Research Financial Compliance Meeting for Business and Grant Managers November 11, :30 – 4 pm Room 3031 Purple Zone Duke South Agenda Faculty Effort Supporting DUHS Compliance Office Updates (things you might like to know!)

Compliance Review Services Research Financial Compliance Evaluation A Research Financial Compliance Evaluation is a review of certain identified risk areas that include a number of the “High Risk Areas” of the Office of Inspector General (OIG) Work Plans: Effort reporting and level of commitment, National Institutes of Health (NIH) Career (“K”) Award effort commitments, NIH Salary Cap and cost sharing, Administrative and clerical salaries – charges are not allowable to federal grants absent specific circumstances justification (CAS forms), Allowability and allocability of charges to grants, Cost transfers – analysis of whether these transfers are appropriately documented, allowable and timely, Reconciliation, supporting documentation and accounting practices, Endowment fund usage. It will also include Health Insurance Portability and Accountability Act (HIPAA) Privacy and IT Security Reviews: Occupational Environmental Safety Office (OESO) records for HIPAA training record completeness, Walk-through reviews of research space to assess compliance with the Privacy Regulations, HIPAA IT Security (done in partnership with the Office of Internal Audit). We want to help you identify any potential risk areas that could cause compliance problems for your Department, Institute, Center or School and help you to resolve those issues.

Research Financial Compliance Reviews Departments, Institutes and Centers Clinical Departments  Medicine  Ophthalmology  Pediatrics Clinical Departments  Anesthesiology  Psychiatry  Surgery Clinical Departments Radiology Bioinformatics and Biostatistics Community and Family Medicine Obstetrics and Gynecology Radiation Oncology Basic Sciences  Neurobiology Basic Sciences  Pathology  Pharmacology and Cancer Biology  Biochemistry Basic Sciences Cell Biology Molecular Genetics and Microbiology Immunology Institutes and Centers  Comprehensive Cancer Center Institutes and Centers  Duke Translational Medicine Institute (DTMI) DCRI DTRI DCCR DCRU  Institute for Genome Sciences and Policy Institutes and Centers Brain Imaging and Analysis Center Center for Clinical Health Policy Research Center for the Study of Aging and Human Development Sarah Stedman Nutrition Center School of Nursing

Research Financial Compliance Reviews Departments, Institutes, Centers and Schools Clinical Departments Obstetrics and Gynecology Radiation Oncology  Radiology Clinical Departments Bioinformatics and Biostatistics Community and Family Medicine Dermatology Medicine Clinical Departments Ophthalmology Basic Sciences Cell Biology Molecular Genetics and Microbiology Basic Sciences Immunology Institutes, Centers, Schools Deane Institute School of Nursing Institutes, Centers, Schools Global Health Institute Sarah Stedman Nutrition Center Duke Graduate Medical School - Singapore Institutes and Centers Brain Imaging and Analysis Center Center for the Study of Aging and Human Development Comprehensive Cancer Center

What is being done well? There are fewer “Significant Observations” in the RFC section! Delinquent effort reporting reduced Better management of: NIH Cost Sharing / Salary Cap NIH Career (K) Award (Effort and Salary Cap)

HIPAA Privacy/IT Security Issues Develop a Formal Process to Identify and Track ePHI Need to have a process in place to identify and track where PIs are storing electronic Protected Health Information (ePHI). Need a process to inventory which PIs and protocols capture or create PHI. Develop a system to identify where ePHI will be stored for all initial protocols. Verify and review compliance for the location on an annual basis when protocols are submitted for renewal. Create or Update Information Security Operations Plans (ISOPs) Certify new and existing systems to achieve compliance. Update ISOPs when changes occur.

Research Financial Compliance (RFC) Issues Unallowable Expenses or Questionable Charges Recommendation - Run (R3/SAP) – SPQuestGL is Unallowable on Federal Codes. Insufficient Documentation to Support Charges to Grants Business Meetings (Entertainment vs. Meeting). Federal Express and Postage. Travel Expenses for Individuals with No Funded Effort on the Project. Monthly Reconciliation of Grant WBS Cost Elements

Administrative Effort Supporting General Operations (Excluding Tenure/Tenure- Track Faculty) (Valid For: DUHS, Univ) Represents salary expense for exempt personnel (excluding tenure/tenure-track faculty - use ) in academic departments who provide administrative support, where such effort cannot be specifically identified to either the instruction/training/departmental research or sponsored research activities. Note: An individual's salary on a single cost object may not be divided between G/L accounts and Use this G/L account for exempt personnel in all non- academic departments who provide administrative support of the overall operations of the Univ Administrative Effort Supporting Instruction/Training/Departmental Research (Excluding Tenure/Tenure-Track Faculty) (Valid For: Univ) Represents salary expense for exempt personnel (excluding tenure/tenure-track faculty - use ) in academic departments whose administrative effort is exclusively in support of the instruction, training, or departmental research activities. Note: An individual's salary on a single cost object may not be divided between G/L accounts & Administrative Effort Supporting General Operations (Tenure/Tenure-Track Faculty Only) (Valid For: DUHS, Univ) Represents salary expense for tenure/tenure-track faculty who provide administrative support that cannot be specifically identified to either instruction/training/departmental research or sponsored research activities. This includes deans and departmental chairpersons. An individual's salary on a single cost object may not be divided between G/L accounts and Administrative Effort Supporting Instruction/Training/Departmental Research (Tenure/Tenure-Track Faculty Only) (Valid For: DUHS, Univ) Represents salary expense for tenure/tenure-track faculty whose administrative effort exclusively supports instruction, training, or departmental research activities. An individual's salary on a single cost object may not be divided between G/L accounts and Research Financial Compliance (RFC) Issues Watch for Incorrect GL Account Coding for Salaries!

Research Financial Compliance (RFC) Issues Expired WBS Cost Elements When requesting closure, make sure account is at zero. There may be outstanding “revenue” issues. Lack of Institutional Biosafety Committee Registrations Look for DNA Usage on DPAF at Time of Proposals. Does the PI have a registration date/number? Are they included on someone else’s registration? Mandatory Compliance Training Compliance Orientation must take place within 90 days of employment. Annual updates required for all. Check your Compliance Exception Reports!

Mark your calendars! Research Financial Compliance Meeting Tuesday, February 17, 2010 Room 3031 – 2:30-4 pm

Things about November 11 th November 11 th is called Veterans Day since 1954 (formerly known as Armistice Day). It is the 315 th /316 th (leap year) day of the year – 50 days left in the year – Mayflower Compact signed in (what is now) Provincetown Harbor – Washington was admitted as the 42 nd state – World War I ends with the signing of the armistice agreement – Knute Rockne told his Notre Dame football team “Win one for the Gipper.” (ND beat Army, 12-7) 1966 – NASA launched spaceship Gemini – The Church of England voted to allow women to become priests.