Chapter 1: The Institution

1.1 Duke as an applicant organization

The applicant or proposing organization is the entity which has established eligibility to receive and administer grants, contracts and other binding agreements from external sponsors and is accountable to the external sponsor for both the performance of the research project or activity and the appropriate expenditure of funds.

As the applicant organization, Duke University assumes responsibility for the administrative, programmatic and financial management of the research project or other activities. To meet this responsibility, University officials (department, school, center, institute, or administrative staff) perform the following functions:

• Establishing that Duke University personnel or Institutional expertise are sufficiently engaged in the project or activity and there is sufficient use of University resources in the conduct, oversight or coordination of the programmatic aspects of the proposed activities to justify the University serving as the applicant organization.
• Ensuring Authorized Organizational Representatives (AORs) are properly identified to the University research community and properly registered in submission systems.
• Confirming the University has the resources to facilitate completion of the research project or activity.
• Ensuring the budget is adequate to complete the research project or activity and funds are expended appropriately.
• Reviewing all applications seeking external funding (i.e., grants, contracts, cooperative agreements) to ensure they are true, complete and accurate submissions.
• Verifying compliance with University and sponsor policies and guidelines, which includes federal regulations when applicable.
• Ensuring individuals serving as Principal Investigators on research activities meet University and sponsor eligibility requirements.
• Developing or providing (directly or via third-party) training programs to support best practices in the execution, administration and monitoring of research activity.
• Implementing a monitoring program, encompassing the financial and programmatic aspects of grants administration, that assists University officials in identifying, monitoring and addressing potential compliance risks.
• Maintaining its standing as a responsible recipient of sponsored research funds.

If the University determines it is unable to perform its duties or serve as the applicant organization, it will withhold the submission of an application to an external sponsor or refuse an award at the time of notification.

In other instances, upon review of the terms and conditions of a research project, the University may choose not to submit the application, refuse acceptance of the award, or relinquish the award when in progress. These include, but are not limited to, scenarios in which the University determines: 1) Duke University resources, personnel or expertise are not sufficiently engaged in the conduct, oversight, or coordination of the programmatic aspects of the proposed activities; 2) the project is using resources of another organization without an appropriate agreement in place; 3) proposal was not reviewed and submitted by Duke University in advance of the award as required by the Internal Submission for External Funding Applications policy; or 4) the research project or activities are not within the mission of Duke University*.

*Applications proposing activities (e.g. clinical care, graduate medical education, quality assurance, etc.) that are within the mission of Duke University Health System (DUHS) must be coordinated with DUHS in advance of proposal submission to determine the appropriate applicant organization.

1.2 Classified Research

No research can be undertaken at Duke University that involves information, research or results of research that are, or would be, classified by the sponsor or any third party. For example, research for the federal government under a subcontract which is classified as secret is not permitted. Duke University does not have any level of institutional security clearance that would be required to in place to conduct classified research.

Research personnel may arrange to participate in projects involving such research through other institutions on an individual basis. The University cannot arrange to obtain security clearances on behalf of its research personnel; any necessary security clearance must be secured on a need-to-know basis by the organization for whom any work is to be done.

1.3 Earmarks

Duke University is committed to excellence in research and hence to the competitive peer review in the federal funding of research. Research funded by earmarks threatens to undermine national excellence in research by diverting resources from the peer review process. As a result, research personnel and institutional officials are prohibited from seeking advocating, or accepting earmarks which benefit Duke or related entities, except under extraordinary circumstances and with the express permission of the President of the University.

Such extraordinary circumstances would include only those in which the President, in consultation with senior administrative leaders of the University, determined the proposed project involved inherently unique circumstances that could not be replicated elsewhere. When the case for an exception is considered, the strong presumption must be against the taking of earmarks.

1.4 Lobbying

Duke is required by law to submit detailed quarterly reports on state and federal lobbying activity by individuals employed, or acting on behalf of, the University and the Health System. Duke University defines lobbying as any attempt to influence legislation on Duke's behalf through direct lobbying or grassroots lobbying. In order to capture various lobbying activities for Duke, the Office of Government Relations sends out a web-based lobbying questionnaire on a quarterly basis to select individuals on campus.

In addition, individuals who are required to complete a Conflict of Interest disclosure form are asked to report lobbying activities as a part of the COI annual disclosure process.

The University recognizes that investigators, research personnel and other members of the Duke community will have a range of interactions with government officials, including discussions related to research activities and results. To assist the community with assessing when and how to report activities, the Office of Government Relations provides examples of government interactions and recommendations for action.
Duke University community members are encouraged to review the examples of government activity and familiarize themselves with recommended actions to allow the University to provide accurate reporting of lobbying activities.