International Research and Service Projects: Risk Management Procedures

INTERNATIONAL RESEARCH AND SERVICE PROJECTS:
 RISK MANAGEMENT PROCEDURES*

Effective Date: June 14, 2007

This memorandum outlines Columbia University's risk management procedures (the "Procedures") for international research and service projects ("Projects").  The University supports and encourages international research and service, but recognizes that the Projects involve special risks that should be considered and addressed.

The Procedures are not designed to second guess the scholarship of a Project or to hinder the grant application process.  At the same time, they provide a mechanism for the University to inquire as to what risks should be considered and how they should be managed.  In addition, the Procedures will assist the University in the development of a data base of information relating to Projects and to better provide the investigators at the University with international research expertise.

I.  Committees

The University will form two standing committees: the International Research Committee (the "IR Committee") and the International Research Advisory Committee (the "IR Advisory Committee"), each of whose members will be appointed by the Executive Vice President for Research (the "EVPR") in consultation with the Office of the Provost.

The IR Committee will consist of two Officers of Instruction and/or Officers of Research and one representative of each of the Office of the General Counsel ("OGC"), the Office of Research Administration ("Research Administration"), the Finance Division and the Office of Research Compliance and Training ("ORCT").  The IR Committee will carry out the Procedures and will report to the IR Advisory Committee on a quarterly basis.

The IR Advisory Committee will consist of Officers of Instruction, Officers of Research and senior administrators who have had experience working on Projects.  The IR Advisory Committee will provide oversight of the IR Committee and will advise on policies and procedures relating to Projects. 

The EVPR will appoint a Chair or Co-Chairs of both the IR Advisory Committee and the IR Committee.

II.  Procedures

A.  Criteria

Generally, only those Projects that meet one or more of the following criteria (the "Criteria") will be reviewed. The Criteria are the following:

a.  The direct costs of the Project exceed $1 million per year, of which at least 50% will be expended outside the United States (either directly or through one or more subcontracts).

b.  The Project involves ongoing University operations in a non-U.S. country, such as the establishment of an office, leasing of space or an on-the-ground presence for more than a nominal period. 

c.   The Project is located in, funded by or involves a collaboration with persons in, a country on the Treasury Department's Office of Foreign Assets Controls list of embargoed countries.  The list can be found at http://www.ustreas.gov/offices/enforcement/ofac/programs.

d.   The Project involves the use of high risk materials (e.g., radioactive materials or certain biologic materials).

•B.     Pre-Award

N.B. It is intended that the steps set forth below not delay the review and submission of any grant application and, if necessary, will be completed after an application has been submitted.

1.   Step One: Notification to Research Administration

a.  Initial Notification

In order to provide the maximum time for pre-application review of a sponsored project proposal (or a renewal thereof) (a "Proposal"), the Principal Investigator ("PI") or Departmental Administrator responsible for the proposal will notify the appropriate Project Officer in Research Administration of his/her intent to apply for sponsorship of a Project.  The Project Officer will ask the PI or Departmental Administrator the questions set forth in the Criteria Questionnaire.  The Criteria Questionnaire is attached as Annex A and will be posted on the Research Administration website.

b.   RASCAL Proposal Tracking System.

If a Proposal is entered into RASCAL, through Research Administration's Proposal Tracking module or through the Institutional Review Board's submission module, RASCAL will ask whether the proposal involves international research or service.  If it does, and the Project Officer has not already done so under Section 1(a) above, the appropriate Project Officer in Research Administration will call the PI or Departmental Administrator responsible for the Proposal and ask the questions set forth in the Criteria Questionnaire. 

c.   InfoEd Grants Management System.*

If a Proposal is entered into the InfoEd Proposal Development module, the PI or Departmental Administrator will be asked whether the Proposal involves international research.  If it does, the appropriate Project Officer will call the PI or Departmental Administrator responsible for the Proposal and ask the questions set forth in the Criteria Questionnaire. 

d.   If a Project Officer, upon review of any Proposal, ascertains that the project involves international research, he/she will call the PI or Departmental Administrator responsible for the Proposal and ask the questions set forth in the Criteria Questionnaire.

e.   If the Project is to be funded by a gift, the initial notification to Research Administration will be coordinated through the Office of University Development and Alumni Relations.

2.  Step Two: International Research Questionnaire

If the Project Officer determines that the Project meets one or more of the Criteria, he/she will call the PI or Departmental Administrator to obtain answers to the questions set forth in the International Research Questionnaire.  A sample Questionnaire is attached as Annex B and will be posted on the Research Administration website.

3.  Step Three: Review of International Research Questionnaire by IR Committee

The Associate Vice President for Research Administration and the Director of ORCT will determine on the basis of the International Research Questionnaire whether the International Research Questionnaire should be reviewed by the IR Committee. If not, the Project Officer will notify the PI or Departmental Administrator.  If so, the Project Officer will forward the International Research Questionnaire to the IR Committee and so notify the PI or Departmental Administrator. In reviewing the Questionnaire, the IR Committee will consider the questions set forth in Annex C.  Any risk management issues noted by the IR Committee will be discussed with the PI or Departmental Administrator.

After its review, the IR Committee will either notify the PI or Departmental Administrator that no further review is needed or work with the PI to resolve any questions. 

If any issue needs further discussion, it will be referred to the appropriate senior administrator for review.  All issues will be addressed and resolved with the PI as expeditiously as possible.

*Until the InfoEd software has been modified to include this feature, the PI or Departmental Administrator should notify the appropriate Project Officer that a proposal for sponsorship of a Project is being entered into the Proposal Development module.

C.  Post-Award Steps

1.  Step One: Financial and Legal Review

After an award is received, the Project will be reviewed for financial, legal and operational risks by the IR Committee or an ad hoc committee appointed by the Chair of the IR Committee and comprised of representatives of the Finance Division and the OGC and such other persons as deemed appropriate by the Chair or Co-Chairs of the IR Committee ("Post Award Committee").  Annex D identifies key issues that should be addressed as part of this review.

2.  Step Two: Finalization of Structure and Procedures                

a. If appropriate, the Finance Division will work with the PI and the PI's school to establish a set of financial controls and an ongoing monitoring plan for the Project.

b. The OGC will work with the PI and the PI's school to establish the appropriate structure for the Project and a plan for mitigation of legal risks, as needed.

c. The final structure and procedures will be approved by the Post Award Committee and, if so determined by the Post Award Committee, an appropriate senior administrator.

3.   Change in Circumstances

If there is any change in the terms of a Project that would result in it meeting one of the Criteria described in Section A above, or if the risk profile of the Project materially changes, the PI should promptly notify the IR Committee of such occurrence.

* These Procedures were originally issued on March 12, 2007.