Post Award
Research CCHIP #025
CLARIFICATION OR CHANGE IN PROCEDURE (CCHIP)
Escalation Procedure for Award Noncompliance
OVERVIEW
When Sponsored Research is notified of, or discovers, noncompliance in sponsored awards, Sponsored Research has an obligation to notify the PI and escalate the concern as appropriate to ensure the award is brought into compliance. When an award remains noncompliant, Sponsored Research has an obligation to enforce compliance through means up to and including suspension of the award.
This CCHIP outlines an escalation procedure to be followed upon notification or discover of grant noncompliance.
DEFINITIONS
Noncompliance – Failure (intentional or unintentional) to comply with applicable federal regulations, state or local laws, the requirements or determinations of the IRB, or university policy regarding research involving human subjects. Noncompliance can result from action or omission. Noncompliance may be non-serious (minor) or serious, and may also be continuing.
CLARIFICATION OR CHANGE
This CCHIP establishes the escalation procedure to be followed in instances of grant noncompliance.
PROCEDURES
Upon notification or discovery of noncompliance:
When Sponsored Research is notified of, or discovers award noncompliance, the Assistant Director (AD) will record the issue for internal tracking, and share with the respective Sponsored Research Administrator (SRA). The AD will monitor the tracking of the noncompliance incident(s).
The process and escalation procedure is as follows:
1. Upon receipt of the notice, the SRA will send the notice received to the Principal Investigator (PI) and Unit Research Administrator (URA).
2. If the award remains noncompliant for an additional 5 business days, the SRA will send a follow up email to the PI and URA. The follow up e-mail will indicate that this is the second notice and that escalation will occur if the award remains noncompliant.
3. If the award remains noncompliant for an additional 5 business days, the SRA will send a follow up email to the PI, URA, and Department Chairperson (or equivalent). The e-mail will indicate that this is the third notice and that escalation will occur and the project may be suspended if the award remains noncompliant.
4. If the award remains noncompliant for an additional 5 business days, the AD will send a follow up e-mail (copying the SRA, Associate Director-Risk Management, and Director of Sponsored Research) to the PI, URA, Department Chairperson (or equivalent), Associate Dean for Research. The e-mail will indicate that this is the fourth notice, and the project may be suspended if the award remains noncompliant.
5. If the award remains non-compliant for an additional 5 business days, the Director of Sponsored Research will request a meeting with the PI, URA, Department Chairperson (or equivalent), Associate Dean for Research, Associate Director-Risk Management, AD, SRA, and Director of Sponsored Research.
Upon returning to a compliant status:
Once the award is brought to a compliant status, the status in Sponsored Research’s tracking mechanism will be updated accordingly.
If project had been suspended, Sponsored Research’s Transactions team will be notified to reactivate the project.
Incidents of increased severity, or requiring immediate suspension:
Depending on the severity of the incident, steps in the escalation process may be bypassed and/or alternate remedies may be imposed at the discretion of Sponsored Research.
CONTACT
Please address your questions regarding this CCHIP to your assigned Sponsored Research Administrator.
RESOURCES
EFFECTIVE DATE
This CCHIP is effective as of the date issued and rescinds any previous guidance pertaining to Escalation Procedures for Award Noncompliance.
ISSUED: March 11, 2021
LAST REVISION: March 11, 2021