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Research Research Policies The University does not impose limitations on the research that faculty and research officers may pursue in their individual capacity, other than to expect that such work will not interfere with their other University responsibilities. It has, however, adopted policies to regulate the conduct of research it sponsors and administers, the most important of which are discussed below. The University's policies on conflicts of interest are described later in this chapter under "Outside Interests and Employment."
Fundamental Principles Governing Externally Funded Research The University regularly enters into agreements with external funding sources, such as government agencies, foundations, and corporations, to sponsor and administer research awards on behalf of its faculty and officers of research. To ensure that these projects do not compromise the University's commitment to unrestricted scholarship, all proposals for externally funded research and instruction must conform to the fundamental principles concerning sponsored projects that are contained in Chapter XL of the University Statutes (see Appendix H). These principles specify certain conditions under which the University will not enter into agreements for the support of research:
Ethics in Research Integrity in the conduct of research and the dissemination of the results is essential to the scholarly purposes to which the University is dedicated. Unethical practices and fraud can destroy the mutual trust that exists among colleagues; undermine the relationship between faculty and students; severely, if not irreparably, injure the careers of associates and subordinates; damage the University; and diminish public confidence in the scholarly enterprise. In recognition of the harm academic misconduct can cause, the University Senate adopted a revised statement on professional ethics and faculty obligations in April 1986. That statement, which is reprinted as Appendix E, sets forth the University's policies on misconduct in research and establishes principles and guidelines for promptly and fairly investigating cases in which such misconduct is alleged to have occurred. The Health Sciences have developed their own guidelines for implementing the University's policies on academic misconduct. Those guidelines are reprinted as Appendix F. Questions about them should be referred to the Office of the Executive Vice President for Health and Biomedical Sciences.
Research on Human Subjects Research involving human subjects has the potential of yielding substantial benefits in the form of new medical treatments, answers to social problems, and the advancement of knowledge. However, it must always take into account the well-being and rights of the individuals who are used as test subjects. The University has a longstanding ethical commitment to minimizing the risks associated with such research and to making sure that individuals who participate in projects conducted under its auspices do so voluntarily and with an informed understanding of what their involvement will mean for themselves. Its policies on human subjects reflect as well its obligations under federal regulations and the written assurances it has given to the Office of Human Research Protections of the Department of Health and Human Services at 45 CFR 46. As outlined in this federal policy:
No research that involves human subjects (as defined above) may be initiated without prior review by one of the University’s Institutional Review Boards (IRBs), also known as the Human Subjects Review Committees. This is true irrespective of whether the research is being funded by a government agency or, indeed, from any source. Faculty and other researchers must consult with the appropriate IRB well in advance of when they want to begin their projects to determine the type of review required for their project. The University has separate Institutional Review Boards for the Morningside and Health Sciences campuses. Information on the policies governing human subjects research, and forms to use for approval of this research on the Morningside Campus, may be obtained from the Morningside IRB office at 854-1324 or on-line at http://www.columbia.edu/cu/opg/policies/policies.html. Officers in the Health Sciences should call 305-5883 or consult the Web site of the Health Sciences IRB at http://cpmcnet.columbia.edu/dept/irb/. Research projects in the Department of Psychiatry are reviewed by the joint Institutional Review Board of the New York State Psychiatric Institute and the Department. Officers in the Department of Psychiatry should call 543-5758. If the study involves recruitment from or procedures performed at the Columbia Presbyterian Medical Center, the CPMC IRB should be consulted as well (305-5883). Additionally, affiliated hospitals other than New York Presbyterian have their own review boards.
Intellectual Property Rights The University's policies on proprietary rights in the intellectual products of faculty activity are set forth in two policy statements adopted by the Trustees, with the endorsement of the University Senate. The policy applicable to inventions and discoveries that are or may be patentable, as well as to the technology associated with them, is described in the document, "Statement of Policy on Proprietary Rights in the Intellectual Products of Faculty Activity," which is reproduced in full as Appendix I. This policy was designed to achieve a balance between the rights and needs of the University and individual faculty members, and to define the responsibilities and privileges of each to the other with respect to patentable inventions or discoveries and the supporting technologies. The policy also sets forth the formula by which any revenues generated by inventions and discoveries will be shared among the University and the creator. In June 2000, the Trustees adopted a new copyright policy which is reprinted as Appendix M. The policy reaffirms the University's historical commitment to the basic academic principles that faculty are free to pursue their research without interference and to share the products of their own intellectual efforts with others. At the same time, it clarifies the rights of the University with respect to works produced by the members of the Columbia community, balances them against the rights and privileges of the works' creators, and, like the patent policy, establishes a framework by which any revenues generated by copyrighted materials will be shared by the University and their creator. The policy assigns responsibility for overseeing the new copyright policy and for adjudicating disputes arising from its application to a standing committee that is appointed by the Provost and includes faculty, who constitute a majority of its members, academic administrators, and a student officer. Research Administration Several central administrative offices of the University assist faculty and officers of research in identifying external funding opportunities, administer the grants and contracts they receive, and manage the University's technology transfer program. Most operate under the supervision of the Executive Vice Provost and include the Office of Projects and Grants, the Office of Research Development and Information, and the Office of Scientific and Technical Advice. Faculty may obtain additional assistance from the Office of Foundation and Corporate Relations in the Office of University Development and Alumni Relations. Separate offices that report to the Executive Vice President for Health and Biomedical Sciences have been established to promote research and administer external awards in the Health Sciences. Among these are the Office of Grants and Contracts and the Office of Clinical Trials. The Executive Vice Provost also directs the University's Strategic Initiative Program, which promotes research and scholarly projects of a cross-disciplinary nature and oversees the Columbia Innovation Enterprise (CIE) and the Columbia Media Enterprises (CME), which seek to realize the potential commercial value of the creativity of the University's faculty and other officers. The missions and operations of the Columbia Innovation Enterprise and the Columbia Media Enterprises are discussed in a later section of this chapter on technology transfers. The other offices and programs are described below.
Office of Projects and Grants The Office of Projects and Grants (OPG) is responsible for coordinating the submission of proposals for sponsored projects to government agencies, private foundations, and industry from divisions other than the Health Sciences, and for the administration of those that are funded. (In cases where faculty within and outside of the Health Sciences are both interested in applying for a particular award but the granting entity only permits a limited number of proposals from the same institution, the Executive Vice Provost will coordinate the University's submission.) It is the only office authorized to submit proposals and accept externally sponsored awards for investigators outside of the Health Sciences. Deans, directors, and department chairs are not authorized to act in this capacity. OPG assists investigators in locating possible funding for themselves and for their doctoral students. It maintains reference libraries with a wide range of materials on funding sources, publishes monthly newsletters containing program information and deadlines, and distributes the latest materials received from funding sources to the appropriate deans, directors, and chairs for further dissemination. Individuals who wish to receive the newsletters or information on programs in selected areas should ask the office to include them on its distribution list. OPG also maintains a computer database on proposals and awards that it makes available to departments and individual investigators upon request. OPG's informational resources are available electronically through the World Wide Web as well as in printed form. The URL for its home page is http://www.columbia.edu/cu/opg. Through the Web page, investigators may access the Web sites of government and nongovernment agencies with information about funding opportunities and policies governing sponsored research. The Web page is also linked to the Sponsored Program Information Network (SPIN), the Illinois Researcher Information Service (IRIS), and other databases of worldwide funding information that are searchable by keywords. It also maintains an Agency Program Information Bulletin Board that lists current (and expired) research opportunities that may be searched by agency, program, or deadline. OPG reviews and approves all applications to sponsoring agencies originating from a department or center outside of the Health Sciences before they are submitted to ensure that they conform to the policies of the University and the guidelines of the proposed sponsor. To assist prospective project directors in applying for external funding, OPG publishes an information guide, entitled Proposals for Sponsored Projects, which may be found electronically on its Web site. Printed copies are available from the Office. Once a proposal has been accepted, OPG negotiates the award with the sponsor, establishes accounts for the project, sets up controls to ensure that the conditions of the award are met and the funds properly spent, acts as a liaison to the sponsor, and helps to administer the project throughout its life. The Office also maintains a special computer system that contains information on proposals and awards, including their personnel and budgets. Information from this system is available for use by investigators and their departments. Responsibility for assisting investigators in each department, institute, and research center outside of the Health Sciences with the preparation of proposals and the administration of awards has been assigned to a specific member of the OPG staff. A directory of these project officers and their departmental assignments may be found on the Office's Web site.
Office of Research Development and Information The Office of Research Development and Information (ORDI) supports the strategic planning needs of the University with respect to research. Its strategic analysis staff monitors trends in both governmental and private sources of support for research, informs members of the University of changes in the external environment affecting research opportunities, issues funding alerts about potential sources of research and technical support, and maintains a reference library of on-line planning documents of governmental and other outside organizations pertaining to research. Its program development staff works with projects initiated with support from the Strategic Initiative Program to make them self-sustainable once that funding ends. ORDI's communications staff supports the Strategic Initiative Program by developing communications strategies for projects it supports. The Office's research news and databases are maintained on the ORDI Web site at http://www.columbia.edu/cu/ord.
Office of Scientific and Technical Advice Staffed by the Associate Vice Provost for Science and Engineering, the Office of Scientific and Technical Advice provides science advice to the senior leadership of the University and supports information and new media technology projects throughout the University. The Associate Vice Provost also deals with laboratory and nuclear safety issues; represents the University on the board of the Brookhaven National Laboratory; and coordinates the selection of University candidates for scientific awards and societies.
Office of Foundation and Corporate Relations The Office of Foundation and Corporate Relations, which reports to the Vice President for University Development and Alumni Relations, assists University faculty and other officers in obtaining support from private philanthropic foundations and corporations for research, instructional projects, outreach, and other academic activities. The Office maintains up-to-date information on foundations and corporations with an interest in funding academic activity, which it regularly disseminates to the University community. Using that information, it works with faculty and other officers to identify the most appropriate foundations and corporations to approach, helps them develop individualized strategies for soliciting support based upon the nature and objectives of the project, and advises on the preparation of proposals that are submitted through the appropriate research administration office. The Office is also available to assist investigators in preparing reports on awards that are funded and otherwise to help with their administration. The Office publishes a handbook that contains further information on its services.
Office of Grants and Contracts The Office of Grants and Contracts (OGC) is the counterpart of the Office of Projects and Grants in the Health Sciences. It assists investigators in identifying sources of research support by maintaining a library of current materials on external funding opportunities and agencies and extensive electronic resources that may be accessed through its home page on the World Wide Web at http://cpmcnet.columbia.edu/research/. To help in the preparation of grant proposals, OGC has published a Manual of Policies and Procedures, which is available in printed form or electronically on the Office's Web site. OGC is responsible for the submission of all proposals from the Health Sciences for sponsored research and for the acceptance of any awards resulting from those proposals, with the following exceptions: Clinical trials are handled by the Office of Clinical Trials, while many proposals to commercial entities are managed through Columbia Innovation Enterprise. With those exceptions, the Office serves as the University's Health Sciences' liaison to funding agencies. It also performs several additional responsibilities with respect to proposals that are accepted, including negotiating the terms of the awards, setting up financial accounts, managing those aspects of post-award administration that do not involve financial accounting, and ensuring that the terms of the award are fulfilled. Primary responsibility for assisting investigators in each department, institute, or center has been assigned to a specific member of the OGC staff. A list of those assignments may be found on the Office's Web site.
Office of Clinical Trials The Office of Clinical Trials, a joint venture between the Health Sciences and New York-Presbyterian Hospital, is responsible for promoting clinical research in the Columbia Presbyterian Medical Center (CPMC) and for serving as an intermediary between the Medical Center and sponsors of clinical trials in the pharmaceutical and biomedical device industries. The Office markets CPMC to potential sponsors in the private sector and works with companies interested in placing clinical trials in the Medical Center. On behalf of the University and the Hospital, it negotiates with potential sponsors and once an agreement is signed, monitors its implementation as well as providing the investigator with a range of management services. The Office also administers several programs financed from the Clinical Trials Fund that are designed to encourage and support clinical research in the CPMC. These include the New Investigator Pilot Awards, the House Staff Mini-Grants Program, clinical infrastructure projects, and a program that contributes to the funding of departmental projects on a matching basis. The work of the Office is overseen by the Clinical Trials Advisory Committee, whose members includes clinical investigators and senior administrators of the University and Hospital. The Committee advises the Executive Vice President for Health and Biomedical Sciences and the President of New York-Presbyterian Hospital on all matters relating to clinical research at CPMC, including the policies and procedures governing that research, issues arising out of specific trials, and the recipients of awards from the Clinical Trials Fund. Information on the Office and the Advisory Committee, and the programs they manage, is available on the World Wide Web at http://cpmcnet.columbia.edu/dept/ctrials.
Strategic Initiative Program The Strategic Initiative Program seeks to promote cross-disciplinary research at Columbia. Administered by the Office of the Executive Vice Provost, it coordinates and invests in projects that directly capitalize on University-wide strengths or lays the foundations for new efforts of potential benefit to the entire University community. Investments made through the Program are used to facilitate the organization of collaborative research teams and to provide start-up support for their joint endeavors, with the expectation that the teams will raise sufficient funding to allow their projects to stand financially on their own. Information on the Strategic Initiative Program may be obtained on the World Wide Web at http://www.columbia.edu/cu/research/strategic.html. Faculty and officers of research interested in exploring potential opportunities through the Program should contact the Office of the Executive Vice Provost.
Administration of Externally Funded Research The full administrative, fiscal, and scientific responsibility for the management of a sponsored project resides with the principal investigators named in the awards. A principal investigator is required to:
The principal investigator normally must be an officer of instruction with a full-time appointment in the rank of professor, associate professor, assistant professor, or instructor, with certain exceptions described below. Persons with appointments carrying other instructional titles, including those in a visiting or adjunct grade, may act as co-principal investigators or co-directors with officers in one of the four instructional grades cited above. However, they may not serve as the sole principal investigator or project director without the special approval of the Provost. In the Faculties of Dental and Oral Surgery, Medicine, Nursing, and Public Health, the Provost has delegated the responsibility for authorizing exceptions to the Executive Vice President for Health and Biomedical Sciences. An officer of instruction or research who is a principal investigator or a project director may continue in that capacity after retirement until the expiration of the current term of funding of the contract or grant. The officer may serve beyond that date on the same project or on a new one only with the special permission of the Provost. The Provost has authorized certain general exceptions to these policies for officers of research in the Health Sciences and at the Lamont-Doherty Earth Observatory. Senior research scientists and research scientists in these divisions may serve as principal investigators or project directors. Associate research scientists at Lamont-Doherty can also serve in those capacities if their proposals are endorsed by two members of the Observatory's senior scientific staff. Similarly, the Executive Vice President for Health and Biomedical Sciences may authorize associate research scientists in the Faculties of Dental and Oral Surgery, Medicine, Nursing, and Public Health to act as principal investigators if their department chair or director assumes responsibility for the fiscal and administrative aspects of their projects. Other officers of research may only serve as principal investigators with the special permission of the Provost or in the Faculties of Dental and Oral Surgery, Medicine, Nursing, and Public Health, the Executive Vice President for Health and Biomedical Sciences. To obtain the permission of the Provost or Executive Vice President for Health and Biomedical Sciences for an exception to the University's general policies on principal investigators, an officer should submit a request through the appropriate sponsored project administration office. The request must be countersigned by the officer's department chair, director, and vice president or dean, as appropriate, and must include an abstract of the proposed project as well as the individual's curriculum vitae.
Filing Proposals for Externally Funded Sponsored Projects The University administers sponsored awards for which full-time faculty and full-time officers of research serve as the principal investigators. Those officers may not, therefore, submit proposals for outside funding through another institution without first obtaining permission from the Provost. Requests for exceptions should be directed to the office, described below, that is responsible for submitting the proposal to the funding source. They are normally granted only in the case of collaborative projects where, by prior agreement among the institutions involved, it is determined that Columbia should not administer the award. Both the Office of Projects and Grants and the Office of Grants and Contracts have published manuals and guidelines to assist faculty and officers of research in preparing proposals for sponsored awards. These are available on the respective Web sites of the two offices as well as in printed form. Investigators in the Health Sciences who are interested in initiating clinical trials or submitting proposals to industrial sponsors should contact the Office of Clinical Trials and the Columbia Innovation Enterprise respectively. Outside of the Health Sciences all proposals must be submitted through the Office of Projects and Grants, regardless of the funding source. A proposal for sponsored research must be approved by the appropriate department chair or director and by the dean or vice president to ensure that the project is consistent with the purposes and priorities of the department, school, institute, or center. This approval is conveyed by means of a CPMC Sponsored Project Proposal Cover Sheet for projects in the Health Sciences and by a Proposal Routing Sheet for those originating in the rest of the University. When a proposal involves personnel from or activity in more than one unit, it requires the approval of the heads of all the units that will be involved. If another institution will participate in the proposed project, the proposal must also be signed by its authorized representative. Special additional authorizations may also be necessary, depending upon the requirements of the project. In particular, they are required when the proposed research involves human subjects, vertebrate animals, recombinant DNA, or radioactive or hazardous materials. Investigators are expected to be informed about and comply with all applicable laws, regulations, and University procedures governing their use. For information on those laws, regulations, and procedures, and, more generally, on when special authorizations are required and how to obtain them, investigators should contact the appropriate sponsored project administration office.
Financial Administration of Externally Funded Research Acceptance of externally funded awards carries with it the obligation to comply with the sponsor's conditions governing expenditures and reporting. Those responsibilities rest primarily with the principal investigators, who are expected to ensure that expenditures from their sponsored projects are appropriate, allowable under the conditions of the awards, and in compliance with the policies of the sponsor as well as the regulations of the University. Columbia does not maintain a separate set of financial policies applicable solely to grants and contracts. All of its policies apply to all transactions, irrespective of funding source, unless otherwise noted in the policies themselves. There are, however, several policy statements of particular relevance to the management of sponsored research. These are listed in Chapter 9 of this Handbook and are available from the Restricted Funds Division of the Office of the Controller and Treasurer. Information on the financial management of external awards is also available on the Web site of the Restricted Funds Division at http://www.columbia.edu/cu/controller/pnp/policiesprocedures_rf.html. The Restricted Funds Division is responsible for the overall fiscal administration of grants and contracts awarded to the University. Among the tasks the Division performs are grant and contract cash management, financial reporting to sponsors, the negotiation of the University's indirect cost recovery and fringe benefits rates, and responses to financial audits of funded research. Restricted Funds does not routinely monitor or otherwise screen individual charges to grants and contracts.
Overdrafts Principal investigators are required to ensure that expenditures and future commitments do not exceed the amounts authorized by the granting agencies. Under certain conditions, expenditures incurred during one budget period of a grant may be carried over, in full or in part, to the new budget period, but only when University and agency policies permit. Investigators should contact the Restricted Funds Division or the appropriate sponsored project administration office to determine if these policies are applicable in the case of a particular grant. Responsibility for funding any remaining overdrafts rests with the principal investigator, the department, institute, or center, and ultimately the school to which the grant or contract is assigned.
Indirect Costs The federal government and most other sponsors provide funding for both the direct costs of a given research project and the related indirect costs. The former consists of those costs directly attributable to a grant or contract, such as the salaries of participants, supplies, and equipment. Indirect costs, in contrast, cannot be easily associated with any single project. They are, instead, expenses that the University incurs on its overall operations in the process of providing support for sponsored research. Examples include expenditures on the operation and maintenance of the physical plant, central and academic administrative offices, and the libraries. The University recovers these costs through the application of an indirect cost rate, which is calculated by the Restricted Funds Division and negotiated with government representatives in accordance with federal regulations, to certain direct expenditures charged to each grant or contract.
Small Business Program The University is committed to promoting and developing opportunities for small firms, particularly those owned and controlled by minorities and women, to do business with its departments and offices to help bring them into the country's economic mainstream. This policy is also designed to ensure that the University's practices and procedures are in conformity with the laws and regulations regarding small businesses. It is implemented through a program, which is coordinated and reviewed by a Small and Small Disadvantaged and Women-Owned Business Committee, chaired by the Associate Provost for Equal Opportunity and Affirmative Action. The Purchasing Office prequalifies firms to participate in the small business program. It is the policy of the University to award orders to those firms when they submit bids that are equal to or below those of other vendors. Principal investigators may obtain a list of the prequalified firms from the Purchasing Office. They must use their best efforts to ensure that they spend the maximum possible funds with those businesses. In addition, when the budget of a contract exceeds $500,000, the principal investigator must obtain the approval of the funding agency for a "Small and Small Disadvantaged Business Subcontracting Plan," which details how the funds will be expended. In certain circumstances these contracts require the use of Small Business Administration (SBA) certified vendors. Additional information on the University's policies for finding SBA certified vendors and the laws and regulations concerning small business may be obtained from the Office of Equal Opportunity and Affirmative Action, the appropriate sponsored project administration office, or from the Purchasing Office's Web page at http://cpmcnet.columbia.edu/dept/purch/.
Laboratory Safety The Offices of Environmental Health provide safety training to all persons who work in laboratories, in accordance with the regulations of the federal Office of Safety and Health Administration. Laboratory safety emergencies, such as a spill or leak of radioactive or hazardous materials, should be reported immediately to the appropriate Office of Environmental Health. After hours, they should be reported to Security, which will, in turn, contact the appropriate members of the Office of Environmental Health. Individuals should not try to deal with an emergency on their own, as that could result in severe injury or long-term health problems for themselves and for others.
Technology Development and Transfers Columbia maintains an active technology transfer program that is designed to realize the potential commercial value of the creativity of its faculty and staff. The program was made possible by the 1981 Bayh-Dole Act that allows universities to retain title to any innovations financed with federal funds, provided that they are diligent in transferring those innovations to the public domain. It is governed by the policies and guidelines in the University's "Statement of Policy on Proprietary Rights in the Intellectual Products of Faculty Activity," which is reprinted in Appendix I. The office primarily responsible for administering the program and promoting the University's objectives in the area of technology development and transfers is the Columbia Innovation Enterprise. A separate office, Columbia Media Enterprises, performs a similar function with respect to the development and commercial licensing of educational materials and methods that utilize the new information technologies. Columbia Innovation Enterprise (CIE) Columbia Innovation Enterprise (CIE) is charged with identifying inventions and discoveries developed in University facilities that have potential commercial value, working with faculty and other officers to obtain patents on them, licensing them to industry, and distributing the resulting income between the University and the individuals who are responsible for them in an equitable manner. The office also seeks to increase private sector funding for research and technology development by negotiating collaborative research agreements with industrial companies. It works with faculty to develop new technologies and products; assists them in establishing startup companies and finding the capital needed to sustain those companies; and serves as the University's primary liaison to private sector companies that are interested in exploring opportunities for working with Columbia faculty. Information on CIE's organization, staff, and activities may be obtained from its Web page at http://www.finance.columbia.edu/controller/cie/index.html. Columbia Media Enterprises (CME) Columbia Media Enterprises (CME) is the counterpart to Columbia Innovation Enterprise in the field of new media. Like CIE, it is charged with identifying, patenting, and licensing innovations developed in University facilities that have potential commercial value and with equitably distributing any resulting income between the University and the individuals who created them. CME is also responsible for developing strategies that will advantageously position the University in the new media domain, for creating commercial alliances with external entities, and for starting new commercial enterprises that will further those strategies. Assignment of Rights As part of its procedures for implementing its intellectual property policy and to comply with federal laws, the University requires certain categories of faculty and officers of research, including full-time postdoctoral officers and student officers of research, to sign an agreement that they will assign to the University their rights to any patentable invention or discovery conceived of or reduced to practice in the course of conducting research. (Graduate students who do not hold appointments as student officers are nonetheless expected to sign assignment agreements if they are supported by certain types of external funding.) No one may be appointed in a category covered by this requirement without completing an assignment agreement. Information on the purpose of the agreement and who must complete it may be obtained from Columbia Innovation Enterprise (CIE). Questions relating to the processing of appointments with the assignment agreement should be addressed to the Assistant Provost for Academic Appointments in the Office of the Provost for Morningside appointments or to the Office of the Executive Vice President for Health and Biomedical Sciences for Health Sciences appointments. A copy of the form may be found on CIE's Web page. Protecting Intellectual Property Officers are responsible for reporting any discoveries or inventions that may have commercial value to CIE as early as possible. In addition, they should be aware that dissemination of information about an innovation outside of the University could jeopardize its patentability. There is no inherent conflict between the freedom of officers to communicate the results of their research as they consider appropriate and the protection of the University's patent rights. CIE can apply for and obtain a patent without interfering with the scholarly dissemination of information about an innovation, provided that the officer communicates with it in a timely manner. To aid officers in understanding their role in the process of obtaining patents, CIE has prepared a guide, "Taking Faculty Inventions and Other Innovations to the Marketplace," which is available on its Web page. A printed copy can be obtained by calling its office. The guide also describes the formulas the University uses in sharing the revenues from intellectual property with the faculty responsible for its creation. |
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Last Revised: November 2001
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