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In the spotlight

FDP Expanded Clearinghouse Pilot

Our institution has joined the Federal Demonstration Project (FDP) Expanded Clearinghouse Pilot.

The Expanded Clearinghouse pilot seeks to test an Entity Profile, including using a national repository of posted information as a less burdensome alternative to achieve the stewardship obligations expected in the subaward issuance and oversight process. The Entity Profile was developed based on review of over 100 subrecipient commitment or certification forms from FDP and other institutions. Common data elements or questions from these forms are contained in the Entity Profile and ours is now live on the Clearinghouse webpage.

Effective tomorrow, only use the subrecipient commitment forms for non-Pilot institutions, but for Pilot institutions, you should NOT be using any form or questionnaire that asks for Entity based information. As part of the Pilot, we have agreed to forego the use of these forms for the other Pilot institutions, and use the Entity Profiles. You are welcome to continue to request and collect the minimal information that is required per subaward, such as IRB and IACUC approval information. If another one of the Pilot institutions is continuing to utilize a Subrecipient Commitment or other certification form that includes entity based questions there is language included in the attached slides that can be used when encountering this situation. It will likely take a bit of time and patience for all the Pilot institutions to get up and running in the Pilot, so be kind, but do share this information with them and gently push back.

Attached is a short slide deck that will give you an overview of the Pilot and here is a link to the list of institutions that are participating in the Pilot http://sites.nationalacademies.org/PGA/fdp/PGA_171219 to access their entity profile, just click on the entity name. The FDP has a webpage dedicated to the Pilot that contains helpful FAQs and other information that you may find helpful so here is the link to the page http://sites.nationalacademies.org/PGA/fdp/PGA_055835.

Please let me know if you have any questions about our profile or the Pilot in general and I hope that our participation helps reduce the burden you all encounter when working on proposals and awards that include subcontracts.

Robin

Robin L. Cyr
Associate Vice Chancellor for Research Compliance
University of North Carolina at Chapel Hill

Attachment: FDP Expanded Clearinghouse Pilot, Phase II

2016 UNC Research Symposium Presentation Materials

Presentation materials from select sessions are now available online and can be found here.

Thank you to all participants for making this year's symposium the most successful yet.

Pilot Program for Enhancement of Employee Whistleblower Protections

In order to encourage employees to report fraud, waste, and abuse in federally funded programs, the National Defense Authorization Act of FY 2013 (41 U.S.C. § 4712), established the “Pilot Program for Enhancement of Employee Whistleblower Protections” (the “Program”).  The purpose of the Program is to provide protections for employees against reprisal for certain whistleblowing activities in relation to federal grants and contracts. The Program provides that employers may not discharge, demote, or otherwise discriminate against an employee as reprisal for whistleblowing.  These protections cannot be waived by agreement, policy, form, or condition of employment. Whistleblowing is defined in the Program as disclosing information that an individual reasonably believes is evident of any of the following:

  • Gross mismanagement of a federal contract or grant;
  • Gross waste of federal funds;
  • Abuse of authority relating to a federal contract or grant;
  • A substantial and specific danger to public health or safety; or
  • A violation of law, rule, or regulation related to a federal contract or grant (including the competition for, or negotiation of, a contract or grant).
The Program provides protection when the disclosure is made to one of the following persons or entities:
  • A member of Congress or representative of a committee of Congress;
  • An inspector general;
  • The government accountability office;
  • A federal employee responsible for contract or grant oversight or management at the relevant agency;
  • An authorized official of the Department of Justice or other law enforcement agency;
  • A court or grand jury; or
  • A management official or other employee of the contractor, subcontractor, or grantee who has the responsibility to investigate, discover, or address misconduct.
Procedures for making a report of suspected fraud, waste or abuse as described above can be found on the Office of the Inspector General’s Whistleblower Hotline website (http://www.oig.doc.gov/pages/hotline.aspx). Any employee with concerns of possible noncompliance may also report them to the University Compliance Line: https://secure.ethicspoint.com/domain/en/report_company.asp or 1-866-294-8688. Furthermore, if you believe that you have been discharged, demoted, or otherwise discriminated against as a reprisal for whistleblowing related to a federal contract or grant, you may submit a complaint to the Inspector General of the agency associated with the federal contract or grant. Complaints under the Program must be filed within three years after the date on which the alleged reprisal took place. For more information regarding the Program and an employee’s rights and remedies, please read the statute here:  http://uscode.house.gov/view.xhtml?req=(title:41%20section:4712%20edition:prelim) A report of suspected fraud, waste or abuse may also be protected under State law.  For more information, please see the University’s “Policy for Reporting Improper Government Activities,” available at:  http://policies.unc.edu/policy-category/university/