Financial Compliance Policies

Policy Title	Summary	Audience
Conflict of Commitment	Any faculty member who performs research under an agreement stipulating that a specified percentage of his or her total effort will be devoted to that project must be able to demonstrate he or she is in compliance with that requirement. Last Updated: July 2019 (Conflict of Interest / COI)	Faculty, Staff
Cost-Sharing	Cost–sharing on proposals for external funds is to be avoided unless required by the sponsor and approved at the time of proposal submission by the Office of Research Support (Campus) or the Office of Research Administration (Schools of Medicine and Nursing). Last Updated: July 2019	Faculty, Staff
Effort Commitment, Reporting, & Certification	All persons employed by the University need to ensure that their annual effort certification accurately reflects all of their activities for the year. Last Updated: July 2019	Faculty, Staff
Equipment Transfers	Equipment is owned by the University and/or the government and, as such, may not be transferred from the University without University and/or the granting agency approval. Last Updated: July 2019	Faculty, Staff
Facilities & Administrative (F&A) Costs	Generally, Duke University requires the inclusion of full Facilities and Administrative costs on all proposals for external funding, except gifts, unless prior approval is obtained from the appropriate Management Center. Last Updated: July 2019 Policy Owner: Provost	Faculty, Staff
Faculty/Staff Effort Management for Clinical Research Studies	University faculty and staff working on clinical research studies must include appropriate effort during the budget/proposal development process and allocate effort appropriately throughout the life of the sponsored agreement to support accurate effort reporting in compliance with applicable federal regulations.	Faculty, Staff
Fiscal Agent	If Duke University serves as a fiscal and/or legal agent for any external organization where the relationship includes either applying for Federally-sponsored funding or charging costs to a Federally-supported project, the Vice President for Research must provide approval, with delegation to the Associate Vice President for Finance and Compliance on the implementation of procedures and internal controls specific to each instance of assuming agency. Last Updated: January 2021	Faculty, Staff
Research Costing Compliance	Each employee or representative of Duke University who is involved in sponsored projects administration has an obligation to ensure compliance with sponsor and University requirements for managing sponsored funds.	Faculty, Staff

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