Compliance and Safety
Research and Sponsored Programs is charged with oversight of faculty and staff in the ethical and safe conduct of sponsored projects and research. Individuals proposing research projects which anticipate the use of human subjects, carcinogenic or toxic compounds, vertebrate animals, recombinant DNA, pathogens, and/or radioactive materials should contact Research and Sponsored Programs for further information about any of these areas.
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.”
- 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.
Ethics in Sponsored Projects
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.
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
Health and Safety
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.
Stephen F. Austin State University is committed to complying with local, state and federal laws, rules, and regulations, as well as university policies and procedures. If you have cause to believe that there has been a violation of any policy, regulation, or law, you are encouraged to report it to your supervisor, department head, college dean, or a director or administrative officer in the relevant office (ORSP, Controller, Audit Services, Provost and VPAA, etc.). If you prefer, you can use a confidential reporting service called EthicsPoint that can be accessed through a web portal or by calling 866.294.9539. University employees are prohibited from retaliating in any manner against an individual that makes a report in good faith and these protections cannot be waived.
The Whistleblower Protection Act of 1989 established protections for individuals who report suspected wrongdoing. There have been enhancements to the law, most recently the " Pilot Program for Enhancement of Employee Whistleblower Protection" (41 U.S.C. 4712 of the National Defense Authorization Act (NDAA), P.L. 112-239), which will be in effect until January 1, 2017. This law applies to all employees working for contractors, grantees, subcontractors, and subgrantees on federal grants and contracts.
The law specifies that an "employee of a contractor, subcontractor, grantee [or subgrantee] may not be discharged, demoted, or otherwise discriminated against" for whistleblowing. In addition, whistleblower protections cannot be waived by any agreement, policy, form, or condition of employment. “Whistleblowing” means reporting information the employee "reasonably believes is evidence of" wrongdoing, which may include the following:
- Gross mismanagement of a Federal contract or grant;
- The gross waste of Federal funds;
- An abuse of authority relating to a Federal contract or grant;
- A substantial and specific danger to public health or safety; or,
- A violation of law or regulation related to a Federal contract or grant (including the competition for, or negotiation of, a contract or grant).
The protections for whistleblower status are triggered if an employee discloses the information related to the above to any of the following individuals:
- A member of Congress, or a representative of a Congressional committee;
- An Inspector General;
- The Government Accountability Office;
- A federal employee responsible for contract or grant oversight or management at the relevant agency;
- An official from the Department of Justice, or other law enforcement agency;
- A court or grand jury; or,
- A management official or other employee of the contractor, subcontractor, grantee, or sub-grantee who has the responsibility to investigate, discover or address misconduct.
Pilot Program for Enhancement of Employee Whistleblower Protection
Preventing Grant Fraud, Waste, and Abuse
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:
- Theft or bribery
- False statements
- False claims
- Mail fraud and wire fraud
Four most common offenders:
- Grant recipients, company officers, business partners, board members, managers
- Bookkeepers, financial staff, and employees
- Contractors and subcontractors
Three most common fraud scenarios:
- Claiming personal expenses as grant expenses
- Billing for costs that have not been incurred or are not tied directly to the grant
- 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.
Drug-Free Workplace Requirements
Stephen F. Austin State University is required by federal statute to provide a drug-free workplace.
- SFA policy 13.11 Illicit Drugs and Alcohol Use outlines the university's commitment to a drug-free workplace. The policy "prohibits all employees (full-time and part-time faculty, staff and students) from engaging in the unlawful manufacture, distribution, dispensation, possession, or use of a controlled substance or alcoholic beverage in the workplace, or reporting to work under the influence of alcoholic beverages or illegal drugs." The policy includes information on health risks and outlines penalties for non-compliance. The policy is part of a drug-free awareness program on campus.
- Employees working on a Federal grant or other agreement must follow policy 13.11 and notify their immediate supervisor or Human Resources representative, within five calendar days, if they are convicted of a criminal drug violation that took place at any property owned or controlled by SFA.
Reference: Drug-Free Workplace Act of 1988