Researcher's Manual - Regulatory Resourses on Campus
Sponsored Projects may include a commitment to “buy out” some of a faculty member’s teaching commitment with the approval of the department chair and divisional dean.
CUNY faculty may budget up to three months of time over the summer months on a sponsored program at the same rate of pay that they would receive over the academic year if they are not teaching during the summer months.
Projects involving sensitive equipment or hiring foreign nationals must be cleared through the Office of Research and Sponsored Programs before spending begins. In some cases, these projects may require a license to export materials or information.
I nstitutional Review Board (IRB)
Projects involving the use of human subjects must receive approval from the Lehman College Institutional Review Board before any work is begun. The use of human subjects may include such activities interviews and surveys. The Office of Responsible Research Practices is available to answer any questions about the use of human subjects in sponsored programs.
Institutional Animal Care and Use Committee (IACUC)
Projects involving the use of animals must receive approval from the Lehman College Institutional Animal Care and Use Committee before any work is begun. The Office of Responsible Research Practices is available to answer any questions about the use of animals in sponsored programs.
Institutional Biosafety Committee
Projects involving hazardous materials must receive approval from the Institutional Biosafety Committee before materials are ordered or used. The Office of Responsible Research Practices is available to answer any questions about the use of hazardous materials in sponsored programs.
Projects involving stem cells must receive approval from the Escrow Committee before any work is begun. The Office of Responsible Research Practices is available to answer any questions about the use of stem cells in sponsored programs.
Responsible Conduct of Research
Lehman College participates in and is subject to the CUNY policies on the Responsible Conduct of Research. According to the federal government and the 2007 Research Misconduct Policy of CUNY, research misconduct is defined as fabrication, falsification, or plagiarism.
Fabrication is making up data or results and recording or reporting them. Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record. Plagiarism is the appropriation of another person's ideas, processes, results, or words without giving appropriate credit in proposing, performing or reviewing research, or in reporting research results. Research misconduct does not include honest error or differences of opinion.
Responsible Conduct of Research, however, is much broader than simple research misconduct. Responsible Conduct of Research also includes many areas such as data acquisition, management, sharing, and ownership; conflict of interest whether financial, commitment, or institutional, human subject protection, animal welfare, publication practices and responsibilities, mentor/trainee responsibilities, peer review, and collaborative research.
In response to increasing federal regulation in the area of Responsible Conduct of Research in 2010, CUNY has put in place a plan for the training and oversight of Responsible Conduct of Research. This plan includes a requirement that all students that are supported by sponsored programs, whether graduate or undergraduate, must receive and participate in training in the Responsible Conduct of Research. The plan as instituted requires Project Directors and Principal Investigators to provide ongoing education in RCR topics to students and postdoctoral researchers participating in the project. The PD/PI must also maintain records of the training, including documentation that the students have successfully completed online training modules appropriate to the research field from CITI and shared the completion certificates with the Office of Research and Sponsored Programs within six weeks of the beginning of the project, or the time when the student or postdoctoral researcher is hired to work on the project.
- More information is available on the CUNY website
Conflict of Interest
The City University of New York has developed guidelines for colleges to use to identify potential conflicts of interest for principal investigators based on the nature of the work and funding source. Lehman College adheres to the CUNY policies and to the sponsor policies as applicable to sponsored programs. The primary conflict of interest concern is the potential for a significant financial interest in the outcome of the research project. Definition of significant financial interest as defined by CUNY policy is as follows:
Anything of monetary value, including, but not limited to, salary or other payments for services (e.g. consulting fees or honoraria); equity interests (e.g. stocks, stock options, or other ownership interests); and intellectual property rights (e.g. patents, copyrights, and royalties from such rights).
The term does not include:
- salary, royalties, or other remuneration from the University;
- income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
- income from service on advisory committees or review panels for public or nonprofit entities;
- An equity interest that, when aggregated for the covered individual and the covered individual’s spouse and dependent children, meets both of the following tests: (i) does not exceed $10,000 in value, as determined through the reference to public prices or other reasonable measures of fair market value; and (ii) does not represent more than a five percent (5%) ownership interest in any single entity; or
- Salary, royalties, or other payments that when aggregated for the Covered Individual and the Covered Individual’s spouse and dependent children over the next twelve months, are not expected to exceed $10,000.
- (See: http://www.cuny.edu/research/index.html and follow the link on Research Compliance for a detailed explanation of the current CUNY policy and procedures used by the University in matters of conflict of interest.)
The Policy as it Applies to Lehman College
Lehman College has a College Conflicts Officer (Dr. Robert Troy, Associate Provost, ext. 7825, firstname.lastname@example.org ) who reviews conflicts of interest submissions on all grant proposals. All proposals must be accompanied by the Disclosure Statement for Certain Academic Employees Upon Application for an External Grant or Contrat— City University of New York form. Each Principal Investigator on a proposal must fill out this form completely and is responsible for disclosing any potential conflict of interest. All sections should be filled out with no section left blank. Note that if a potential conflict of interest is identified, it may still be possible to conduct the research project with some modifications. Once a potential conflict of interest is identified, then the College Conflicts Officer reviews the disclosure statement and makes a determination. The PI and Conflicts Officer then discuss the conflict and it is hoped that a solution can be attained at that time. A review process has been defined by the University if there is disagreement between the PI and the Conflicts Officer.
In addition to financial conflicts of interest, Lehman College is also required to manage apparent conflicts of interest with regard to the individual or the institution. Some sponsors (such as the National Institutes of Health), define investigators very broadly. When this is the case, the conflict of interest disclosure should cover not only the project Principal Investigator, but also her or his immediate family.
All possible care will be taken to protect the information pertaining to conflict of interest disclosures both in the Office of Research and Sponsored Programs and in the Conflict of Interest Officer’s files.
Faculty members are encouraged to disclose early and often. In the vast majority of cases, conflicts may be managed within Lehman College and research will be able to continue. Penalties at the federal level usually only arise when conflicts are not disclosed.
In addition to their published policies, for the purposes of Conflict of Interest, NIH has clarified:
The term ‘Investigator’ means the Principal Investigator (PI) and any other person who is responsible for the design, conduct, or reporting of research funded by PHS, or proposed for such funding. The term “Investigator” includes the Investigator’s spouse and dependent children.
- An Investigator is not just the Principal Investigator or Senior/Key Personnel conducting the PHS-sponsored research.
- Recipient institutions are encouraged to broadly consider an individual’s role, rather than title, and their degree of independence when applying the definition.
All sponsored programs are subject to the Research Foundation of CUNY’s sexual harassment policy, which includes mandatory training for all project personnel (including faculty). Faculty may meet the training requirement by providing the Research Foundation of CUNY with a copy of their CUNY sexual harassment training certificate. All other project personnel must pass the sexual harassment training course which is available on the Research Foundation web site.
The CUNY definition of equipment is any item over $1000 in value. These items, regardless of how they were purchased, must be logged, tagged, and tracked annually through Lehman College’s equipment office. For sponsored program budgeting purposes, equipment follows the federal definition, and is defined as any item with a value of over $5,000 and a usable life span of over one year. Consult with the Office of Research and Sponsored Programs before budgeting equipment into a proposal as additional regulations may apply.
CUNY has a robust intellectual property policy that applies to all faculty. If you believe your research may result in patentable intellectual property or will involve copyrightable materials, please disclose this to the Office of Research and Sponsored Programs at the time of the proposal.
Technology transfer (disclosure agreements, data use agreements, patenting, and copyright issues) for sponsored programs is handled by the Research Foundation in concert with the appropriate CUNY offices.
Cost sharing should only be included on a sponsored project if it is required by the sponsor. Projects requiring cost sharing must include letters of commitment for all costs and resources not provided by the sponsor. Cost sharing arrangements must be approved by the department chair, divisional dean, and Office of Research and Sponsored Programs.