The Office of Research & Sponsored Projects is charged with oversight of faculty and staff in the ethical and safe conduct of sponsored projects and research. University research is supported by a mix of sponsors that range from for-profit organizations, foreign entities and state and local governments. By far, the major source of university sponsored research comes from the Federal government. For this reason, regulations and compliance impose a significant demand of all universities, including UWG. 

  • Financial Conflict of Interest
  • Responsible Conduct in Research
  • Effort Reporting
  • Subrecipient Monitoring
  • Research Integrity
  • Compliance Toolbox
  • Financial Conflict of Interest

    Financial Conflict of Interest

    An important part of research integrity and maintaining the public trust is proper management of financial conflicts of interest(FCOI) that might affect a person's judgment during the conduct of research.  University of West Georgia Principal Investigators are required to list all key personnel on the Proposal Routing Form.  Key personnel include anyone involved with the design, conduct, or reporting of the research.  All key personnel must complete CITI training for Conflicts of Interest and submit a Significant Financial Interest Form.  See our Getting Started page. 

    PI/Investigator responsibilities:

    1. The project PI, and any personnel involved with the design, conduct, and/or reporting must complete CITI Conflicts of Interest training.
    2. A Significant Financial Interest (SFI) certification form must be filed prior to the submission of any grant and must be submitted annually for each project.
    3. In the event of a significant financial interest, a FCOI Disclosure form must be submitted.  If the interest is deemed a conflict, a FCOI management plan will be established.
    4. Investigators must amend their certification with thirty (30) days of discovering or acquiring a new, or previously unreported, significant interest.
    • UWG Financial Conflict of Interest Policy
      UWG Financial Conflict of Interest Policy

      (all research and sponsored proposal submissions)

      Federal regulations require that all applicants for funding (grant, cooperative agreements, and contracts) from the Public Health Service (PHS/NIH) or from the National Science Foundation (NSF) have in place policies and procedures that ensure investigators disclose to a designated Institutional Official (IO) any significant financial interest (and those of his/her spouse and dependent children). It is the policy of the University of West Georgia (UWG) that all investigators applying for external funding disclose significant financial interest. It must be emphasized that it is the responsibility of the Investigator and all personnel responsible for the design, conduct or reporting of research under the terms of a federal grant or contract to disclose all Significant Financial Interests (SFI). It is the responsibility of the designated institutional official to make the determination as to whether the disclosed Significant Financial Interests constitute a Financial Conflict of Interest (FCOI). If a conflict of interest exists the institution is required to implement procedures to manage, reduce, or eliminate the conflict of interest prior to the institution’s expenditure of any funds under the award.

      The UWG policy applies to subcontractors working on federally funded research (see section on subcontractors).

      Definitions:

      Excluded payer means a Federal, state, or local government agency, a United States institution of higher education, an academic teaching hospital, a medical center, or a research institute that is affiliated with an institution of higher education.

      Financial Conflict of Interest (“FCOI”) means any significant financial interest requiring disclosure under this Policy and that UWG, through its Institutional Official, reasonably determines could directly and significantly affect the design, conduct, or reporting of research.

      Institution means the University of West Georgia (UWG). The terms Institution and UWG are used interchangeably in this Policy.

      Institutional Official (“IO”) means the person appointed by UWG, or his/her designee(s), responsible for the oversight and implementation of this Policy. This includes (without limitation) responsibility for the solicitation and review of information from Investigators concerning significant financial interests requiring disclosure. UWG has appointed the Associate Vice President for Research and Sponsored Projects as its Institutional Official. In reviewing and making determinations concerning Investigator disclosures per this Policy, the IO will act in consultation with the university Provost.

      Investigator means the project director or principal investigator and any other person, regardless of title or position, who is directly and significantly affect the design, conduct, or reporting of research. This may include collaborators or consultants. The role of individuals involved in research and the degree of independence with which they work is used to determine who should disclose.

      Institutional Responsibilities shall mean, as determined by the IO, those activities conducted on behalf of the Institution by an Investigator, including research, activity as a consultant, teaching, professional practice, administrative duties, committee memberships, and service on panels.

      Manage means taking action to address an Investigator’s FCOI, which can include reducing or eliminating the FCOI, to provide a reasonable expectation that the design, conduct, and reporting of research will be free from bias related to the FCOI.

      Research means any systematic investigation, study or experiment designed to develop or contribute to generalizable knowledge, including behavioral and social-sciences research. The term encompasses basic and applied research as well as product testing and development. The term includes, but is not limited to, any activity for which research funding is available under grants, cooperative agreements or otherwise, such as a research grant, career development award, center grant, individual fellowship award, infrastructure award, institutional training grant, program project, research resources award or contract.

      Senior/key personnel means the PD/PI and any other person identified as senior/key personnel by UWG in the grant application, progress report, or any other report submitted to the federal sponsor by UWG under this policy, including subrecipients or subcontractors.

      Significant Financial Interest (SFI) means a financial interest consisting of one or more of the following interests of the Investigator (and those of the Investigator’s spouse and dependent children) that reasonably appears to be related to the Investigator’s institutional responsibilities:

      • Payments from a publicly traded entity over the 12 months preceding the disclosure that, when aggregated, exceeds $5,000 as of the date of the disclosure
        • Includes salary and any payment for services not otherwise identified as salary such as;
        • Equity interest includes any stock, stock option, or other ownership interest, as determined through reference to public prices or other reasonable measures of fair market value;
        • Intellectual Property rights and interests and any payment for services, salary, consulting fees, honoraria, paid
      • Payments from a non-publicly traded entity in the twelve months preceding the disclosure that, when aggregated, exceeds $5,000
        • Investigator holds any equity interest (e.g., stock, stock option, or other ownership interest)
        • Includes non-profits (such as foundations);
        • Intellectual property rights and interests (e.g., patents, copyrights), upon receipt of income related to such rights and
      • Investigators also must disclose the occurrence of any reimbursed or sponsored travel paid on behalf of the Investigator (i.e. not reimbursed to the Investigator) regardless of amount, related to UWG
      SFI does not include:
      • Remuneration from UWG including Intellectual Property rights assigned to UWG and paid by the institution to the Investigator
      • Income from investment vehicles (mutual funds, retirement accounts) so long as the Investigator does no control investment decisions made by these vehicles
      • Income from teaching engagements, seminars, lectures sponsored by a federal m, state, or local government agency, an Institution of higher education, an academic teaching hospital, a medical center, or a research institute;
      • Income from service on advisory committees or review panels for a federal, state, or local government agency, an Institution of higher education, an academic teaching hospital, a medical center, or a research
      Training Requirement for FCOI

      Investigators must complete FCOI training prior to submitting an application/proposal for any external funding. Follow-up training is required every three (3) years or immediately in instances where the institutional policy is revised; the PI is not in compliance with the policy or FCOI management plan; or when an investigator is new to the institution.

      1. All investigators must complete the CITI Financial Conflict of Interest training provided at https://citiprogram.org/
      2. In addition it is recommended that investigators attend one workshop each year regarding The Office of Research & Sponsored Projects will conduct workshops in the Fall and Spring of each year
      3. FCOI “just-in-time” FCOI training will be provided at the request of any funded project
      Disclosure, Review, and Monitoring Requirement for FCOI
      1. Prior to submission of a proposal the PI and any member of the research team who contributes significantly to the design, conduct and reporting of the project will complete the Significant Financial Interest In instances of Significant Financial Interest, the investigator will complete the Financial Conflict of Interest Disclosure Form.
      2. Minimally, FCOI updates will be completed annually. The Office of Research and Sponsored Projects will maintain a database and send reminders to faculty in January of each Signed forms will be due no later than January 31st of each year.
      3. Investigators must also disclose within 30 days of discovering or acquiring any new SFI.
      4. Disclosure of travel: Investigators must disclose the occurrence of any reimbursed or sponsored travel (i.e., travel which is paid on behalf of the Investigator and not reimbursed to the Investigator so that the exact monetary value may not be readily available), related to the Investigator’s Institutional responsibilities during the previous twelve months, other than travel reimbursed or sponsored by an excluded Travel disclosures must include the purpose of the trip, the identity of the trip’s sponsor or organizer, the trip’s origin and destination, and the duration of the trip. In addition, the Institutional Official may request other information about the trip as necessary to evaluate whether the travel may constitute a Financial Conflict of Interest.
      Review of Financial Disclosures

      The following process shall apply to financial conflict of interest disclosures submitted by Investigators. The same process will apply if it is the initial submission, annual renewal, a newly discovered or acquired SFI, or the submission of a new investigator at UWG. The Institutional Official will review disclosures of SFI related to institutional responsibilities.

      1. Determination of Financial Conflicts of
        1. The IO shall review each disclosed Financial Conflict of Interest; determine whether such conflict relates to funded research, and, if so related, determine whether a Financial Conflict of Interest (as defined below) exists; and
        2. The IO shall determine what conditions or restrictions, if any, should be imposed by the institution to manage, reduce, or eliminate such conflict or
        3. The IO may, depending on the scope of the potential conflict, request that additional staff or faculty serve on an ad hoc review committee to assist in its timely
      2. Existing Financial Conflict of

      A “Financial Conflict of Interest” exists when the IO reasonably determines that a Significant Financial Interest could directly and significantly affect the design, conduct, or reporting of federally-funded research or educational activities.

      1. Management of Financial Conflicts of

      If the IO determines that a Significant Financial Interest constitutes a Financial Conflict of Interest, the IO will work in conjunction with the Provost to develop a management plan. The IO and Provost will review the research, the financial interests in question, and the areas of conflict, and devise a plan for the management of the Financial Conflict of Interest (see “Management Plan” below).

      After the fact discovery: In the event a SFI is discovered, whether not disclosed by the investigator in a timely manner or not reviewed by the institution, the IO will: review the significant financial interest; determine whether it is related to the Investigator’s institutional responsibilities; determine whether a financial conflict of interest exists; and, if so will within 60 days:

      1. Implement an interim management plan that specifies the actions that have been, and will be, taken to manage such financial conflict of interest going forward;
      2. within 120 days of the determination of noncompliance, complete a retrospective review of the Investigator’s activities to determine whether any research, or portion thereof, conducted during the time period of the noncompliance, was biased in the design, conduct, or reporting of such If necessary, UWG will update the previously submitted FCOI report, specifying the actions that will be taken to manage the financial conflict of interest going forward. If bias is found, UWG is required to notify the PHS Awarding Component promptly and submit a mitigation report to the PHS Awarding Component. UWG may determine that additional interim measures are necessary.
      Management plan

      If it is determined by the IO that a SFI creates a FCOI; the IO, in consultation with the Provost, shall assess and determine if a management plan is necessary. If a financial or management conflict of interest exists that would reasonably appear to comprise objectivity of the research, a management plan will be proposed for ensuring research objectivity. Possible strategies include, but are not limited to:

      • Public disclosure of the FCOI when presenting or publishing the research
      • Disclosure of FCOI directly to potential research subjects
      • Monitoring of research by independent reviewers
      • Modification of the research plan
      • Change of personnel or personnel responsibilities, or disqualification of personnel from participation in all or a portion of the research
      • Reduction or elimination of the financial interest
      • Severance of relationships that create financial conflicts

      The management plan will be shared with funding agencies, as appropriate.

      For studies that are ongoing, when an existing investigator discloses a new SFI, within 60 days the review process described above will be initiated. If a FCOI exists, a management plan will be implemented. If necessary, additional interim measures may be implemented to manage the FCOI between the date of disclosure and completion of the review.

      Reporting Requirements

      Should any reported conflict or non-compliance require reporting to PHS, the Institutional Official or designee will prepare applicable FCOI report in accordance with PHS regulations. The FCOI reports shall contain information required by law or otherwise by the sponsor. The Investigator should be aware that information pertaining to FCOIs may be disclosed to sponsors or oversight agencies and, in some cases, to the public and may contain such details as the value and nature of the financial interest and elements of the management plan.

      If the funding for the Research is made available from a prime PHS awardee (UWG is sub-recipient in funding), such reporting shall be made available to the prime awardee such that they may fulfill their reporting obligations to the PHS.

      Financial Conflicts of Interest occurring on projects funded by the NIH will be reported to NIH via the eRA Commons FCOI Module. Reports will be made by the IO or their designee.

      Maintenance of Records

      In general, records related to the identification, evaluation, and response to FCOI in Research shall be retained for three years following the date that the final Research expenditure report has been submitted to the research sponsor or for a longer period when specified by applicable governmental or University requirements.

      Sub-recipient Requirements

      When a PHS-funded project for which UWG is the lead institution includes a sub-recipient investigator – whether a sub-grantee, contractor, subcontractor, or collaborator – the sub-recipient investigator is also subject to PHS and NSF FCOI regulations. To ensure compliance, the sub-recipient institution must certify in writing whether sub-recipient investigators will follow the FCOI policy of UWG or the sub-recipient institution; if the sub-recipient institution’s policy will apply, the certification verifies that the policy complies with the PHS and/or NSF FCOI regulation. This certification form will be made available by request from the UWG Office of Research & Sponsored Programs.

      UWG employees serving as sub-recipient investigators on PHS-funded research are subject to UWG’s FCOI policy; in such a case, UWG investigators may request a certification from the Office of Research & Sponsored

      Programs to verify their compliance with the UWG FCOI policy and PHS FCOI regulations for the sponsored project’s lead institution.

      Sub-recipient investigators who are subject to UWG's FCOI policy must fulfill all requirements for investigators as described in this policy, particularly in regards to responsibilities related to the disclosure of SFIs and FCOI training.

      For sub-recipient investigators who are subject to their affiliated institution’s FCOI policy, sub-recipient institutions must report all identified FCOIs to the UWG Office of Research & Sponsored Programs as soon as possible following internal review of disclosed SFIs and prior to the expenditure of funds.  Early reporting will help to ensure timely commencement of funding following a notice of award. For subsequently identified FCOIs, sub-recipient institutions must provide a FCOI report to UWG within 30 days of when a new FCOI is discovered or acquired. FCOI reports made to UWG for sub-recipient investigators must include the following information:

      1. Name of the entity with which the investigator has an FCOI
      2. Nature of the FCOI (e.g., equity, consulting fees, travel reimbursement, honoraria)
      3. Value or estimated value of the financial interest
      4. Description of how the financial interest relates to PHS-funded research and the basis for the determination that it conflicts with the research
      5. Key elements of the management plan
        • Role and principal duties of investigator in the research project
        • Conditions of the management plan
        • How the management plan will safeguard objectivity in the research project
        • Confirmation of the investigator's agreement to the management plan
        • How the management plan will be monitored to ensure compliance
        • Other pertinent information

      In the event a sub-recipient investigator has an FCOI to report, UWG will provide a sub-recipient FCOI report with the above information to the PHS awarding component prior to the expenditure of funds and within 60 days of any subsequently identified FCOI.

      Non-Compliance Penalties

      All Employees must comply with the Institution’s FCOI policy to reduce, manage, and eliminate all potential financial conflicts of interest. In the event an FCOI is present or there has been noncompliance of the FCOI policy, the Employee must cooperate with the management plan set forth to remedy the FCOI or noncompliance. Penalties for noncompliance may include:

      1. Cannot submit for externally funded opportunities
      2. Termination of the activity that creates the conflict of interest, including inability to draw funds from grant and contract speed types or participate in IRB protocols
      3. Funds drawn from a federally funded grant may need to be returned
      4. Additionally -
      • Divestiture of significant financial
      • Deactivation of employee’s badge access to parking and
      • Disciplinary action against the employee up to and including
      • In the case of violation of criminal or civil law, violation may be subject to civil or criminal
      • Reporting to applicable federal agencies

      Except to the extent required by law and federal regulations, the information disclosed will be kept confidential. You should know, however, that the Institution is required to report the existence of real or potential conflicts of interest to certain federal agencies. Specifically, the NIH (PHS) requires institutions to report to the PHS the existence of any conflicting interests and to assure that the interest has been managed, reduced or eliminated. NSF requires that only conflicts that have not been managed, reduced or eliminated prior to the expenditure of funds under an award be reported to NSF.

  • Responsible Conduct in Research

    UWG Responsible Conduct of Research Training

    The University of West Georgia endorses Responsible Conduct of Research Training. This training is required for students and individuals supported by NSF and/or NIH research funding.

    Please review the Responsible Conduct of Research Training Plan for the requirements of RCR training.

    Responsibilities:

    The PI for the NSF/NIH funded project is required to certify that training has been completed. Certifications are due in the Office of Research & Sponsored Projects by January 31st of each year.

    Required Training:

    NSF
    Students (undergraduate and graduate and postdoctoral researchers who receive NSF funds (salary and/or stipends) to conduct research on NSF grants must receive RCR training. Students must take RCR training if they receive NSF scholarship or stipend support to engage in research, or if conducting research is included in their academic program.

    NIH
    All trainees, fellows, participants, and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and dissertation research grant will receive training in the Responsible Conduct of Research.

    This RCR training requirement applies to the following NIH programs: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K05, K07, K08, K12, K18, K22, K24, K25, K26, K30, K99/R00, KL1, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R.
    *NOTE: CITI training may be used to support RCR training, however also requires significant face-to-face instruction.

    RCR Subject Matter:
    Conflict of Interest
    Policies regarding human subjects
    Mentor/mentee responsibilities
    Collaborative research
    Peer review
    Data acquisition
    Research misconduct
    Contemporary ethical issues.

    • Responsible Conduct of Research Training Plan
      Responsible Conduct of Research Training Plan

      The University of West Georgia (UWG) endorses Responsible Conduct of Research (RCR) on its campus and expects its employees and students to abide by pertinent rules, policies, guidelines and regulations. The RCR Plan involves the education and mentorship of faculty, staff, and students involved in projects sponsored by the National Science Foundation (NSF) and the Public Health Service (PHS) at UWG.

      UWG’s RCR training plan is intended to satisfy minimum baseline requirements of Section 7009 of the America COMPETES Act. It is understood that RCR can be taught and learned in many ways and that standards can vary from discipline to discipline. Thus, departments, programs, and principal investigators are strongly encouraged to provide training that goes beyond the minimum requirements, varying content and delivery modes in such a way that the supplemental training addresses the specific needs, issues, and concerns of the discipline.

      NSF

      In January of 2010, The National Science Foundation (NSF) implemented Sections 7009 of the America Creating Opportunities to Meaningfully Promote Excellence in Technology, Education, and Science (COMPETES) Act (Public Law 110-69-August 9, 2007) http://www.gpo.gov/fdsys/pkg/FR-2009-08- 20/html/E9-19930.htm.

      Section 7009 (42 USC 1862o–1) requires that all grant applications for financial assistance from the NSF for science and engineering research or education include a description in each grant proposal a plan to provide appropriate training and oversight in the responsible and ethical conduct of research to undergraduate students, graduate students, and postdoctoral researchers participating in the proposed research project. To that end, the Office of Research & Sponsored Projects (ORSP) has developed procedures for meeting the minimum requirements.

      For those individuals in need of NSF-compliant training, the ORSP provides online RCR training modules through the Collaborative Institutional Training Initiative (CITI) at no cost to students, faculty, and staff. The modules cover.

      • Misconduct;
      • Responsible Authorship and Publication;
      • Plagiarism;
      • Conflict of Interest;
      • Data Acquisition and Management;
      • Responsible Peer Review;
      • Responsible Mentoring;
      • Responsible Collaboration

      This institutionally-sponsored training is in addition to any program-driven training offered to students by their respective colleges and departments.

      These CITI modules provide the minimum training to augment discipline-specific training that must be provided by the college, department and/or supervisor.

      NIH

      The National Institutes of Health (NIH) requires that all trainees, fellows, participants and scholars receiving support through any NIH training, career development award (individual or institutional), research education grant, and dissertation research grant must receive instruction in responsible conduct of research. This policy became effective January 25, 2010 and applies to the following programs: D43, D71, F05, F30, F31, F32, F33, F34, F37, F38, K01, K02, K05, K07, K08, K12, K18, K22, K23, K24, K25, K26, K30, K99/R00, KL1, KL2, R25, R36, T15, T32, T34, T35, T36, T37, T90/R90, TL1, TU2, and U2R, and any NIH program funded by NIH which requires RCR training in the funding opportunity announcement. OT-OD-10-019 http://grants.nih.gov/grants/guide/notice-files/NOT-OD-10-019.html.

      CITI training in Responsible Conduct in Research training is required for each trainee, fellow, participant, and scholar receiving support. Additionally, the NIH requirements highly encourage multiple forms of RCR training, including formal courses, small-group discussions, and instruction by research training faculty members. The Office of Research & Sponsored Projects staff will work with faculty members to create a compliant training program, which will include significant face-to-face interaction and participation. The plan will include continuing and ongoing training in research ethics throughout each year of the funded NIH project.

      RESPONISBILITIES FOR RCR TRAINING PLAN IMPLEMENTATION

      Responsibility for compliance with the NSF and NIH RCR mandates rests primarily with principal investigators. Training requirements are as follows:

      Training requirements
      • Principal Investigators, co-investigators, and senior personnel submitting proposals on or after January 1, 2015 are encouraged to complete training through the CITI RCR training course at the time of new proposal submission to NSF or
      • Principal Investigators shall identify undergraduates, graduate students, and post-doctoral associates, trainees, fellows, participants, and scholars receiving support to be hired on NSF or NIH-funded projects and ensure completion of RCR CITI training within 60 days of
      • Students completing CITI training should provide the PI with the CITI completion This certificate should be kept on file by the PI for annual certification to the ORSP.
      • Annually, the PI shall complete a Responsible Conduct of Research Training Certification, attach all student CITI certifications and submit these to the Office of Research & Sponsored Projects Research Compliance Officer by January 31 of each year. Forms can be found on the ORSP Compliance web
      • Additionally, NIH funded PI’s with trainees, fellows, participants, and scholars receiving support from NIH- funded projects must keep all attendance records for their individual RCR training program and submit this documentation with their annual

      Please contact Charla Campbell for any questions you might have or for help using the site. charlac@westga.edu.

      The CITI RCR modules are available at https://www.citiprogram.org/.

  • Effort Reporting

    The federal government requires an effort report when an individual is compensated by or has agreed to contribute time to a federally sponsored project.  All faculty who serve as investigators on sponsored agreements are personally responsible to certify the amount of effort that they and their employees spend on sponsored activities.

    Effort Reporting Procedures and Policy

    • UWG Effort Reporting Procedures
      UWG Effort Reporting Procedures

      July 2011 (v.1), October 2013 (v.2), March 2014 (v.3)
      POLICY NUMBER: 4.2b
      POLICY NAME: Time and Effort Reporting Procedures for Sponsored Projects

      Statement of Need

      The federal government requires an effort report when an individual is compensated by or has agreed to contribute time to a federally sponsored project. Anyone who is paid by funds from a sponsored project, or whose effort has been contractually committed to a project, is personally responsible for certifying the amount of effort that they have devoted to the project.

      PROCEDURE DETAILS:

      UWG utilizes the after-the-fact confirmation method, requiring the Principal Investigator (PI), and any individual paid from a sponsored project, or whose effort has been contractually committed to a project, to certify on a regular basis. Faculty, staff, and students are required to confirm that salaries and wages charges assessed to a sponsored project are appropriate to effort expended on each award. UWG project employees must certify at the conclusion of each semester, (Fall, Spring, and Sumer) in January, May, and August, effort reports that specify the percent of total effort spent on sponsored activities. Effort reports must be certified by the individual receiving payment or an individual with first-hand knowledge of effort expended. All UWG employees paid from sponsored funds will follow procedures for managing effort commitments and the effort reporting certification process outlined in this policy.

      Managing Effort Commitments

      An Individual’s Total Institutional Activities should not exceed 100% and must be consistent with his/her other duties. It is important to understand that Effort is not calculated on a 40-hour workweek or any other standard workweek. A faculty work week is the average number of hours a faculty member normally works during a week. Hours are to be averaged over the effort reporting period. For many faculty this number will vary from one week to another. As an example, if within an effort reporting period, a faculty member were to work half 60-hour weeks and half 40-hour weeks, his/her average work week would be 50 hours. Hours are averaged over the semester in which the sponsored (or cost shared) effort occurs.

      Department Chairs, Assistant/Associate Deans, and Deans are not limited to a specific effort amount, as long as administrative duties are being successful conducted as determined by his/her supervisor. In no case will the Effort be over 100% paid from a grant. In the case of a training grant or other project that specifically restricts any salary charges, effort is recorded as voluntary uncommitted cost-sharing unless specifically required as a mandatory committed cost-sharing activity by the sponsor.

      Certification Process

      Upon award, the ORSP will review and document all committed effort based on the proposal and final negotiated contract and budget. The Department will complete the paperwork necessary (Personnel Action Request), with Principal Investigator approval, to charge the proposed effort to the sponsored project account or its associated cost-share account for the appropriate budget period. In January, May, and August, a payroll distribution report is prepared by ORSP and the distribution of compensation paid to the employee is calculated in percentages for sponsored project-funded time, cost-shared time, and all other institutional activities. An effort report form is populated with this percentage distribution and the percent effort contractually committed to the project for the time period being certified. For full‐time employees, forms are emailed directly for certification. The employee is asked to certify that the percent effort distribution is a reasonable representation of his/her total effort performed for UWG during the reporting period. By entering the “actual effort” committed, if this number varies from the “committed effort” a written explanation of the variation must be submitted with the signed effort certification report. Effort forms must be initialed by the PI responsible for each grant prior to the return of the form to ORSP. Forms for part‐time and student workers are sent to the PI who is responsible for either securing the certification from these employees or ensuring that someone who is able to verify each employee’s effort provides the certification. By signing the form, the Certifier attests that he/she has a suitable way of verifying the stated effort and that the effort amounts shown are reasonable estimates of actual work performed during the stated period. Most commonly, it is the PI who has this first‐hand knowledge, although in some cases it may be another staff member who supervised the part‐time or student employee who has the firsthand knowledge.

      Time and Effort Certification is a federal requirement and must be completed in a timely manner. Any individual who submits a falsified report or fails to comply with the requirements of this policy in a timely manner may be subject to disciplinary action up to and including termination and/or funding disallowances.

      Short Title: Time and Effort Reporting Procedures
      Effective Date: 1/15/2014
      Cancels/Supersedes: new policy
      Revision Dates: 1/8/2014
      Oversight: Associate Vice President for Research and Sponsored Projects
      Authority and Purpose: This document contains the detailed procedures for effort reporting for sponsored projects at UWG.

      Definitions:

      Budget Period – identified by the sponsor as a beginning and ending date during which funds can be expended under the award.

      Committed Effort – the amount of effort proposed in a grant, project, or contract that is accepted by a sponsor, regardless of whether salary support is requested from the sponsor for the effort.

      Co-Principal Investigator – additional individual identified as key personnel but is not the Project Director, the Lead Investigator, or Director and does not have signing authority for grant funds.

      Cost Sharing – portion of the project or program cost not borne by the funding agency. This includes all contributions, mandatory or voluntary, of institutional resources committed in the proposal or award. Cost sharing of effort is included in the calculation of total committed effort. Mandatory and/or voluntary cost share must be identified in the proposal routing form and approved by the responsible department and college. An account designated to cover these charges must be identified prior to proposal submission.

      Cost Transfers – transfers to or from a sponsored account of a charge that was previously recorded on another account or to another funding source.

      Designated Responsible Party – the person at UWG who manages and is responsible for the effort reporting compliance program.

      Effort – the amount of time spent on any activity expressed as a percentage of Total Institutional Activities for which an individual is compensated by UWG.

      Effort Certification – a means of confirming that the effort supported or paid by the sponsor has been performed and the effort expended in support of a project (but not paid by the sponsor) has been performed.

      Institutional Base Salary (IBS) – the total guaranteed annual compensation an individual receives from UWG; whether the individual’s time is spent on research, instruction, service, or other activities. A nine-month appointment is considered to be the individual’s annual rate. Administrative supplements are included in the IBS and are not calculated separately as part of the Effort Certification process. In order for the administrative supplement to be included as a part of the IBS, it must be guaranteed for the fiscal year. A temporary assignment (e.g., less than one-year) is not included in the IBS.

      Key Personnel – anyone paid from sponsored funds, or whose effort is committed in the proposal, without whom the project cannot be successfully completed.

      Matching Funds – synonymous with Cost Sharing.

      Mandatory Committed Cost Sharing – required by the sponsor as a condition of obtaining the award and included in the contract or grant proposal.

      Notice of Award – the official notification (email, fax, letter, or dually-executed contract) from a sponsor indicating that the submitted proposal, application, or contract is formally approved and accepted for funding.

      Project Period – identified by the sponsor as a beginning and ending date during which the project will be performed by UWG.

      Principal Investigator – individual identified as the Project Director, the Lead Investigator, or Director of a Sponsored Project and has signing authority for project funds.

      Summer Salary - As referenced in UWG’s Faculty Handbook, Section 113 – Faculty Compensation for Summer School Teaching, an individual holding a nine-month appointment cannot exceed 33.3% of the nine-month rate during the summer. Effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary as effort and pay would not occur during the same period. Further, faculty are not permitted to indicate unpaid summer effort in a proposal to a sponsor; the University is not obligated to pay faculty salary during the summer, unpaid committed summer effort has no monetary value.

      Sponsored Projects – involve a specific commitment of time and can be either: 1) externally funded activities in which a formal written agreement, such as a cooperative agreement, contract, or grant is entered into by UWG and by a sponsor for research, training, or other public service activities; or 2) internally funded for which the activities are separately budgeted and accounted for by UWG as a result of a formal application and approval process.

      Total Institutional Activities – those activities for which an individual is paid by UWG. Activities include administrative duties, instruction, research, and public service.

      Voluntary Committed Cost Sharing – effort proposed that was not required by the sponsor and that is in excess of effort paid by the sponsor and/or mandatory cost sharing.

      Voluntary Uncommitted Cost Sharing – effort that may benefit a project but was not committed in the proposal or award.

      Designated Responsible Party

      The Associate Vice President of Research and Sponsored Projects is the Authorized Institutional Official. The Research Compliance Officer serves as the designated responsible party at UWG responsible for the Time and Effort reporting compliance program.

      Education

      The Office of Research & Sponsored Projects will meet with each Principal Investigator at the time of award and review effort commitments made in the grant/contract. ORSP will also conduct Time & Effort Training periodically throughout the year, maintain a FAQ webpage for frequently asked questions relating to Time & Effort, and will be available to answer questions via phone or email.

      Cost Sharing

      UWG’s policy on Cost Sharing requires that only the minimum amount required by the Sponsor is allowed, and Voluntary Cost Sharing is not permitted without appropriate Vice Presidential approval unless the proposed Cost Sharing meets the University’s strategic objectives. Cost Sharing may be required by the Sponsor or volunteered; however, any Commitment of Effort, whether solicited or Volunteered, that is referenced in the award must be honored, reported, and captured in the Effort Reporting system. ORSP will identify, monitor, and track all Mandatory and Voluntary committed Cost Sharing on a semester basis for effort reporting.

      A Cost Share account will be established when monetary Cost Sharing commitments have been committed in an awarded sponsored project. Funds to cover the cost share commitment will be moved into this account by the department/Dean responsible, and then reported to the ORSP office. For both Mandatory and Voluntary committed Cost Sharing, when a notice of grant award is received in which Cost Sharing was proposed, the Cost Sharing becomes a binding commitment that must be provided for and tracked in a consistent manner. These forms of Cost Sharing are monitored and reported annually to the accounting office for inclusion in the appropriate direct cost base in the facilities and administrative rate proposal. Cost Sharing commitments are cross-checked against proposal approval forms to verify availability of committed funds.

      Expenditure Transfers

      Expenditure Transfers are transfers to or from a sponsored project account of a charge that was previously recorded to another account or to another funding source. Expenditure transfers will be made at the discretion of the ORSP with ultimate responsibility held by the Associate Vice President for Research and Sponsored Projects. All personnel being paid by sponsored projects must be paid from the correct account code via a Personnel Action Request (PAR). Expenditure Transfers between budget periods will not be recorded unless specifically approved in writing by the sponsor. No Expenditure Transfers will be made after the project final report has been submitted unless the transfer benefits the sponsor.

      Record Retention Schedules

      Each investigator is responsible for retaining sufficient and adequate records, as required by the sponsor, to document and answer inquiries regarding the sponsored project costs, cost transfers, billing rate calculations, utilization of services, hourly timecard copies, and billed charges. All sponsored project activity is subject to audit, internally and externally, depending on the sponsor’s audit requirements and record retention policies. Records must be retained for a minimum of three (3) years beyond the expiration date and/or closing date of the sponsored project unless an audit or litigation claim is begun before the expiration of this period. All sponsor-imposed retention schedules must be honored regardless of the time frame. The ORSP personnel review sponsor-issued regulations and guidelines for reasonableness of retention schedules before accepting and/or entering into a sponsored project.

      Authority

      • 2 CFR 220, COST PRINCIPLES FOR EDUCATIONAL INSTITUTIONS (OMB CIRCULAR A-21)

      Interpretation

      UWG’s Designated Responsible Party manages and is responsible for the Time and Effort reporting compliance program. Questions or concerns regarding this policy should be directed to the Research Compliance Officer.

      References

      OMB Circular A-21, J.10 Compensation for Personnel Services (http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html#b)http://www.whitehous e.gov/omb/circulars/a021/a21_2004.html - b) http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html - b) http://www.whitehouse.gov/omb/circulars/a021/a21_2004.html - b)

    • UWG Effort Reporting Policy
      UWG Effort Reporting Policy

      POLICY NUMBER: 4.2a
      POLICY NAME: Time and Effort Reporting Policy for Sponsored Projects

      Statement of Need

      The Federal government requires an effort report when an individual is compensated by or has agreed to contribute time to a federally sponsored project. Anyone who is paid by funds from a sponsored project, or whose effort is contractually committed to a project, is personally responsible for certifying the amount of effort that they have devoted to the project.

      Applicability

      This Time and Effort Reporting Policy applies to all individuals receiving funding for an externally funded sponsored project, or whose effort has been contractually committed to a project, and any internally funded faculty research grant. This policy also applies to any individual with responsibility for allocating labor expenses to sponsored projects and to any individual involved in the management, administration, or oversight of sponsored projects.

      This policy establishes institutional requirements for individual certification of effort reports and the ORSP verification of payroll distribution and committed effort activities on sponsored projects, such as grants, and contracts. This policy represents the minimum requirements in each policy area of Time and Effort reporting for The University of West Georgia (UWG) in order to comply with federal policies regulating the application for and the expenditure of funds as outlined in the Office of Management and Budget (OMB) Circular A-21 (2 CFR 220), Cost Principals for Educational Institutions.

      Policy

      UWG utilizes the after-the-fact confirmation method, requiring the Principal Investigator (PI), and any individual paid from a sponsored project, or whose effort has been contractually committed to a project, to certify on a regular basis. The details for certifying effort are provided in 4.2b: Time and Effort Reporting Procedures

      Time and Effort Certification is a federal requirement and must be completed in a timely manner. Any individual who submits a falsified report or fails to comply with the requirements of this policy in a timely manner may be subject to disciplinary action up to and including termination and/or funding disallowances.

      POLICY ADMINISTRATION:

      See Procedure 4.2b: Time and Effort Reporting Procedures for how this policy is enacted at UWG.

      Short Title: Time and Effort Reporting
      Effective Date: 01/15/2014
      Cancels/Supersedes: new policy
      Revision Dates: 1/15/2014
      Oversight: Associate Vice President for Research and Sponsored Projects

      Authority and Purpose:

      Federal regulations (OMB Circular A-21, 2 CFR 220) require an effort report when an individual is compensated by or has agreed to contribute time to a federally sponsored project. At UWG, anyone who is paid by funds from a sponsored project, or whose effort is contractually committed to a project, is responsible for certifying the amount of effort that they have devoted to the project.

      Definitions:

      Budget Period – identified by the sponsor as a beginning and ending date during which funds can be expended under the award.

      Committed Effort – the amount of effort proposed in a grant, project, or contract that is accepted by a sponsor, regardless of whether salary support is requested from the sponsor for the effort.

      Co-Principal Investigator – additional individual identified as key personnel but is not the Project Director, the Lead Investigator, or Director and does not have signing authority for grant funds.

      Cost Sharing – portion of the project or program cost not borne by the funding agency. This includes all contributions, mandatory or voluntary, of institutional resources committed in the proposal or award. Cost sharing of effort is included in the calculation of total committed effort. Mandatory and/or voluntary cost share must be identified in the proposal routing form and approved by the responsible department and college. An account designated to cover these charges must be identified prior to proposal submission.

      Designated Responsible Party – the person at UWG who manages and is responsible for the effort reporting compliance program.

      Effort – the amount of time spent on any activity expressed as a percentage of Total Institutional Activities for which an individual is compensated by UWG.

      Effort Certification – a means of confirming that the effort supported or paid by the sponsor has been performed and the effort expended in support of a project (but not paid by the sponsor) has been performed.

      Institutional Base Salary (IBS) – the total guaranteed annual compensation an individual receives from UWG; whether the individual’s time is spent on research, instruction, service, or other activities. A nine-month appointment is considered to be the individual’s annual rate. Administrative supplements are included in the IBS and are not calculated separately as part of the Effort Certification process. In order for the administrative supplement to be included as a part of the IBS, it must be guaranteed for the fiscal year. A temporary assignment (e.g., less than one-year) is not included in the IBS.

      Key Personnel – anyone paid from sponsored funds, or whose effort is committed in the proposal, without whom the project cannot be successfully completed.

      Matching Funds – synonymous with Cost Sharing.

      Mandatory Committed Cost Sharing – required by the sponsor as a condition of obtaining the award and included in the contract or grant proposal.

      Project Period – identified by the sponsor as a beginning and ending date during which the project will be performed by UWG.

      Principal Investigator – individual identified as the Project Director, the Lead Investigator, or Director of a Sponsored Project and has signing authority for project funds.

      Summer Salary - As referenced in UWG’s Faculty Handbook, Section 113 – Faculty Compensation for Summer School Teaching, an individual holding a nine-month appointment cannot exceed 33.3% of the nine-month rate during the summer. Effort expended during the academic year does not satisfy a commitment related to the receipt of summer salary as effort and pay would not occur during the same period. Further, faculty are not permitted to indicate unpaid summer effort in a proposal to a sponsor; the University is not obligated to pay faculty salary during the summer, unpaid committed summer effort has no monetary value.

      Sponsored Projects – involve a specific commitment of time and can be either: 1) externally funded activities in which a formal written agreement, such as a cooperative agreement, contract, or grant is entered into by UWG and by a sponsor for research, training, or other public service activities; or 2) internally funded for which the activities are separately budgeted and accounted for by UWG as a result of a formal application and approval process.

      Total Institutional Activities – those activities for which an individual is paid by UWG. Activities include administrative duties, instruction, research, and public service.

      Voluntary Committed Cost Sharing – effort proposed that was not required by the sponsor and that is in excess of effort paid by the sponsor and/or mandatory cost sharing.

      Voluntary Uncommitted Cost Sharing – effort that may benefit a project but was not committed in the proposal or award.

      Designated Responsible Party

      The Associate Vice President of Research and Sponsored Projects is the Authorized Institutional Official. The Research Compliance Officer serves as the designated responsible party at UWG responsible for the Time and Effort reporting compliance program.

    • UWG Effort Reporting Tools
      UWG Effort Reporting Tools

    Effort Reporting Frequently Asked Questions

    • What is Time and Effort Reporting and why must effort be reported?
      What is Time and Effort Reporting and why must effort be reported?

      T&E reporting is necessary to record employee time and effort expended to fulfill commitments to sponsors of externally funded restricted grants and contracts. It is also necessary to properly charge the labor cost where the labor was preformed. Reports should reflect effort within 5% of what is budgeted.

      Each grant or contract includes guidelines for charging employee time spent working on that project. In order to comply with sponsors' funding regulations, UWG must maintain complete and accurate records of effort expended by employees paid from a grant or contract or contributed to a grant or contract as cost sharing. Effort charged to any contract must represent work done on that project only.

      Failure to maintain time and effort reporting may result in overcharges to funding sources and, in certain cases, could subject UWG to civil or criminal fraud investigations.

    • How does the Time and Effort Report get recorded?
      How does the Time and Effort Report get recorded?

      There are 2 methods to record actual time and effort expense to the account in which it occurred.

      The Personnel Action Request (PAR) will accommodate several chart strings where expenditures will occur. When a person is hired or becomes grant or cost share funded and will have that status for a semester or more, the PAR is used to assign the employee to the proper chart string(s). This method will be reflected in the labor distribution report generated in payroll.

      The other method used is the Time and Effort Report. This method records the effort expended by the employee for a specific time period to the project for which the work was done. This is an after the fact method of recording.The Office of Research & Sponsored Projects is responsible for distributing, collecting, reviewing, and maintaining for a prescribed period the official file of time and effort reports for faculty, staff, and students paid by grants & sponsored projects. Reports must be current and available for review upon request from university financial affairs, the internal auditor, Academic Affairs, the departmental supervisor, and federal or state auditors.

      For more information and assistance, faculty and staff should contact the Office of Sponsored Projects to ensure that effort is reported properly. 

    • Who must sign the Time and Effort Report?
      Who must sign the Time and Effort Report?

      Each individual paid from grant or sponsored funds must sign their T&E Report. This includes matching/cost share salaries. If students are unavailable at the time the report is due, a responsible party with direct knowledge of time spent on the project may certify the students Effort Report.

    • Can Changes and Corrections be made to Time and Effort Reports?
      Can Changes and Corrections be made to Time and Effort Reports?

      It is important to report time and effort carefully to avoid the necessity of making retroactive corrections. However, changes may be warranted when it is necessary to correct clerical and data entry errors.

      Retroactive corrections will only be approved when sufficient reasons and explanation are provided or when the charges violate the restrictions of an account. These corrections can only be done in the current fiscal year.

      If effort is used as cost sharing, then the effort must be documented in the same fashion as above. All cost share efforts must be documented with in the payroll system.

    • When is the Time and Effort due?
      When is the Time and Effort due?

      Normally time and effort is recorded on an end of the semester basis. However, the sponsor may require them more frequently.

    • Why must my Time and Effort Report be timely?
      Why must my Time and Effort Report be timely?

      T&E reports must be timely to allow the grant accounting office appropriate time to process and record the effort.

      Timely reporting is necessary to be able to report correct information to the sponsor in a timely manner.

      Timely reporting provides up to date expenditures totals to the PI/ project director.

      It provides timely reimbursement of salary and fringe benefit cost to the department.

    • What is contributed or cost-shared effort?
      What is contributed or cost-shared effort?

      Cost sharing represents that portion of the total project costs of a grant agreement that are not borne by the sponsor. The educational institution or other non-federal third party pays these costs. The grantor may require cost sharing (matching), or the institution may volunteer. Regardless, any commitment of effort or matching referenced in the project proposal or the award document must be honored, reported and captured in the effort reporting system.

      Cost-sharing is frequently referred to as matching. 

    • What is the difference between effort reporting and payroll distribution?
      What is the difference between effort reporting and payroll distribution?

      Payroll distributions and effort reports are not the same. Payroll distributions are the distribution of an individual’s salary and benefits in the accounting record. Effort reports describe the allocation of an individual’s actual time and effort for specific projects, whether or not reimbursed by the grantor. Certifying is attesting that salaries, wages and benefits charged to the grants (including required match portions) and to other institutional activities (including voluntary match) is reasonable in relation to the time and effort actually performed.

    • What are common errors in effort reporting?
      What are common errors in effort reporting?

      Total institutional effort for an individual (that is, the sum of the time/effort percentages devoted to each category of compensated, employment duties and activities) cannot, of course, exceed 100%.

      Errors occur when a researcher thinks that the “40 hour work week” has application to effort reporting. A researcher is improperly reporting effort if, proceeding on this assumption he/she reports an allocation of 50% of his/her total effort to a sponsored research project based on having devoted 20 hours per week to the project, when 20 hours actually reflects a smaller proportion of his/her overall work. Another researcher who has spent many hours mentoring a promising doctoral student may fall into the error of thinking, “I do that on my own time.” These well-intentioned but potentially costly mistakes all result from a failure to recognize that effort on a sponsored research project must be measured against “total institutional effort,” described above.

    • What happens if certify incorrect effort on my report?
      What happens if certify incorrect effort on my report?

      Certified effort reports provide the basis for institutional claims for reimbursement of direct and indirect charges under a federal contract or grant, and inaccurate or fraudulent reports may give rise to a False Claims Act lawsuit. An individual who is found to have violated this Act can be subjected to civil penalties of not less than $5,000 nor more than $10,000 for each violation; to criminal sanctions, if the violation was willful, of imprisonment for up to five years and fines of up to $25,000; and to an order to reimburse the government for three times the amount of damages sustained by the government because of the individual’s act. There have been reported instances where individual researchers have been required to make substantial civil monetary reimbursements to the federal government because of their involvement in improper effort reports. Of course, the institution can suffer as well for False Claims Act violations by its employees. Institutional sanctions may include the payment of costly settlements, as mentioned above, or even debarment from participating in federally funded research. The issue of compliance with effort reporting requirements should always be approached with these potentially heavy sanctions for violations in mind.

    • What happens if the effort report is inaccurate?
      What happens if the effort report is inaccurate?

      The employee should individually review the report to determine if the distribution of salary during the reporting period provides a reasonable representation of compensated effort during that period. “Reasonable” is defined as no more than + 5% variance in effort from the salary distribution percentages reported. If the salary distribution is not a reasonable representation of effort, the employee should make corrections below the printed percentages to indicate actual effort distribution, and then sign the certification statement. The employee should keep in mind that total effort must always equal 100%. If the employee changes one percentage figure to reflect a different level of effort, a corresponding change must be made in another category to keep total effort at 100%

      If the salary distribution presented on the effort report form is not a reasonable representation of the individual’s total compensated effort performed for UWG during the reporting period (within + 5% in any category), the individual should make appropriate changes before certifying. In the event the proportion of the effort on the sponsored project significantly exceeds the proportion of compensated time charged to the sponsored project account, no change in the charges to the sponsored project are generally required. If, however, the individual’s actual effort is significantly less than the proportion of his/her compensation that is charged to the sponsored project, reduction of the personnel costs charged to the sponsored project account during the reporting period will likely be necessary.

    • What are the categories (types) of effort?
      What are the categories (types) of effort?

      Direct Charge – All activities established by grant, contract or cooperative agreement with a sponsoring agency, and that are budgeted and accounted for separately by a sponsored account (Fund Code 20).

      Cost Share – Costs or specific activities assignable to a sponsored project that are not funded by that project. Committed cost share are costs and activities proposed to sponsors and awarded as such and/or is required as a condition of the award. Cost Share refers to a cash match of funds, cash cost sharing means that the funds are taken from a university account and deposited under a cost sharing number associated with your grant account.

      In-Kind Match - The reasonable value of personnel effort, equipment, materials or other property used in the performance of a statement of work. In-kind cost share is offered up by a grant recipient or a third party and is not a budgeted expense to a sponsor. In-kind cost sharing consists of goods and services donated to the project by UWG units or by external partners.

     
  • Subrecipient Monitoring

    No information currently available

  • Research Integrity
    Research Integrity

    As an institution devoted to the creation and dissemination of new knowledge through research and scholarship, UWG is committed to maintaining the truthfulness and integrity fundamental to these activities through the truthfulness and integrity fundamental to these activities through the responsible and ethical conduct of our faculty, staff, and students.  UWG is required to report to the Office of Research Integrity (ORI) annually and disclose any allegations of research misconduct.

    It is a fundamental responsibility of the UWG faculty, staff, students, and administration to maintain the trust of the public in all research and scholarly activity and to preserve the university's reputation for high standards of scholarly integrity.  All members of the UWG community have the responsibility to report suspected misconduct.

    Major Misconduct Offenses 

    • Fabrication of data
    • Plagiarism
    • Abuse of confidentiality
    • Falsification in research
    • Dishonesty in publication
    • Deliberate violation of federal, state, university regulations
    • Property violations
    • Failure to report observed major offenses
    • Retaliation
    • Responsible Conduct in Research and Scholarship Policy
      Introduction

      It is the policy of the University of West Georgia to maintain the highest standards of research and scholarship integrity regardless of the source of funding for that research or scholarship, or the type of research or scholarship being conducted. The University is committed to truth, accuracy, and intellectual honesty in research investigation and scholarship in the classroom, in proposing and conducting research and other forms of scholarship, in the reporting of results, and in relationships with colleagues. Fraud or misconduct in research or scholarship is an offense that severely damages the reputation of those involved, the university itself, and the entire educational community. The University of West Georgia complies with guidance issued by the federal Office of Research Integrity by promoting ethical conduct in academic research and scholarship and all aspects of the research enterprise.

      This policy is intended to provide guidelines for reporting and investigating allegations of research and scholarship misconduct. The University must assure that research and scholarly misconduct is reported accurately and in a timely manner while simultaneously assuring that allegations are handled fairly and effectively in order to protect the reputations of all concerned.

      This policy is adopted in compliance with various federal laws, regulations and policies dealing with misconduct in research and scholarship, including the Health Research Extension Act of 1985 (42 U.S.C. 289b), Public Health Service (PHS) regulations to be promulgated pursuant to that Act, and the policy adopted by the National Science Foundation (NSF), regulation 45 CFR Part 689. These laws, regulations, and policies require universities receiving federal funds to establish administrative procedures for reviewing allegations of misconduct in connection with research. This policy is in compliance with the Georgia Board of Regents Ethics Policy (BOR Policy Manual 8.2.20). This policy pertains to all research and creative activity conducted at UWG. The Associate Vice President for Research and Sponsored Operations, acting as the University’s Research Integrity Officer, is responsible for implementing this policy and for acting as liaison with external agencies and/or individuals making allegations.

      What is NOT Research or Scholarly Misconduct

      Honest errors or honest differences in interpretations or judgments of data are not considered to be misconduct. Findings of misconduct require significant departure from accepted practices of the scholarly community for maintaining the integrity of the research record; must have been committed intentionally, or knowingly, or in reckless disregard of accepted practices; and, the allegations must be proven by a preponderance of evidence.

      Policy Statement

      Misconduct or fraud in research or scholarship is the fabrication, falsification, plagiarism of data or related information in the proposing, performing, reviewing or reporting of research or other scholarship results, tampering with the data of others and other practices that materially deviate from those that are commonly accepted within the academic community. Misconduct in research and scholarship can be reported to any official of the University. Such a disclosure triggers an inquiry where the facts are examined and the University determines whether or not to conduct a full investigation. A full investigation involves an in- depth University Committee examination of the allegations. A recommendation is given to the President if disciplinary action against the researcher should be taken.

      Definitions

      Allegation: Any written or oral statement or other indication of possible research or other scholarly misconduct made to an institutional official.

      Complainant: An individual filing a written complaint of misconduct.

      Conflict of Interest: Real or apparent interference of one person’s interests with the interests of another person, where potential bias may occur due to prior or existing personal or professional relationships.

      Day or Days: Refers to working days.

      Evidence: Documents or statements of any type which support or refute allegations and testimony.

      Good Faith Allegation: An allegation made with the honest belief that research or scholarly misconduct may have occurred. An allegation is not in good faith if it is made with reckless disregard for, or willful ignorance of, facts that would disprove the allegation.

      Initial Inquiry: An information-gathering and initial fact-finding process to determine whether an allegation or apparent instance of misconduct warrants a formal investigation. An inquiry will be conducted with minimum publicity and maximum confidentiality.

      Investigation: A formal examination and evaluation of all relevant facts to determine if an instance of misconduct has taken place, to evaluate its seriousness, and if possible, to determine responsibility and the extent of any adverse effects resulting from the misconduct.

      Research Misconduct or Scholarly Misconduct: Fabrication or falsification of data, plagiarism, or other practices that seriously deviate from those that are commonly accepted within the academic or research community for proposing, conducting, or reporting research or scholarly activity. It does not include honest error or honest differences in interpretation or judgments of data. Additionally, this definition includes violations of University policy pertaining to research, including the failure to obtain proper review and approval by the University committees responsible for research involving human subjects, animal subjects, radioactive materials, and biohazards, as well as the failure to comply with rules and guidelines set forth by the committees responsible for these areas.

      NSF: The National Science Foundation.

      Plagiarism: The act of appropriating the literary composition of another, or parts or passages of his or her writings, or the ideas or language of the same, and passing them off as the product of one’s own mind. It involves the deliberate use of any outside source without proper acknowledgment. Plagiarism is scholarly misconduct whether it occurs in any published work or in applications for funding.

      PHS: The Public Health Service.

      President: The President of the University of West Georgia.

      Respondent: An individual who is the subject of an inquiry or investigation.

      University: The University of West Georgia.

      Provost: The Provost and Vice President for Academic Affairs of the University of West Georgia.

      Reporting of Possible Misconduct

      All employees or individuals associated with the University of West Georgia are expected to report observed, suspected, or apparent misconduct to the Research Integrity Officer (Associate Vice President for Research and Sponsored Operations). If an individual is unsure as to whether a suspected incident falls within the definition of research or other scholarly misconduct, he/she should contact the Research Integrity Officer to discuss the suspected misconduct informally. This consultation will be kept confidential to the extent permissible by law.

      Ultimately, all allegations of misconduct will be made in writing, signed by the Complainant, and will be made in confidence directly to the Research Integrity Officer. Upon receipt of a written complaint, the Research Integrity Officer will inform the Provost and Vice President for Academic Affairs, the University General Counsel, and the Respondent of the allegation.

      Every effort should be made to resolve the situation at this level. In the event that the person making the allegation considers the Research Integrity Officer and/or the Provost to have a conflict of interest, the allegation may be reported directly to the President. Actions constituting research or other scholarly misconduct as defined in this document will not be actions that can be grieved through the Faculty Grievance Process.

      Should attempts to resolve the situation be unsuccessful, the Research Integrity Officer will review the written complaint and consult with the University General Counsel to determine whether probable cause exists to conduct an Initial Inquiry, whether PHS or NSF support is involved, and whether the allegation falls under either the PHS or NSF definition of research or other scholarly misconduct. Sufficient evidence or information to permit further inquiry into an allegation does not always exist. If the issue involved is found not to warrant further inquiry, satisfactory resolution through means other than this policy should be sought and to the extent possible, the identity of the complainant(s) will remain confidential.

      Initial Inquiry

      Following the preliminary assessment, if the Research Integrity Officer, in consultation with the Provost and the University General Counsel, determines that the allegation provides sufficient information to allow specific follow-up, he or she will notify in writing, with return receipt, the Respondent’s College Dean and the Respondent, and immediately begin the Initial Inquiry. At this point, if external funding is involved, the funding agency should be notified that an investigation has been initiated. The purpose of the Initial Inquiry is to make a preliminary evaluation of the available evidence and testimony of the Complainant, the Respondent, and key witnesses to determine whether there is sufficient evidence of possible research or other scholarly misconduct to warrant an investigation. The purpose of the Initial Inquiry is NOT to reach a final conclusion about whether misconduct definitely occurred or who was responsible. If it is determined that an Initial Inquiry is necessary, every reasonable effort will be made to protect the identity of the individual(s) involved (if the process reaches the Investigative Phase, however, the right of the Respondent to confront the Complainant requires that the identity of the Complainant be revealed).

      The Research Integrity Officer is responsible for forming an Inquiry Committee, the membership of which will be determined by the Research Integrity Officer, the Dean of the Respondent’s College, and the Provost.

      Inquiry Committee

      If it is determined that the formation of an Inquiry Committee is necessary, the Committee and Committee Chair will be appointed within 10 days of the initiation of the Inquiry. The Inquiry Committee will consist of a minimum of three persons who do not have real or apparent conflicts of interest in the case, are unbiased, and have the necessary and appropriate expertise to carry out a thorough and authoritative evaluation of the relevant evidence, interview the principals and key witnesses, and to conduct the Inquiry. These individuals may be faculty, subject matter experts, administrators, lawyers, or other qualified persons, and they may be internal or external the University.

      Members of the Committee and experts will agree in writing to observe the confidentiality of the proceeding and any information or documents reviewed as part of the Inquiry. Outside of the official proceedings of the Committee, they may not discuss the proceedings with the Respondent, Complainant, witnesses, or anyone not authorized by the Research Integrity Officer to have knowledge of the Inquiry.

      The Research Integrity Officer will notify the Respondent of the proposed Committee membership within five (5) days of its formation, in writing, with return receipt. If the Respondent submits a written objection to any appointed member of the Inquiry Committee or expert based on bias or conflict of interest, within five (5) days, the Research Integrity Officer will immediately determine whether to replace the challenged member or expert with a qualified substitute.

      Notification of the Appropriate Parties

      Upon initiation of the Inquiry, the Research Integrity Officer will notify the Respondent in writing, with return receipt, that a complaint of misconduct has been received and advise the Respondent of the Inquiry. The notification will specify the following:

      • The research or other scholarly project in question
      • The specific allegations
      • The definition of the misconduct
      • The identification of PHS or NSF funding, if involved
      • The list the names of the members of the Inquiry Committee (if appointed) and experts (if any)
      • An explanation of the Respondent’s opportunity to challenge the appointment of a member of the Committee or expert for bias or conflict of interest
      • The Respondent’s right to be assisted by counsel, to be interviewed, to present evidence to the Committee, and to comment on the Inquiry report
      • The Respondent’s obligation as an employee of the University to cooperate with the investigation, and
      • A description of the University’s policy on protecting the Complainant against retaliation and the need to maintain the Complainant’s confidentiality during the Inquiry, and any subsequent

      Simultaneously, the Respondent will be notified that the relevant research records will be located, collected, inventoried, and secured in order to prevent the loss, alteration, or fraudulent creation of records (research records produced under federal grants, cooperative agreements, and most contracts are the property of the University, and employees cannot interfere with the University’s right of access to them). The documents and materials to be sequestered will include all of the original items (or copies, if originals cannot be located) that may be relevant to the allegations. Additionally, records from other individuals, such as co-authors, collaborators, or Complainant(s) may need to be sequestered. The Research Integrity Officer will obtain the assistance of the Respondent’s supervisor and University General Counsel in this process, as necessary. If the Respondent is not available, sequestration may begin in the Respondent’s absence. The Respondent will not be notified in advance of the sequestration of research records.

      To protect the rights of the Respondent and all other involved individuals, as well as to enable the University and its representatives to meet their institutional, regulatory, and legal responsibilities, documentation of custody must be ensured and maintained, with the originals kept intact and unmodified. Therefore, a copy of a dated receipt should be signed by the sequestering official and the person from whom an item is collected, and a copy of the receipt should be given to the person from whom the record is taken.

      If it is not possible to prepare a complete inventory list at the time of collection, one should be prepared as soon as possible, and then a copy should be provided to the person from whom the items were collected within ten working days of the request. If the copy cannot be delivered to the individual within ten working days, a written explanation of the relevant circumstances, along with the anticipated delivery date, will be transmitted in confidence to that individual. This explanation will become a part of the Inquiry records. When the requested copy is delivered to the person from whom the original item has been taken, a dated receipt will be signed by that person and the designated University official, with copies provided to both individuals. The Research Integrity Officer will be responsible for maintaining files of all documents and evidence and for the confidentiality and the security of the files.

      The Research Integrity Officer and Provost, in consultation with appropriate (including legal) advisor(s), will determine what additional notification(s) is necessary, including if and when external funding agencies should be notified. This notification will include a complete description of the evidence and will be provided by the Provost. The Research Integrity Officer, the Provost, and/or the Inquiry Committee may meet separately with the Respondent and Complainant and will review all pertinent and reasonable documentation to determine if a formal Investigation should be recommended. Refusal on the part  of the Respondent to cooperate will be grounds for the recommendation for an Investigation.

      The Respondent may consult with legal counsel or a non-lawyer personal advisor (who is not a principal or witness in the case) to seek advice, and may be accompanied by legal counsel or a non-lawyer personal advisor to any meeting on this matter. The Respondent’s legal counsel’s role, as well as the personal advisor’s role is limited to advising the Respondent. Neither the legal counsel nor the personal advisor may participate in any administrative proceedings.

      Charge to the Committee and the First Meeting

      The Research Integrity Officer, or his or her designee, will prepare a charge for the Inquiry Committee that states the purpose of the Inquiry, describes the allegations and any related issues, outlines the appropriate procedures for conducting the Inquiry, assists the Committee with organizing plans for the Inquiry, and answers any questions raised by the Committee. The Research Integrity Officer, his or her designee, and the University General Counsel will be present or available throughout the Inquiry  to advise the Committee as needed.

      Conducting Interviews

      The purpose of an interview at the Inquiry stage is to allow each Respondent, Complainant, or witness to tell his or her side of the story. Before an interview, the Committee should provide each witness with a summary of the matters or issues intended to be covered at the interview. If the Committee raises additional matters, the witness should be given an opportunity to supplement the record in writing or in another interview. Interviews with the Respondent will be transcribed or tape recorded. Interviews with anyone else will be summarized, tape-recorded, or transcribed. A transcript or summary of the interview will be provided to each witness for review and correction of errors. Witnesses may add comments or information. Changes to the transcript or summary will be made only to correct factual efforts.

      Witnesses may be accompanied and advised by legal counsel or by a non-legal advisor who is not a principal or witness in the case. However, the counsel or advisor may only advise the witness and may not participate directly in the interview. Witnesses will respond directly to the interview questions.

      If the Respondent admits to the misconduct, he or she will be asked immediately to sign a statement attesting to the occurrence and extent of the misconduct. Normally, an admission is a sufficient basis to proceed directly to an Investigation. However, the admission may not be a sufficient basis for closing a case. Further investigation may be needed to determine the extent of the misconduct or to explore additional issues. If an admission is made, the Research Integrity Officer, in consultation with University General Counsel and other appropriate persons, will determine whether there is a sufficient basis to close a case, after the admission is fully documented and all appropriate procedural steps are taken.

      Committee Deliberations

      The Inquiry Committee will evaluate the evidence and testimony obtained during the Inquiry. After consultation with the Research Integrity Officer, Provost, and University General Counsel, the Committee members will decide whether there is sufficient evidence of possible misconduct to recommend further investigation. The scope of the Inquiry does NOT include deciding whether misconduct occurred or conducting exhaustive interviews and analyses.

      The Inquiry Report

      The Inquiry will be completed and a written report of the findings will be prepared by the committee and submitted to the Provost within 45 days following its first meeting, unless the Research Integrity Officer approves an extension for good cause. If the Inquiry cannot be completed within 60 days, a report will be made to the Provost citing progress to date, the reasons for the delay, and the estimated completion date. The Respondent and any other individual(s) involved will be informed of the delay.

      The final report will contain the name and title of the committee members and experts, if any, the allegations, whether it involves a PHS or NSF funded project, a summary of the Inquiry process used, a list of the records reviewed, summaries of any interviews, a description of the evidence in sufficient detail to demonstrate whether an Investigation is warranted or not, the Committee’s determination as to whether an Investigation is recommended, and whether any other actions should be taken if an Investigation is not recommended. University General Counsel will review the Report for legal sufficiency. The Respondent will be provided a copy of the Inquiry Report, with return receipt. The Complainant will be provided with those portions of the draft report that address the Complainant’s role and opinions in the Investigation. The Research Integrity Officer may establish reasonable conditions for review to protect the confidentiality of the draft report. Within 15 days of the receipt of the draft report, the Respondent and Complainant will provide their comments, if any, to the Inquiry Committee.

      Any comments that the Respondent or Complainant submits on the draft report will become part of the final report and record. Based on the comments, the Inquiry Committee may revise the report as appropriate.

      If the University plans to terminate an Inquiry of an allegation of misconduct on a PHS or NSF funded project, for any reason, without completing all relevant requirements under the applicable subparts or sections (e.g., 50.103 (d) for PHS and

      • for NSF), a report of such planned termination, including a description of the reasons for such termination will be made to the agency’s cognizant office, which will then decide whether further Inquiry should be

      If the Inquiry reveals substantial evidence of misconduct, the Research Integrity Officer will transmit the final report and any comments to the Provost who will make the determination of whether findings from the Inquiry provide sufficient evidence of possible research or other scholarly misconduct to justify conducting an Investigation. The Inquiry is completed when the Provost makes this determination.

      The Provost, in consultation with the Research Integrity Officer, the University General Counsel, and other appropriate parties, will reach his/her determination on a case-by-case-basis, considering all relevant factors, including, but not limited to:

      1. the accuracy and reliability of the source of the allegation of misconduct
      2. the seriousness of the alleged misconduct
      3. the scope of the alleged incident and the context in which it became known, and,
      4. other information obtained during the

      If an Investigation is initiated, any outside sponsoring agency that may be involved or have an interest in the alleged misconduct will be notified. The Provost, in consultation with the Research Integrity Officer and University General Counsel, will determine what this notification will include and to whom it will be directed. The Complainant and the Respondent will be notified in writing, with return receipt, when an Investigation will follow.

      If the Inquiry does not produce substantial evidence of misconduct, the Provost will inform the person who made the allegation, the Respondent, the University General Counsel, the President, and any other individual(s) involved in the Inquiry to whom the identity of the Respondent was disclosed, and the matter will be closed. The University will make diligent efforts to restore the reputation of the Respondent by providing all relevant parties with a factual report of the outcome and the conclusions of the Inquiry. The University will maintain sufficiently detailed documentation of the Inquiry to enable it to respond to potential requests to review the reasons for determining that an Investigation was not warranted. These records  will be maintained in the Office of the Associate Vice President for Research and Sponsored Operations in a secure manner in accordance with University System of Georgia Records Retention Policies.

      If the allegation had been made in good faith, the University will make diligent efforts to protect against retaliation the positions and reputations of the Complainant(s) and other individuals who have cooperated with the University’s Inquiry. Any alleged or apparent retaliation will be reported immediately to the Research Integrity Officer or Provost. If either the Research Integrity Officer or Provost is considered to have a conflict of interest, the alleged or apparent retaliation will be reported directly to the President.

      Interim Administrative Actions

      Upon recommendation of the Research Integrity Officer, the Provost, and the University General Counsel, the Dean of the Respondent’s College may meet with the Respondent for the purpose of imposing temporary interim administrative actions prior to the completion of an Inquiry or Investigation, if necessary, to safeguard the integrity of the research or scholarly activity, prevent inappropriate use of sponsored funding, or otherwise protect the interests of a sponsor, the University, or the public. If temporary suspension of duties is imposed, such suspension will be without loss of pay, pending the conclusion of the process described in this document. The Respondent will be informed of the reasons for the action taken and afforded the opportunity to oppose the action.

      Formal Investigation

      The purpose of the Formal Investigation is to explore in detail the allegations, to examine the evidence in depth, and to determine specifically whether misconduct has been committed, by whom, and to what extent. The Investigation will also determine whether there are additional instances of possible misconduct that would justify broadening the scope beyond the initial allegations. This is particularly important where alleged misconduct involves clinical trials or potential harm to human subjects or the general public or if it affects research that forms the basis for public policy, clinical practice, or public health practice.

      The Research Integrity Officer will notify the Respondent, in writing, with return receipt, as soon as reasonably possible after the determination is made to open an Investigation. The notification will include a copy of the Inquiry Report, the specific allegations, the sources of funding, if any, the definition of scholarly misconduct, the procedures to be followed in the Investigation, including the appointment of the Investigation Committee and experts, the opportunity of the Respondent to be interviewed, to provide information, to be assisted by counsel, to challenge the membership of the committee and experts based on bias or conflict of interest, and to comment on the draft report. The Research Integrity Officer will immediately sequester any additional pertinent research records that were not previously sequestered during the Inquiry. This sequestration will occur before or at the time the Respondent is notified that an Investigation has begun. The procedures to be followed for sequestration during the Investigation are the same procedures that apply during the Inquiry.

      The Research Integrity Officer is responsible for conducting or designating others to conduct the Investigation. In cases where the allegations and apparent evidence are straightforward, such as an allegation of plagiarism, or simple falsification, or an admission of misconduct by the Respondent, the Research Integrity Officer may choose to conduct the Investigation directly or designate another qualified individual to do so. In such cases, the Investigation official will obtain the necessary expert and technical advice to consider properly all scientific issues.

      Investigative Committee

      In complex cases, the Research Integrity Officer will appoint an Investigation Committee (hereafter known as the “Investi- gative Committee”) within 10 days of the notification to the Respondent that an investigation is planned. The Research Integrity Officer will be a member of the Committee, and will serve as Chairperson. The Investigative Committee should consist of at least three individuals who do not have real or apparent conflicts of interest in the case, are unbiased, and have the necessary expertise to evaluate the evidence and issues related to the allegations, interview the principals and key witnesses, and to conduct the investigation. These individuals may be scientists, administrators, subject matter experts, lawyers, or other qualified persons, and they may be internal or external to the University. Individuals appointed to the Investigative Committee may also have served on the Inquiry Committee.

      Members of the Committee and experts will agree in writing to observe the confidentiality of the proceedings and any information or documents reviewed as part of the Inquiry. Outside of the official proceedings of the Committee, they may not discuss the proceedings with the Respondent, Complainant, witnesses, or anyone not authorized by the Research Integrity Officer to have knowledge of the Inquiry.

      The Research Integrity Officer will notify the Respondent of the proposed Committee membership within five (5) days of its formation, in writing, with return receipt. If the Respondent submits a written objection to any appointed member of the Investigative Committee or expert based on bias or conflict of interest within five (5) days, the Research Integrity Officer will immediately determine whether to replace the challenged member or expert with a qualified substitute.

      The Respondent may consult with legal counsel or a non-lawyer personal advisor (who is not a principal or witness in the case) to seek advice and may be accompanied by legal counsel or a non-lawyer personal advisor to any meeting on this matter. The Respondent’s legal counsel’s role, as well as the personal advisor’s role is limited to advising the Respondent. Neither the legal counsel nor the personal advisor may participate in any administrative proceedings.

      Once formed, the Investigative Committee will, in consultation with the University General Counsel, establish the procedures to be followed in conducting the Investigation. The Complainant and Respondent will be fully informed of the procedures.

      The Investigative Committee will initiate the Investigation within 30 days of the completion of the Inquiry, and will take no more than 60 days to complete the Investigation, prepare a report of its findings, including recommended action(s), and submit the report to the Research Integrity Officer, the Provost, and the President. In undertaking this investigation, the Investigation Committee will act promptly, ensure fairness to all, secure the necessary and appropriate expertise to carry out a thorough and authoritative evaluation of the relevant evidence, and take precautions against real or apparent conflicts of interest

      Charge to the Committee and the First Meeting

      The Research Integrity Officer, with the assistance of the University General Counsel, will convene the first meeting of the Investigation Committee. The Research Integrity Officer will define the subject matter of the Investigation in a written charge to the Committee. The charge will describe the allegations and related issues identified during the Inquiry, define research and other scholarly misconduct, and identify the name of the Respondent.

      The Investigation may consist of a combination of activities including but not limited to: (1) examination of all documentation including, but not necessarily limited to, relevant research records, computer files, proposals, manuscripts, publications, correspondence, memoranda, and notes of telephone calls; (2) review of the report from the Inquiry; and, (3) interviews of parties and witnesses who may have been involved in or have knowledge about the case. Interviews of the Respondent will be tape recorded or transcribed. All other interviews will be transcribed, tape recorded, or summarized. Summaries or transcripts of all interviews will be prepared, provided to the interviewed party for comment or revision, and included as part of the investigatory file.

      Investigation Report

      At the conclusion of the Investigation, the Investigation Committee will prepare a written Investigation Report. A draft Investigation Report will go through the review below and changes may be made. After this review is complete and any changes have been made, the Research Integrity Officer will submit the final Investigation Report to the Provost. The Investigation Report will be organized according to the following outline, except when special factors suggest a different approach.

      1. Background
        1. Chronology of events
        2. Public health issues
      2. Allegations
      3. Sponsored Support or Application(s) (by Allegation)
      4. University Inquiry: Process and Recommendation
        1. Composition of committee
        2. Individuals interviewed
        3. Evidence sequestered and reviewed
      5. University Investigation: Process
        1. Composition of Investigation Committee
        2. Individuals interviewed
        3. Evidence sequestered and reviewed
      6. University Investigation: Analysis of each Allegation
        1. Background
        2. Analysis of all of the relevant evidence and specific identification of evidence supporting the finding
        3. Conclusion: Research or other scholarly misconduct or no misconduct
        4. Effect of misconduct (for example, potential harm to research subjects, reliability of data, publications that need to be corrected or retracted, )
      7. Recommendation of Investigation Committee
      8. Attachments
      Comments on the Draft Investigation Report
      1.       University General Counsel

      The Research Integrity Officer will provide the University General Counsel with a copy of the draft Investigation Report for a review of its legal sufficiency. The General Counsel’s comments will be incorporated into the draft Investigation Report as appropriate

      2.       Respondent

      After the University General Counsel has reviewed the draft Investigation Report and the comments of the General Counsel have been incorporated into the draft report as appropriate, the Research Integrity Officer will provide the Respondent with a copy of the draft report. The Respondent will be allowed ten days to review and comment on the draft report and Respondent’s written comments will be attached to the final Investigation Report. The findings of the final Investigation Report will take into account the Respondent’s comments in addition to all of the other evidence.

      3.       Complainant

      After the University General Counsel has reviewed the draft Investigation Report and the comments of the General Counsel have been incorporated into the draft report as appropriate, the Research Integrity Officer will offer the Complainant an opportunity to review those portions of the draft Investigation Report that address the Complainant’s role and opinions in the Investigation. The Complainant will be allowed ten days to review and comment on the draft Investigation Report. The Complainant’s written comments will be attached to the final Investigation Report. The draft Investigation Report will take into account the Complainant’s comments, in addition to all other evidence.

       4.       Confidentiality

      In distributing the draft Investigation Report, or portions thereof, the Research Integrity Officer will inform each recipient of the confidentiality under which the draft Investigation Report is made available and may establish reasonable conditions consistent with laws of the State of Georgia and federal law to ensure this confidentiality during the Investigation.

       Finalizing the Investigation Report

      After the Investigation Committee has received comments to the Investigation Report, the Investigation Committee will review those comments and make any changes to the Investigation Report that the Investigation Committee deems necessary. The Investigation Committee will then issue its final Investigation Report. The Research Integrity Officer will maintain a file containing the final Investigation Report and the documentation to substantiate the findings of the Investigation Committee.

       Investigation Decision and Notification
      1. If the Investigation Committee determines that, by a preponderance of the evidence, no research or other scholarly misconduct has occurred, it will recommend such a finding to the
      2. If the Investigation Committee determines that, by a preponderance of the evidence, that research or other scholarly misconduct has occurred, it will recommend such a finding to the

      The Research Integrity Officer will provide the Provost with a complete copy of the final Investigation Report. Based on a preponderance of the evidence, the Provost will make the final determination as to whether to accept the recommendation of the Investigation Report, its findings, and recommended University actions, if any. The Provost may also return the Investigation Report to the Investigation Committee with a request for further fact-finding or analysis. The determination of the Provost, together with the Investigation Report, constitutes the final Investigation Report for purposes of a Sponsor’s review.

      When a final decision has been reached, the Research Integrity Officer will notify both the Respondent and the Complainant in writing of that decision. In addition, the Provost will, after consultation with the University General Counsel, determine whether law enforcement agencies, professional societies, professional licensing boards, editors of journals in which falsified reports may have been published, collaborators of the Respondent in the work, or other relevant parties should be notified of the outcome of the matter. If a Sponsor is involved, the Research Integrity Officer will also notify the Sponsor of the Investigation and its outcome. The Research Integrity Officer is responsible for ensuring compliance with all notification requirements of funding or sponsoring agencies.

      Time Limit for Completing the Investigation

      The Investigation Committee will complete the Investigation and submit its Investigation Report to the Provost no more than 90 calendar days after the decision of the Provost that an Investigation was necessary, unless the Research Integrity Officer approves an extension for good cause. If the Research Integrity Officer approves an extension, the reason for the extension will be entered into the records of the case and included in the final Investigation Report. The Respondent will also be notified of any extension.

      The Investigation is completed when the Provost determines whether research or other scholarly misconduct has occurred. This determination will be made within 15 days of the Provost’s receipt of the Investigation Report. Any extension of time, or any request by the Provost that the Investigation Committee conduct additional investigation or analysis, will be based on good cause and incorporated into the final Investigation Report.

      Requirements for Reporting to ORI (if applicable)

      The Research Integrity Officer will ensure compliance with the following requirements in those cases where an allegation of research or other scholarly misconduct involves Public Health Service support or sponsorship:

      1. When an admission of research or other scholarly misconduct is made, the Research Integrity Officer may contact the ORI for consultation and advice. Normally, the individual making the admission will be asked to sign a statement attesting to the occurrence and extent of The University will not accept an admission of research or other scholarly misconduct as the basis for closing a case or not undertaking an Investigation without prior approval from the ORI.
      1. The decision of the University to initiate an investigation must be reported in writing to the Director of the ORI on or before the date the Investigation begins. At a minimum, the notification should include the name of the person(s) against whom the allegations have been made, the general nature of the allegation, and the PHS application or grant number(s) involved. Information provided to the Director of the ORI through this notification will be held in confidence by ORI to the extent permitted by law, will not be disclosed as part of the peer review and Advisory Committee review processes, but may be used by the Secretary of Health and Human Services, and any other officer or employee of the Department of Health and Human Services to whom similar authority may be delegated, in making decisions about the award or continuation of
      1. If the University plans to terminate an Inquiry or Investigation for any reason without completing all relevant requirements under 42 CFR 50.103(d), the Research Integrity Officer will submit to ORI a report of the planned termination, including a description of the reasons for the termination. ORI will then decide whether further investigation should be
      1. The Research Integrity Officer will notify the ORI of the final outcome of the The Research Integrity Officer will make the Investigation Report and the documentation necessary to substantiate the findings of the Investigation Committee available to the Director of the ORI, upon request. The Director of the ORI will decide whether the ORI will either proceed in its own investigation or will act on the findings of the University. The final Investigation Report submitted to the ORI must describe the policies and procedures under which the Investigation was conducted, how and from whom information was obtained relevant to the Investigation, the findings, the basis for the findings, the actual text or an accurate summary of the views of any individual(s) found to have engaged in the misconduct, and a description of any sanctions taken by the University.
      1. If the University determines that it will not be able to complete the Investigation in 120 days, the Research Integrity Officer will submit to the ORI a written request for an extension and an explanation for the delay that includes an interim report on the progress to date and an estimate for the date of completion of the Investigation Report and any other necessary steps. Any consideration for an extension must balance the need for a thorough and rigorous examination of the facts versus the interests of the Respondent and the PHS in a timely resolution of the If the request is granted, the University must file periodic progress reports as requested by the ORI. If satisfactory progress is not made in the University’s Investigation, the ORI may undertake an Investigation of its own
      1. Upon receipt of the final Investigation Report and supporting materials, the ORI will review the information in order to determine whether the Investigation has been performed in a timely manner and with sufficient objectivity, thoroughness, and competence. The ORI may then request clarification or additional information and, if necessary, perform its own
      1. In addition to sanctions that the University may decide to impose, the Department of Health and Human Services also may impose sanctions of its own upon investigators or the University based upon authorities it possesses or may possess, if such action seems appropriate.
      1. The Research Integrity Officer will keep the ORI apprised of any developments during the course of the Investigation which disclose facts that may affect current or potential Department of Health and Human Services funding for the individual(s) under investigation or that the Public Health Service needs to know to ensure appropriate use of federal funds and otherwise protect the public
  • Compliance Toolbox

     UWG Compliance Resources

    Compliance Forms & Instructions

    Forms
    Instructions
    Institutional Review Board (IRB) Please see the IRB Forms page for required application forms
    Significant Financial Interest (SFI) Form Policy
    Subrecipient v Contractor determination form  
    Subaward: Award Specific Risk Assessment  
    Subaward: Organizational Risk Assessment  
    Responsible Conduct of Research Certification CITI Instructions
    FCOI Disclosure Form To be used if there is a conflict of significant financial interest