Obligations and Responsibilities

       This section contains a summary of the policies and procedures the University follows to promote the scholarly and scientific inquiries of its faculty and officers of research and to meet the regulatory and other requirements of the external sponsors that provide the financial resources that sustain much of that research. In addition, it describes certain administrative offices that can assist investigators conducting research at the University.

       More detailed information may be found in a suite of handbooks prepared by the Office of the Executive Vice President for Research: the Sponsored Projects Handbook, Clinical Research Handbook, Research Environmental Health and Safety Handbook, Research Radiation Safety Handbook and Animal Research Handbook (Research Handbooks) available on the Columbia Research website.

Research Policies

       The University does not impose limitations on the research that faculty and officers of research may pursue in their individual capacity, other than to expect that such work will not interfere with their other University responsibilities. It has, however, adopted policies to regulate the conduct of research, some of which are discussed below.

Fundamental Principles Governing Externally Funded Research

       The University regularly enters into agreements with external funding sources, such as government agencies, foundations, and corporations, to support research undertaken by its faculty and professional officers of research. To ensure that these projects do not compromise the University’s commitment to unrestricted scholarship, proposals for externally funded research are expected to conform to the principles contained in Chapter XLIII of the University Statutes, which specify conditions under which the University will not accept external support:

• An outside party may not be given the power to censor, exercise an effective veto over, or unreasonably delay the publication or other dissemination of the results of the project.

• An outside party may not determine who can participate in a research project on the basis of political beliefs or exclude anyone on criteria that violate the University’s nondiscriminatory policies, subject to the University’s obligations under state and federal laws.

• The University will not be a party to classified research, will not seek security clearances for any individual or facility, and will not control access to information in accordance with any security regulation.

Central Administrative Offices Involved in Sponsored Research

       The Office of the Executive Vice President for Research has overall responsibility for the University’s research enterprise. It assists faculty and officers of research in identifying external funding opportunities, administering the grants and contracts they receive, and ensuring that they comply with both University and external regulations governing the conduct of research. It oversees the following offices:

• Sponsored Projects Administration (SPA), which serves as the primary support office for sponsored research grants and contracts. SPA provides assistance throughout the project lifecycle, and is responsible for assuring compliance with regulatory and other requirements that govern sponsored projects;

• Clinical Trials Office, which facilitates and enhances the timely execution of quality clinical research;

• Office of Research Compliance and Training, which administers the University’s policies on financial conflicts of interest in research, research misconduct, and international research and export controls, and which serves as a resource on compliance questions, including those relating to data management, effort reporting, and science and security;

• Institutional Animal Care and Use Committee facilitates quality animal research that is conducted in an ethical and responsible manner to further science and to improve human and animal health;

• Human Research Protection Office and the Institutional Review Boards, which ensure that research involving human subjects, including behavioral research (e.g., surveys) and biomedical investigations (e.g., clinical trials), is conducted ethically and in a manner that promotes compliance with all applicable policies and regulatory requirements;

• Research Initiatives and Development, which fosters interdisciplinary collaboration, builds shared research facilities and resources, and supports efforts to secure funding for such collaborations; and

• Environmental Health and Safety, which guides and promotes a productive and safety conscious research environment compliant with University policy and applicable regulations.

• Postdoctoral Affairs, which serves the University’s postdoctoral research scientists, scholars and fellows by providing them with educational, training, and career development resources.

More detailed information about these offices and the areas they oversee may be found in the Research Policies and Handbooks  page on the Columbia Research website.

       Proposed research that involves human subjects, vertebrate animals, recombinant DNA, stem cells, or radioactive or hazardous materials requires special regulatory approvals through the appropriate research offices or committees at the University. These requirements and related procedures are summarized in the Research Handbooks. All research that involves human subjects must be reviewed by one of the University’s Institutional Review Boards before the study begins. Any person listed as research personnel on a protocol must have an appointment at the University.

Principal Investigators

       The full administrative, fiscal, and scientific responsibility for the management of a sponsored project resides with the principal investigator named in the award. A principal investigator is required to:

• assume overall responsibility for the management of the project;
• determine project feasibility;
• ensure that all of the information in the funding proposal is presented in a manner that is complete, accurate, and developed according to the practices commonly accepted within the relevant academic community;
• ensure that all required approvals are obtained and University forms and certifications are completed in a timely manner;
• know and abide by the terms and conditions of the award;
• conduct the work on the project according to the research protocol or statement of work that was submitted with the original proposal or as subsequently modified by the sponsor in agreement with the principal investigator and the University;
• ensure that all work meets the highest ethical standards and is conducted in accordance with the University’s conflict of interest policies;
• ensure that all work performed is conducted in compliance with applicable federal, state, and local laws and regulations and with University policies and requirements;
• ensure that all key personnel are qualified and have met the necessary training requirements;
• manage the project’s budget so that funds are spent correctly, taking into account any restrictions imposed by the sponsor, and avoid cost overruns;
• ensure that all financial records and reports are accurate and auditable;
• monitor the activities of subrecipients, if any;
• submit reports on the research in a timely manner, according to the sponsor’s requirements; and
• complete the formal closeout of the project.

       The University recognizes that in some cases principal investigators may delegate these duties to administrative personnel, but they retain overall responsibility for the financial and administrative management of their sponsored projects.

       Questions concerning the duties of a principal investigator should be directed to SPA or to Sponsored Projects Finance in the Office of the Controller. Information on financial management of sponsored awards is also available in the Research Handbooks and through Columbia Finance.

       The principal investigator normally must be an officer of instruction with a full-time appointment in the rank of professor, associate professor, assistant professor, or instructor (a limited term appointment for a maximum of two years when someone has been offered a position as an assistant professor, but has not completed the educational requirements before assuming the appointment), or a senior research scholar/scientist or research scholar/scientist. Faculty or officers of research holding other titles, including those in a visiting or adjunct grade, may act as co-principal investigators with faculty in one of the ranks mentioned above. However, they may not serve as the sole principal investigator without the approval of the appropriate chair and dean or executive vice president and the Provost. The Provost has delegated the authority to make such exceptions for faculty holding appointments at the Columbia University Irving Medical Center to the Executive Vice President for Health and Biomedical Sciences and for faculty holding appointments elsewhere to the Executive Vice President for Research, and for officers of research holding appointments at Lamont-Doherty Earth Observatory to the Director.

       Exceptions are granted only on a project-by-project basis, or in certain unusual cases, for a limited time period. Officers seeking an exception should submit a letter signed by the appropriate chair and dean or executive vice president addressed to the Provost or to one of the officers listed in the previous paragraph. The letter must include an acknowledgement that the applicable department, school, institute, or center has financial, managerial, and programmatic responsibility for the project and confirmation that appropriate non-sponsored support will be provided to cover proposal writing and other non-sponsored activities of the investigator for whom the exception is sought. The investigator’s curriculum vitae and an abstract of the project covered by the exception should accompany the letter.

       For non-sponsored research studies involving human subjects or vertebrate animals, a similar waiver request must be submitted to the Human Research Protection Office or to the Institutional Animal Care and Use Committee if the principal investigator does not meet the qualifications outlined above.

       A faculty member or officer of research who is a principal investigator may continue in that capacity after retirement until the expiration of the current term of funding of the sponsored project. The officer may serve as a principal investigator beyond that date only with the special permission of the appropriate designee of the Provost.

       Faculty or officers of research serving as principal investigators may not prepare or submit proposals for outside funding through another institution without first obtaining permission from the applicable chair, dean or executive vice president, and Executive Vice President for Research. Requests for exceptions should be directed to Sponsored Projects Administration. They are normally granted only in the case of collaborative projects where it is determined that Columbia should not administer the award.

Research Misconduct

       Integrity in the conduct of research and the dissemination of the results are essential to the scholarly purposes to which the University is dedicated. Unethical practices and fraud can destroy the mutual trust that exists among colleagues; undermine the relationship between faculty, officers of research, and students; severely, if not irreparably, injure the careers of associates and subordinates; damage the University; and diminish public confidence in the scholarly enterprise. In recognition of the harm academic misconduct can cause, the University Senate adopted an Institutional Policy on Misconduct in Research which applies to the entire University and covers misconduct in research involving falsification, fabrication, and plagiarism. It also defines the process by which the University promptly and fairly investigates allegations of research misconduct.

       The University’s Standing Committee on the Conduct of Research implements the policy. The Office of Research Compliance and Training administers the policy and is a resource for anyone with concerns or questions about possible research misconduct. It offers further information on the University’s policies and procedures for dealing with misconduct.

International Research

       To support international research and service, the University has established Risk Management Procedures for International Research and Service Projects and has an International Research Committee made up of faculty and senior administrators that reviews certain international research projects that might involve special risks for the University. Information on the federal laws and regulations relating to foreign asset controls, sanctions, export controls, and international boycotts is available from SPA or the Office of Research Compliance and Training.

Effort Reporting

Federal regulations require that the effort devoted to sponsored projects is appropriately documented, and that the salaries charged are reasonable in relation to the effort devoted to those projects. Accordingly, each faculty member who receives sponsored project funding must annually certify their own effort. In addition, principal investigators must certify the effort of graduate students, postdoctoral officers, and staff funded by their projects. All effort reporting is documented in the University’s electronic certification system called ECRT (Effort Certification and Reporting Technology) which can be accessed through Columbia Finance’s Documenting Personnel Costs (Effort Reporting) page.