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Research Compliance: Models for Managing - Panel
Carol Blum, Council on Governmental Relations (COGR)Peter Dunn, Purdue University
Ara Tahmassian, Boston University
In Perspective• Increase in:– Number – Type– Complexity
• Changes in Operation• Breadth of Impact
Risks of Shifting Landscape• High-Profile Events• High Profile Attention• Changes in Prosecutorial Approach and
Settlement Outcomes
Organizational Impact• In the past:– Add-on to sponsored programs– Committees self-managing– Special needs addressed case-by-case
• Currently:– Alter reporting structures– Staff support for various functions– Breadth of issues mitigated by uniform approaches
What is compliance?
• It is the proverbial Hydra the multi-headed monster!
• You need to start by clearly defining the scope• Is limited to certain areas (e.g. non-financial,
financial) or all encompassing?• Is it centralized in one office with responsibility
to develop and implement?• Is it a coordinating office that acts as a quality
assurance or auditing office?
Structure• Where does it report?
– Depends on the institutional organization
• What is the authority?– Depends on the scope– Should have clear definition and limits– Generally is shared and matrix
• Who reports to the Office– Depends on the authority and scope
Boston University and Boston Medical Center
• BU has:– Two campuses, 16 Schools, 2 Graduate Divisions and an Honors
College– Charles River Campus (CRC) with 13 Schools, Honors College and 1
Graduate Division– Medical Campus with 3 Schools and Graduate Medical Sciences– Number of centers and Institutes– A University Provost and Chief Academic Officer and Medical
Campus Provost• BMC is the affiliated Hospital which is a separate legal entity
and has its own research program
Office of Research Compliance• Was created in October of 2006 to unify the research
compliance and support for both BU and BUMC• Prior to that each campus and BMC had its own separate
structure (e.g. most of the assurances, permits, licenses, policies, procedures, etc.)
• For all practical purposes in many instances they were separate entities
• Difficult for faculty to collaborate from one side with the other
Office of Research Compliance, (Cont’d)
• Office of responsible for all non-financial research compliance issues
• Operational units (e.g. fCOI, Animal Care and Use, Committees, RCRC, Research Integrity, EHS, Research Occupational Health, etc.) with the exception of BMC Sponsored Program were put under the ORC as “shared services”
• Unified all permits, assurances, policies, procedures, etc.
Office of Research Compliance Reporting
• Associate VP Research Compliance has a matrix reporting to– CEO of BMC– VP Research and Associate Provost for Research at CRC– Provost of Medical Campus (has its own Associate Provost for
Research)• Advantage is direct contact with those in position to
make decision• Some challenges with building consensus for three needs
Does it Work?
• The program and structure was based on what was best for meeting the needs of the entities and making collaborative research easier while ensuring compliance
• Overall it has worked well • Eliminated many duplicative programs and streamlined processes• Faculty have easier time collaborating under single set of requirements• Funding methodology had to be developed to allocate costs in fair way• Program has to make sure it is seen as unbiased and cater to specific
needs of each entity (e.g. clinical, research, undergraduate)
Challenges• Providing support personnel at two locations• Human Subject is still two separate programs due to
different needs at Medical Campus vs. Charles River Campus which is mainly social behavioral and student research programs
• Two different grant administration offices due to legal requirements requires sub-awards
• Contract was simplified by BU Office doing all contract and cost transfers for expenses
Factors You Should Consider
The BU structure and reporting was based on the unique organization of the BU and BMC. The questions that you should consider in designing your program include:• Do you have multiple campuses?• Is all research administered through one entity?• Is there a single individual responsible for all research
at your institution?• Will a centralized support structure work for you?
Purdue University• Indiana’s Land Grant University• A university system consisting of four campuses:
– West Lafayette– Indiana University Purdue University Fort Wayne (IPFW)– Calumet– North Central
• No (human) Medical School• College of Pharmacy, School of Nursing, School of
Veterinary Medicine
Purdue University, (cont’d) • Purdue West Lafayette manages research compliance (OVPR,
REM/Physical Facilities) and sponsored projects (Sponsored Program Services) for the Purdue University System.
• Centrally managed research compliance functions for all campuses of the University System. – Reporting to the Vice President for Research
• Responsible for protection of research subjects, conflict of interest, biosafety, research security (export control and classified research)
– Reporting to the Vice President for Physical Facilities• Radiological and Environmental Management (REM) responsible for
oversight of general lab safety, chemical safety, use of radiation and radiation-producing devices (including laser safety), research use of controlled substances.
OVPR Research Compliance – Components– Regulatory oversight committees which review, approve, oversee execution of protocols; staff who
evaluate financial interest disclosures and manage COIs and oversee Select Agent Program.• Human Research Protection Program• Purdue Animal Care and Use Committee/Laboratory Animal Program• Institutional Biosafety Committee• Conflict of Interest• Select Agent Program
– Research Regulatory Compliance• Identifies regulatory issues associated with proposals after submission• Ensures that active, congruent protocols and/or Technology Control Plans exist before release of funds and
throughout life of project• Monitors required RCR Training• Assists in project closeout (delinquent technical/invention reports)
– Research Quality Assurance• Reviews process to ensure is working and produces desired impact• Post approval monitoring for regulatory oversight committees• Support external audits• [Good Laboratory Practice Quality Assurance]
How is it Working?Advantages:• Separation in OVPR of oversight, compliance, and quality assurance functions
ensures that – Oversight faculty/staff not overworked, – Different individuals responsible for protocol development/review (good cop) and post-approval
monitoring (bad cop)– Dedicated staff available for monitoring sponsored program compliance– Separate staff without other line responsibilities focus on quality assurance.
Challenges:• Split responsibilities between OVPR and OVPF requires continuing communication
and managing relationships.• Regional campus faculty question central management by WL for system; need to be
reminded of costs and risks of campus specific distributed system
