A follow-up report of two routine University audits performed in March 2006 found that two of the six audit recommendations have been completed – the others are in progress.
The Office of Research Services and Administration Restricted Funds and the Office of Technology Transfer were the focus of the University’s quarterly audit update at last week’s Oregon State Board of Education meeting. Both routine audits were conducted in March 2006, and the follow-up reviews were presented at the board meeting.
The audits’ objective was to determine the adequacy of internal control structures in key office areas.
Resultant University actions include an office-wide restructure of duties in ORSA – including a new director – and an expanded conflict of interest policy with a new mandatory disclosure of conflicts, to be fully implemented by 2008.
ORSA’s purpose is to assist “faculty who seek, obtain and manage grants and contracts in support of their research, instructional programs and public service projects.” The report said controls over the office’s key reviewed areas “need improvement.” Controls exist, but some are not functioning and additional controls are needed.
The office received four commendations but the report also recommended ORSA make four changes.
One concern said the University’s interest in obtaining awards creates a potential conflict of interest because faculty face pressures to perform activities to obtain awards and as a result, do not devote enough attention to subsequent compliance issues.
In response, ORSA agreed to charge Vice President for Research and Graduate Studies Rich Linton with reorganizing the office’s directorial structure. ORSA will document the roles and responsibilities of two new associate director positions.
The audit also revealed a need for personnel performance evaluations and annual position descriptions. It suggested documenting policies and procedures to define employee roles and responsibilities. Currently, employees may not be complying with the office’s policies simply because they are not familiar with them.
“The lack of policies and procedures may result in inefficient operations and have a negative impact on employee morale,” according to the report. “Further, without clear policies and procedures in place, staff may not know how to perform their job duties and activities in compliance with applicable program requirements.”
ORSA said it would attempt a job description and evaluation update, and create the appropriate written policies and procedures.
The second routine audit was of the Office of Technology Transfer. The office received a “satisfactory” rating, which is the highest rating OUS awards.
“Controls are in place and functioning effectively, except for those noted,” according to the report.
OTT helps University inventions “successfully make the transition from academia to the commercial marketplace.”
The office also received four commendations, but only two recommendations, both of which are outside the discretion of the office itself and in the hands of University administrators.
First, the review noted the faculty disclosure requirements. Currently, the University requires faculty disclosure only when an external funding proposal is submitted for approval. Further disclosures are voluntary. The report recommended Linton “initiate a requirement for all faculty members to report annually any financial interests or activities that could be construed as a conflict of interest or represent that no interest exists.”
To prevent potential conflicts of interest, the University charged the Office for Responsible Conduct of Research to work toward a more comprehensive conflict of interest policy. Mandatory disclosure will be required by June 30, 2008.
The second recommendation is to require faculty to sign a statement of the University’s ownership of intellectual property developed while they work at the University.
The University will comply by adding a clarifying paragraph to annual notices of appointments.
Don Gerhart, OTT Director, said he was very happy with the audit results.
“The program has been growing and expanding a lot in the last six or seven years,” said Gerhart. “It was a validation that the efforts we’ve made are starting to bear fruit.”
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AUDIT FOLLOW-UPS
The Oregon University System’s follow-up report of the March 2006 routine audits it performed in two University offices found that one-third of its recommended modifications have been completed. The remaining recommendations are in progress.
The Office of Research Services and Administration Restricted Funds and the Office of Technology Transfer were the subjects of two routine audit follow-ups.
ORSA initially received a “Need Improvement” rating, while OTT received a “Satisfactory” rating – the highest possible.