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Compliance Policies & Practices

These entries  provide  a mostly comprehensive list of compliance topics; please note that for an individual project, only a handful of these issues require attention. The External Grants Office is happy to help identify and provide guidance on compliance issues pertinent to your project.

Acquisition of Equipment: CSB/SJU's threshold for capitalizing equipment is a purchase price of $5,000 or greater and useful life of more than one year.  If a grant award allows purchase of equipment, the PI should, where reasonably possible, obtain at least three bids from separate vendors.  Upon selecting one, he/she should document the reason for selecting that vendor over the others.

Animal Research: CSB/SJU do not currently hold the appropriate federal assurances for animal research.  No federal proposals involving animal research can be submitted.   For non-federal proposals involving animal research, the PI should consult with the Institutional Animal Care and Use Committee (IACUC).

Data Management Plan: The National Science Foundation requires a data management plan for each new proposal submitted on or after January 18, 2011 that describes plans for the management and sharing of the products of research, or to assert the absence of the need for such plans. The plan for each project will, by necessity, be different.  However, all CSB/SJU grant seekers should consult and coordinate their data management plans with the institutional data management plan being developed by the CSB/SJU libraries. 

Financial Conflict of Interest: Federal regulations require institutions to have policies and procedures in place that ensure that investigators disclose any significant financial interest that may present an actual or potential conflict of interest in relationship to externally sponsored projects.  External Grants staff request PIs seeking federal grants to make disclosure prior to the submission of a proposal for funding.    The Provost reviews those disclosures.  In cases where a PI has a conflict of interest, the Provost is responsible for devising a strategy to satisfactorily manage, reduce or eliminate the conflict prior to the expenditure of any funds on an award.  If a new reportable significant conflict of interest arises at any time during the period after the submission of the proposal through the period of the award, the filing of a disclosure is also required.

Human Subjects Research: All research involving human subjects should meet federal and relevant professional standards, regardless of funding source, and whether carried out by faculty or students.   Research plans that involve research on humans must be reviewed by the College of Saint Benedict/Saint John's University Institutional Review Board (IRB).  The principal investigator is responsible for submitting an application to the IRB.  The IRB is responsible for determining if the research plan is exempt from further IRB oversight (this does not mean the PI is exempt from protecting human research subjects from harm), or if the research plan requires expedited or full board review.  If a proposed grant-funded project involves human subjects research, External Grants staff may act as liaison between the PI, IRB and funding agency.  Typically the timing of IRB approval is after a proposal is submitted, when it appears likely or certain that the funding agency will make an award.  IRB approval is required before the research can begin.