Escalation Protocols for Research Related Matters

Escalation Protocols for Research Related Matters

March 28, 2019 | Alexander A. Bustamante
The letter outlines the escalation and investigation protocols for research-related matters involving foreign entities at the University of California (UC) campuses. President Janet Napolitano emphasized the increasing scrutiny from federal agencies like the National Institutes of Health (NIH) on international engagements and the need for a mechanism to track, escalate, and investigate these inquiries. Recent federal inquiries have focused on non-compliance with federal grants, contracts, and awards, as well as other issues such as intellectual property diversion, student recruitment, compliance with reporting requirements, and cybersecurity threats. To address these concerns, the Office of Ethics, Compliance and Audit Services (ECAS) and the Office of General Counsel (OGC) are developing a systemwide investigative protocol. The protocol aims to ensure timely and appropriate responses to triggering events, which include communications from federal agencies expressing concerns about foreign entity involvement or campus knowledge of violations. The protocol also specifies the roles of the Locally Designated Official (LDO) and other relevant offices in handling these matters, including reporting, investigation, and communication with federal agencies. The letter provides detailed procedures for triggering events, escalation, and investigation, emphasizing the importance of timely notification and proper training. It also outlines the responsibilities of various campus departments and federal agencies in handling inquiries and investigations.The letter outlines the escalation and investigation protocols for research-related matters involving foreign entities at the University of California (UC) campuses. President Janet Napolitano emphasized the increasing scrutiny from federal agencies like the National Institutes of Health (NIH) on international engagements and the need for a mechanism to track, escalate, and investigate these inquiries. Recent federal inquiries have focused on non-compliance with federal grants, contracts, and awards, as well as other issues such as intellectual property diversion, student recruitment, compliance with reporting requirements, and cybersecurity threats. To address these concerns, the Office of Ethics, Compliance and Audit Services (ECAS) and the Office of General Counsel (OGC) are developing a systemwide investigative protocol. The protocol aims to ensure timely and appropriate responses to triggering events, which include communications from federal agencies expressing concerns about foreign entity involvement or campus knowledge of violations. The protocol also specifies the roles of the Locally Designated Official (LDO) and other relevant offices in handling these matters, including reporting, investigation, and communication with federal agencies. The letter provides detailed procedures for triggering events, escalation, and investigation, emphasizing the importance of timely notification and proper training. It also outlines the responsibilities of various campus departments and federal agencies in handling inquiries and investigations.
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