uses
• As part of Site Visits
• On-going Institute-wide Monitoring Program (TBD)
• Self Monitoring
• Executive Information System (EIS)
• Quarterly Monitoring Reports

11
Monitoring Areas Covered

• Account Balances (to include Overruns)
• Charges to unallowable GL accounts
• Charges outside period of availability
• Cost transfers
• Human Subject training
• Equipment purchased at end of award period
• Procurement Card purchases
• Outstanding financial closeout
• Miscellaneous revenue
• Scan for Unallowable Costs
• Fabricated Equipment

12
EIS Dashboard (Executive Information System)
13
QA

• Questions and Answers

14
Research Administration Improvement Initiative
(RAII)
Patrick Fitzgerald, Director, Office of Sponsored
Programs pwf_at_mit.edu
15
Objectives of RAII
Improve effectiveness and efficiency of research
administration (RA) activities in DLCs and
central administration at MIT
Processes and policies
Roles
Training
Technology Resources
Develop compre-hensive training system improve
training materials and programs
Under-stand RA roles and develop effective
organi-zational themes, models
Create, improve, document, and com-municate
processes, policies and respons-ibilities
Build suite of systems, tools and reports that
support RA

• Ensure continued staffing with knowledgeable
  administrators
• Effective and efficient organizational structure
• Tools and systems that are helpful and utilized

• Reduction of administrative burden and improved
  services for faculty
• Regulatory compliance without compro-mising
  ability to do outstanding research

Outcomes
16
RAII Team Structure
Steering Committee Co-Chairs Patrick Fitzgerald
(OSP), Ron Hasseltine (Science)

• John Donahue (OSP)
• Robin Elices (ASO)
• Gill Emmons (CAO)
• Deborah Fisher (Audit)
• Tim Gordon (Audit)
• Sheila Kanode (Engineering)
• Colleen Leslie (Center Cancer Research)

• Diane MacDonald (Broad Inst.)
• Doreen Morris (Provost)
• Eileen Nielsen (OSP)
• Charlene Placido (Provost/Research)
• Marilyn Smith (Provost/Research)
• Judith Stein (HR)

Faculty Advisory Committee

• Steve Buchwald
• Steve Eppinger
• Karen Gleason (Chair)
• Jackie Lees
• Ken Oye
• Miklos Porkolab
• Alex Slocum
• Larry Vale
• Jacob White
• Victor Zue

Sub-teams
1. Roles and organ-izational structure
2. Policies and processes
4. Technology Resources
3. Training

• Team lead for each sub-team from Steering
  Committee
• Sub-team members comprised of Steering Committee
  members as well as other community members

Project administrator Kristen Shikes Project
manager Cecelia Wardle
17
RAII Sub-Team Activities
Sub-Team
Key Activities and Deliverables

• Roles and Organizational Structure
• Policies and Processes

• Develop roles and responsibilities accountability
  matrix
• Analyze life of grant segmented in 12 phases
• Develop framework for characterizing existing
  Research Administration departmental models
• Develop recommendations for enhancements to
  existing organizations and structures
• Review report with Steering Committee and
  Sponsors and develop action plan/next steps
• Compile RA policies, understand and prioritize
  gaps
• Develop recommendations to create new or improve
  existing RA policies and processes
• Catalog (on website), document, and communicate
  existing policies

18
RAII Sub-Team Activities
Key Activities and Deliverables
Sub-Team

• Develop and improve tools that support RA (e.g.,
  forecasting, COEUS, Research Administration
  portal)
• Integrate research data and develop standard
  reports
• Assess overall RA training needs and curriculum
  outline
• Develop new courses and non-course training
  materials
• Create web based fundamentals training
  Specialized Training for Administrators of
  Research
• Develop training manual for more experienced
  staff
• Develop implementation plan

• Technology Resources
• Training
• General
• STAR Program

19
Example of a RAII spin-off project

• Mechanical Engineering (ME) Department
• Background
• Ocean Engineering merged with ME in Jan 05
• New Department has 75 faculty and 25 million in
  research volume
• Decentralized model for Res Admin support
• Faculty heavily involved in Res Admin activities

20
Example of a RAII spin-off project

• New Organizational Model for Mechanical
  Engineering (ME) Department
• Satellite office of central OSP located in dept
• Dual reporting OSP Director and Dept Head
• Manager and Departmental Research Administrators
  dedicated to support of ME faculty
• Full-time Research Admin specialists replace
  part-time support staff

21
QA

• Questions and Answers