Institutional Authorization

All investigators, meaning “the project director or principal Investigator and any other person, regardless of title or position, who is responsible for the design, conduct, or reporting of externally funded projects, or proposed such funding”, should have a current Disclosure of Significant Financial Interests (SFI) form on file by the application deadline. The annual disclosure of significant financial interests is a strategy to maximize the objectivity of externally supported activities pursued by investigators who may have financial relationships with entities outside the University. Disclosure to the University must be made annually or more frequently when circumstances change.  The University requests disclosures in the spring from faculty and staff that applied for or were awarded funds during the past three years.  See Syracuse University’s updated Policy on Financial Conflict of Interest for more information.

As required by federal regulation, all individuals supported on sponsored projects, including graduate students, must acknowledge the University’s intellectual property policy, which states that title to technology  resulting from research, work, or study supported by externally sponsored or University allocated resources belongs to Syracuse University. See the Faculty Manual, Section 3.23 for more information on the Ownership and Management of Intellectual Property.

Most sponsors no longer require Institutional Review Board (IRB) or Institutional Animal Care and Use Committee (IACUC) approval at the time of application submission; however many sponsors require the same information contained in the Syracuse University IRB/IACUC protocol applications to be included in the grant application, including in some cases informed consent documents. For more information see the Compliance menu.

Whether supported by an external sponsor or the University, in no case can human or animal subjects’ research begin without written approval by the appropriate oversight board.

Research that may affect either personnel safety or environmental well being is subject to local, state or federal statutes or regulations. Syracuse University requires personnel engaged in such research to obtain training relevant to the potential hazard, or secure University approvals or licenses, as appropriate to the activity.  The need for such oversight is indicated on the Proposal Approval Form (PAF). Environmental Health and Safety Services oversees these programs (for example, chemical hygiene, radiation safety, and recombinant DNA). At this time, Syracuse University does not support research using select agents. Faculty members interested in using these materials in their research should contact the Director of Environmental Health and Safety Services or the Director of Research Integrity and Protections.

If a grant or contract is awarded on the basis of false or misrepresented information, or if the University does not comply with sponsor’s requirements, the sponsor may take any necessary and appropriate action, which may include pursuit of administrative, civil, or criminal remedies.

Syracuse University, the Office of Sponsored Programs, the PI or others may be subject to administrative or other remedies if we deliberately withhold information, submit fraudulent information, or do not comply with applicable requirements. Even if a grant is not awarded, the University may be subject to penalties if the information contained in or submitted as part of an application, including its certifications and assurances, is found to be false, fictitious, or fraudulent.

Agencies of the federal government may pursue civil or criminal action under a variety of statutes and regulations, including:

• The Program Fraud and Civil Remedies Act of 1986 (31 U.S.C. 3801 et seq.) provides for the administrative imposition of civil penalties and assessments against persons who knowingly make false, fictitious, or misleading claims to the federal government for money, including grants, loans, or benefits. Penalties and assessments are adjusted annually for inflation; regulations at 45 CFR Part 79 specify the process for imposing them, including hearing and appeal rights.
• The Criminal False Claims Act (18 U.S.C. 287 and 1001) provides for criminal prosecution of a person who knowingly makes or presents any false, fictitious, or fraudulent statement, representation, or claim against the United States, with penalties including imprisonment and fines.
• The Civil False Claims Act (31 U.S.C. 3729(a)) provides for penalties and damages, through civil litigation, against any person who knowingly presents a false or fraudulent claim for payment, uses a false record or statement to get a false claim paid, or conspires to defraud the federal government. A “false claim” is any request or demand for money or property made to the United States, or to a contractor, grantee, or other recipient, if the federal government provides or will reimburse any portion of the funds claimed. Civil penalties are adjusted annually for inflation, plus damages of up to three times the amount of the false claim.

Federal agencies may also administratively recover misspent grant funds under the authorities in the Code of Federal Regulations. Current civil penalty amounts are published annually; see the applicable CFR inflation-adjustment tables for the figures in effect.

Federal agencies may also administratively recover misspent grant funds pursuant to the authorities contained in the Code of Federal Regulations.

The federal government and other sponsors expect the University to conduct business with responsible persons and organizations to protect the interests of the sponsor and to ensure the integrity of the programs supported. The Office of Management and Budget presents guidance on this matter to federal agencies and recipients of federal funds at 2 CFR Part 180; each agency’s specific policies and procedures pertaining to debarment and suspension are then issued in a regulation within its specific chapter of the Code of Federal Regulations (CFR).

When the Office of Sponsored Programs (OSP) submits proposals to sponsors, it certifies on behalf of the University that the proposal does not include persons or organizations debarred, suspended, proposed for debarment, declared ineligible or voluntarily excluded from receiving financial assistance by any Federal department or agency.  OSP certification is supported by the PI/PD’s attestation on the Proposal Approval Form (PAF).

The principal investigator/project director (PI/PD) is responsible for adherence to suspension and debarment regulations prior to proposal submission and during the life of the award.  Departmental administrative staff and various University offices assist the PI/PD with the task of verifying eligibility. For example, OSP subscribes to a proprietary service to screen eligibility of SU employees, subcontractors or consultants named in an application or award, regardless of sponsor type. OSP will also screen any new award sponsors to confirm their “good standing” with federal agencies.   Having been identified in this resource, the parties are scanned by the service daily; OSP is notified of any individual or entity whose status has changed, triggering further investigation and, if appropriate, action by the PI/PD.

During the life of the award, the PI/PD or his/her designee is responsible for ensuring the eligibility of individuals not named in the proposal who participate in a sponsored project [1].  Such individuals may be SU employees including graduate students, postdoctoral researchers, or technical personnel or non-SU personnel such as consultants. The PI/PD is also required to ensure the eligibility of vendors of goods or services at or above the federal procurement threshold before goods are acquired or services performed.

PI/PDs or their designee may use the System for Award Management (SAM) to verify that their staff, collaborators and vendors are not debarred, suspended or otherwise excluded from receiving federal funds. Copies of such checks should be available upon request. To support the PI/PD, OSP will also verify previously unnamed consultants or subrecipients upon request by the PI, designee or other University office.  Documentation would be available upon request.

For acquisitions that use standard University procurement procedures, responsibility for confirming vendor eligibility at or above the federal procurement threshold is assigned to the Purchasing Office. For procurements at or above that threshold that do not use standard procedures (for example, a confirming invoice), the Office of Sponsored Accounting verifies debarment and suspension screening with the PI/PD.

[1] Participants in human subjects’ research are excluded from this requirement.