The Office of Sponsored Projects and Research support the college's goals of investing in our faculty and staff and advancing academic excellence.
Our office assists faculty, staff, and students distinguish themselves through their scholarly efforts. We accomplish this by assisting with the funding needs of faculty, staff, and students engaged in original research, creative endeavors, and other forms of scholarship. Our office:
- Funds faculty scholarly projects through internal grant programs
- Provides consultative services and technical support for faculty developing external grant proposals
- With our partners in the Business Office, assists with the administration of grant awards
- Upholds the college's mission by attending to regulatory and compliance concerns through the development of policies and procedures relating to externally sponsored projects
We strive to serve the campus community with exceptional expertise and customer service. Please let us know how we may assist you.
Saint Anselm College Institutional Profile
Saint Anselm College
Office of Sponsored Programs and Research
Legal Name and Address
Saint Anselm College
Office of Sponsored Programs and Research
100 Saint Anselm Drive, Box 1738
Manchester, NH 03102-1310
Phone: (603) 641-7174
Fax: (603) 641-7222
Congressional District: NH 1
Authorized Saint Anselm College Representatives
Mary Ellen Emmerling, Grants Administrator and Accountant (603) 641-7253
Important Institutional ID Numbers and Dates
Employee Identification Number (EIN) 02-0222182 Dun and Bradstreet Number 073969388 Human Subjects Federal Wide Assurance # FWA00011017
Expires: January 8, 2018
Fringe Benefits Rate
The following percentages should be used on budgets accompanying proposals:
- 16% for the summer
- 30% for the Academic Year
Facilities and Administrative (Indirect) Costs
In accordance with our negotiated agreement with the DHHS, the following predetermined rate should be used until further notice: 53% of Modified Total Direct Costs.
Grant Approval Process
The Grant Proposal Guidelines have been recently updated to require that all grant proposals be approved by the Grant Proposal Review Committee before being submitted to a funding agency (see Faculty Handbook in the Portal).
When faculty and staff members consider applying to sources outside Saint Anselm College for grants or other forms of financial support, they should complete a Grant Review Form (PDF/27KB), and submit it to the director of sponsored programs and research. This brief form provides the committee with basic information about the proposal and the extent to which it will involve the college in any form of fiscal obligation, including funds, in-kind contributions or released time. In most cases, the committee will approve the proposal within one week of receiving the form.
For your convenience, the college's grant review form may be downloaded (below) and saved to your computer. Completed forms should be sent via email as an attachment to email@example.com. If you have questions about the grant proposal process, please contact Sponsored Programs and Research at (603) 641-7174.
Sponsored Programs Policies
Sponsored Programs Policies
This page lists the major policies and procedures of the College relevant to externally sponsored (grant-funded) projects.
- Human Subjects in Research
- Mandatory Research Integrity training
- Principal Investigators of Sponsored Projects
- Faculty and Staff Compensation from Sponsored Projects
- Financial Conflict of Interest (includes disclosure forms)
- Charging and Distribution of Indirect Costs
- Authority to Submit Proposals
- Intellectual Property
- Research Misconduct (PDF/263KB)
Please note that Saint Anselm College considers instances of non-compliance with institutional policies, including those pertaining to sponsored projects and research, to be serious events which could result in loss of funding or other consequences as appropriate to the case.
Please note that the following definitions apply to these policies:
- A grant represents a contractual arrangement with a federal, state, private, or other non-college agency under which funds are made available and are administered by the College for a specified project or program. This excludes contracts to individual faculty for consulting or fellowships.
- Research is "a systematic investigation, including development, testing, and evaluation, designed to contribute to generalizable knowledge." As described in the Belmont Report ". . . the term 'research' designates an activity designed to test a hypothesis [and] permit conclusions to be drawn . . . Research is usually described in formal protocol that sets forth an objective and a set of procedures to reach that objective." 'Research' generally does not include operational activities such as practice activities in medicine, psychology, social work, and public health (e.g., routine outbreak investigations and disease monitoring) and studies for internal management purposes such as program evaluation, quality assurance, quality improvement, fiscal or program audits, marketing studies, or contracted-for services. It generally does not include journalism or political polls. However, some of these activities may include or constitute research in circumstances where there is a clear intent to contribute to generalizable knowledge.
- The terms pay, salary, stipend, honoraria, etc. all represent additional compensation.
Saint Anselm College requires that we inquire immediately into allegations or other evidence of possible compliance deficiencies. If federal funds are involved, we must be prepared where appropriate to take interim administrative steps to protect federal funds and ensure that the purposes of the federal assistance are carried out. Institutional procedures for handling perceived deficiencies must maintain a common, formal and easily available entry point for receiving all allegations.
If you want to report what you believe to be a perceived deficiency regarding misconduct in research, please read Saint Anselm College's Research Misconduct Policy (PDF/263KB).
The Research Integrity Officer (RIO) is the institutional official responsible for assessing allegations of research misconduct to determine if they fall within the definition of research misconduct and warrant an inquiry on the basis that the allegation is sufficiently credible and specific so that potential evidence of research misconduct may be identified. The RIO at Saint Anselm College is the Vice President of Academic Affairs or his/her designee.
Misconduct in research runs contrary to Saint Anselm College's mission as an institution of higher education, undermines the public trust placed in the research enterprise of our nation's colleges and universities, and wastes valuable public and private resources. Therefore, it is the policy of Saint Anselm College to neither condone nor tolerate research misconduct by any member of its community.
This statement of policy and procedures is intended to carry out Saint Anselm's responsibilities under the Public Health Service (PHS) Policies on Research Misconduct, as well the corresponding policies on research misconduct of a variety of federal funding agencies.
This document applies to allegations of research misconduct (fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results-see Section II.) involving a person who, at the time of the alleged research misconduct, was employed by, was an agent of, was under the authority of, or was affiliated by contract or agreement with this institution. As such, the document is applicable to all members of the College community, including, but not limited to, faculty, staff, and graduate and undergraduate students.
This document does not distinguish between funded and unfunded research activities, except where it refers to specific agency requirements.
This document does not distinguish between scholarly disciplines. It is acknowledged, at the very least, that research may take on a different character from discipline to discipline. However, each discipline has its professional standards of conduct, and to the extent that fabrication, falsification, or plagiarism are rejected by those professional standards, this document applies to the research activities of those disciplines.
Research Misconduct (as defined in this document) is a specific instance of impropriety within the broader domain of personal and professional conduct. Allegations of misconduct outside the scope of research misconduct as defined in Section II should be directed to the appropriate chair, dean, director, vice president, or other College official.
This statement of policy and procedures does not apply to authorship or collaboration disputes.
Authority to Submit Proposals for Externally Sponsored Projects and Research and Signature Authority for Sponsored Projects and Research
Authorized Organizational Representatives
For the purposes of external grants for sponsored programs and research, the Authorized Organizational Representative (AOR) of Saint Anselm College is the Chief Financial Officer of the College, who has the authority to bind the institution in formal agreements. The Chief Financial Officer signs all formal award documents, indicating acceptance of the award. Individual faculty, staff, or students are not authorized to bind the college in formal agreements.
At the proposal submission stage, many sponsors require the sign-off of the AOR indicating the institution's willingness to put forward the application on behalf of the Principal Investigator of the proposed project, and in some instances, to provide institutional Certifications and Assurances required by the program. This may involve an actual signature on a form, or a "digital" signature through an electronic submission system. For efficiency in operations, the Director of Sponsored Programs and Research serves as the college's delegate during the proposal submission process, signing on her/his behalf and providing the required Certifications and Assurances for the grant proposal.
The Director of Sponsored Programs and Research invokes this authority only after the proposal has undergone the Routing/Approval process adopted by the college, including the signature of the Vice President for Academic Affairs or the Appropriate Vice President, the Vice President of Finance and the Director of Sponsored Programs and Research on the internal Proposal Review Form. In the event of the absence from campus of a key individual whose signature is required, his/her designee shall sign.
Saint Anselm College community members are reminded that all grant proposals for sponsored programs and research are to be submitted via Sponsored Programs and Research, who will submit the proposal to the sponsor on your behalf after all internal approvals have been secured. The college reserves the right to withdraw any application that has not been institutionally approved at the proposal stage, or to decline awards emanating from unapproved submissions.
Charging and Distribution of Indirect Costs (Overhead) Policy
Indirect Costs that are recovered from external grants awarded to the college are intended to cover costs that are incurred for common or joint objectives and therefore cannot be readily identified with a specific project or activity of an organization. Typical examples of indirect cost type items are the costs of operating and maintaining facilities, local telephone service, office supplies, and accounting and legal services. It will be the policy of the college to apply the maximum allowed indirect costs to all grants and this amount should be included in all grant application budgets. Any exception to applying the full overhead rate will require the approval of the Dean of the College/or Relevant Vice President, the Director of Sponsored Programs and Research, the Chief Financial Officer and the Executive Vice President.
The college's current federally negotiated indirect cost rate is 53% MTDC. Our current practice with the state of New Hampshire is to charge a rate of 10% as a courtesy to the state and in recognition of our role in the region. Many foundations also allow overhead costs to be added to grants, and the allowed rate for each specific foundation should be charged.
Distribution of Indirect (Overhead) Funds
Beginning with the current fiscal year, the college will establish a policy to distribute a portion of indirect costs recovered from external grants to the Dean of the College or relevant Vice President, department, and Principal Investigator who were awarded the grants. In the past, all indirect costs went to the college's General Fund. With the new policy, indirect costs (overhead) will be distributed as follows:
- Principal Investigator (PI) 25%
- PI's home department or Center/Institute 15%
- Dean of the College or relevant Vice President 20%
- General Fund (15%)
- Grants Office (25%)
If the award specifies that the project is affiliated with a center or institute, the departmental portion (15%) will be directed to the named center/institute, rather than the PI's home department. If faculty from more than one department are involved in the research project, the department of the lead PI will receive the funds.
Because overhead funds are awarded to the college, Saint Anselm College reserves the right to change this policy at any time or to make exceptions to it on an individual basis. Grants that are received as earmarks to the college or that involve dollar amounts in excess of $500,000 will be reviewed individually. The college also reserves the right to review and reallocate individual research accounts accumulated over time.
Guidelines for Implementation of the Policy
The restricted funds that go to the PIs, departments/centers/institutes, the Dean and Vice Presidents can be used for a variety of purposes necessary for carrying out all research and programmatic projects and to encourage and support sponsored research, including, but not limited to, seeding new projects, attending conferences, hiring research assistants, related travel, equipment, supplies and materials and the like. These funds are not to be used for faculty salaries. Where appropriate, PIs are encouraged to discuss with their department chairs how funds to the department and funds to the principal investigator (PI) might be pooled to enhance the overall research infrastructure necessary for the conduct of research or to partner with other organizations to conduct research. Overhead funds remaining in the account of a PI will be returned to the college's general fund if the PI is no longer employed with the college.
Most costs for grant-funded projects must be charged directly to the grant (as direct costs). Such costs include an appropriate percentage of the PI's annual and/or summer salary, course buyouts, consultants, undergraduate assistants, equipment needed for research, travel, subject payment fees, postage, photocopy charges, costs of lab analysis, materials that will be used solely for the conduct of a specific research project, etc. Please contact Mary Mader, Director of Sponsored Programs and Research, at (603) 641-7174, firstname.lastname@example.org for assistance with proposals and awards.
Approved by the Saint Anselm College Faculty Senate and the Senior Leadership Team 3/10.
Collaborative Institutional Training Initiative (CITI) Training
In order to assist Saint Anselm College researchers in meeting institutional and sponsor requirements for research integrity training, the college is a member of the Collaborative Institutional Training Initiative (CITI). This paid subscription provides online training modules in three key areas of research ethics:
- Responsible Conduct of Research (RCR)
- Institutional Review Board (IRB) Protection of Human Subjects
- Institutional Animal Care and Use Committee (IACUC)
Investigators conducting research that is externally sponsored or which involves human or animal subjects (regardless of funding status) must complete the appropriate training module(s).
To complete the training, please visit the CITI Web site, and complete the following steps:
- Register and affiliate yourself with Saint Anselm College. This is essential so that SAC receives proof of your completion of training via a system generated notification.
- Select the appropriate course(s) (e.g., Responsible Conduct of Research, Human Subjects Research, Lab Animal Research) and the appropriate learner group (e.g., Social/Behavioral Research, Humanities, Physical Sciences, etc.)
- Complete the online readings and quizzes. You may log in and out of the system as many times as you need. It is recommended that you NOT try to complete the training in a single session. Each time you log in, you will be able to continue from where you previously left off. You can repeat quizzes and readings as many times as needed.
If you need assistance registering with the system or additional information, please contact Mary Mader, Director of Sponsored Programs and Research at email@example.com or (603) 641-7174.
Faculty and Staff Compensation from Sponsored Projects
In keeping with federal requirements for external funding, the college must comply with the Office of Management and Budget (OMB) Circular A-21, Cost Principles for Educational Institutions for all federally sponsored programs. Because the federal government is a primary sponsor of research and other scholarly activities at Saint Anselm College, the cost policies of the federal government are extended to all sponsored projects, regardless of sponsor type.
Faculty Compensation from Sponsored Projects: Academic Year Effort
Faculty may not receive more than their regular annual salary as a result of participation in sponsored projects during the academic year. This is in accordance with OMB Circular A-21 Section J.10.d.(1) which states "In no event will charges to sponsored agreements, irrespective of the basis of computation, exceed the proportionate share of the base salary for that period."
Some sponsors will reimburse the college for a portion of a faculty member's academic year salary when the sponsored project is carried out during the academic year. This does not increase the faculty member's salary, but generally helps the institution recover a portion of the salary expenses that are allocable to the sponsored project. This is commonly referred to as a "buy-out" of the faculty member's time by the grant (or can take the form of a "course buy out") to complete the work of the project. Salary replacement funds provided by grants shall be returned to the College's general fund.
Example: A faculty member's annual 9-month salary equals $50,000. As a PI on a grant, the faculty member requests and is granted $5,000 from the sponsor in academic year salary to cover 10% effort spent on the project during the academic year. The faculty member would still receive a salary of $50,000 for the academic year, not $55,000.
Faculty Compensation from Sponsored Projects: Summer Effort
A faculty member on a 9-month contract may be paid summer salary (supplemental pay over and above the 9-month academic year salary) for effort contributed to a sponsored project during the 3-month summer period. Charges are based on the same monthly base rate of pay as during the academic year. Summer salary chargeable to grants and contracts is limited to that effort actually expended on the project. Faculty members receiving three months of summer support (maximum allowable) from a sponsored project must put the entire three summer months into the work of the grant. Summer salary cannot be paid for effort expended during the academic year.
Example 1: A faculty member on a 9-month contract may be paid one-ninth of his/her prior academic year salary for one summer month of sponsored research. If the faculty member's academic year salary is $50,000 for nine months, the faculty member receives an additional $5,556 ($50,000 / 9 = $5556) for the month spent working on the sponsored research project. $50,000 + $5556 = $55,556 in total pay.
Example 2: A faculty member plans to spend two weeks at ½ effort (one week total effort) in the summer prepping for a grant funded project (e.g., a program he or she will lead). Delivery of the program itself will constitute one additional week of full-time effort. Thus, the faculty member may receive supplemental pay from the grant equivalent to 2 weeks in total (1/2 month). Assuming the faculty member's salary is $50,000 for nine months, the faculty member receives an additional $2,778 ($50,000 / 9 = $5,556 monthly salary divided by 2 to get to ½ month effort).
Compensation from Sponsored Projects: 12-Month Faculty, Administrators, and Staff
All 12-month employees performing work on sponsored projects are generally not eligible to receive pay beyond their regular compensation. In rare instances where the work meets the federal criteria for intra-college consulting (work must be clearly distinct from their normal duties and occur outside of their normal work hours or during a period for which the individual has used accrued leave) during the period for which they request supplemental pay. Requests must be approved by the individual's Supervisor, the appropriate Vice President and Human Resources in consultation with Sponsored Programs and Research.
Federal Policy: OMB Circular A-21 J.10.d (1) (Cost Principles of Educational Institutions - Compensation for Personnel Services) states: Since intra-university consulting is assumed to be undertaken as a university obligation requiring no compensation in addition to full-time base salary, the principle also applies to faculty members who function as consultants or otherwise contribute to a sponsored agreement conducted by another faculty member of the same institution. In unusual cases where consulting is across departmental lines or involves a separate or remote operation, and the work performed by the consultant is in addition to his/her regular departmental load, any charges for such work representing additional compensation above the institutional base salary are allowable provided that such consulting arrangements are specifically provided for in the agreement or provided in writing by the sponsoring agency. An employee providing consulting services within their primary department is ineligible for additional compensation (OMB Circular A-21). An employee who is an investigator on a sponsored project cannot be compensated for intra-university consulting on that project.
Administrative Support Costs Charged to Sponsored Projects
Because administrative support is designated under OMB Circular A-21 as being part of our indirect costs, administrative support salaries should not be directly charged to federal grants (supplemental or otherwise). PIs with extraordinary administrative support needs in connection with a grant should speak with the Dean or the appropriate Vice President prior to proposal submission about utilizing some of the indirect dollars returned to the school under the college's Indirect Cost Distribution Policy to assist with these needs.
Financial Conflict of Interest in Research Statement of Need and Purpose
Externally sponsored research is an important part of supporting faculty scholarly research and fulfilling the college's mission. As this activity grows in sophistication and complexity it may intersect increasingly with industrial explorations and entrepreneurial ventures, creating for investigators the potential for conflicting interests. A conflict of interest exists when it can be reasonably determined that an investigator's personal financial concerns could directly and significantly influence the design, conduct, or reporting of sponsored research activities. Faculty and staff of the college have an obligation to scrupulously maintain the objectivity of their research, avoiding any conflict of interest.
Saint Anselm College has developed this policy to protect the integrity of sponsored research and to comply with federal regulations. These regulations require that any faculty and staff member in a position to influence the outcome of a funded project asserts that he or she has no financial conflict of interest with regard to the project, or report any conflict that does exist. It is the intent and policy of the college, as an institution of higher education in receipt of federal research support, to comply with present and future regulations.
Specifically, the intent of this policy is to identify and eliminate or manage any possible threat to research objectivity at Saint Anselm College. The main components are disclosure of investigators' financial interests that might be affected by the research, and application of methods to minimize or eliminate the risks associated with such connections. It is not meant to discourage, but rather to safeguard the pursuit and dissemination of knowledge.
This policy becomes effective July 1, 2010 and applies to any employee of Saint Anselm College who is responsible for the design, conduct, or reporting of research activities funded or proposed for funding by external sources. The policy also includes the investigator's immediate family, which is defined as his/her spouse or domestic partner and dependent children. Project directors are responsible for ensuring that all participants in a project who are responsible for the design, conduct, or reporting of the research disclose any significant financial interests that would reasonably appear to be affected by the research. Individuals who come to work on an established project through reallocation of effort, hiring, transfer, promotion, etc., and thereby take on a responsible position in a project, must also disclose any such significant financial interests.
Collaborators, subcontractors, sub-recipients, and visiting scientists must either comply with this policy or provide a certification to the college Grant Officer that their institutions are in compliance with pertinent federal policies and that they in turn are in compliance with their own institutional policies. Subcontractors from commercial firms need make a certification only when the prime award is from the Public Health Service.
Significant Financial Interests
Any Saint Anselm College employee responsible for the design, conduct, or reporting of research activities funded or proposed for funding by external sources must reveal all current significant financial interests that would reasonably appear to be affected by the research. Significant financial interest is defined as any current financial interest of the investigator and his/her immediate family that could reasonably appear to be affected by the activities proposed for funding; or any interest held by the investigator and his/her immediate family in a business entity (company, corporation, or other enterprise) whose financial interests might reasonably appear to be affected by such activities.
Specifically, significant financial interests might include, but are not limited to, any of the following:
- Anything of significant monetary value, including salary or other payments for services, such as consulting fees or honoraria;
- Direct equity interests, such as stock, stock options, or ownership interests;
- Intellectual property rights owned by the investigator, such as patents, copyrights, and royalties from such rights.
The term does not include:
- Financial interests in business enterprises or entities that when aggregated for the investigator and his/her immediate family meet both of the following tests:
- the financial interest does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and
- the financial interest does not represent more than a five percent ownership interest in any single entity.
- Salary, royalties, or other remuneration from Saint Anselm College
- Salary, royalties, or other payments that when aggregated for the investigator and his/her immediate family, are not expected to exceed $10,000 during the next twelve month period;
- Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
- Income from service on advisory committees or review panels for public or non-profit entities.
An investigator may choose to disclose any other financial or related interest that might present an actual, potential, or perceived conflict of interest. Disclosure can be a key factor in protecting an individual's reputation and career from potentially harmful allegations of misconduct.
All Disclosure Statements and related documents are considered sensitive information and only those persons involved in the implementation of this policy will have access to such records.
Each investigator who has significant financial interests possibly affected by the research must complete a Saint Anselm College Financial Disclosure Statement (Word/17KB) and attach all required supporting documentation. In addition, the investigator must submit a proposed conflict of interest management plan that details steps that could be taken to manage, reduce, or eliminate any conflict of interest. The form, documentation, and plan should be submitted in a sealed envelope marked confidential to the Grants Officer.
All significant financial interests must be disclosed prior to the time a proposal is submitted. All financial disclosures must be updated by investigators during the period of the award as new reportable significant financial interests are obtained.
Review of Disclosures
The Vice President of Finance will review all disclosure statements to determine whether the significant financial interests of the investigator could reasonably be expected to affect the design, schedule, conduct, or reporting of the activities funded or proposed for funding. The Vice President of Finance may request additional clarifying information from the individual which will be treated as non-public information to the extent allowed by law.
Management Plans for Conflict
The Vice President of Finance may propose a conflict management plan and approve it or add conditions or restrictions to ensure that any conflict is managed, reduced, or eliminated. Such conditions or restrictions may include, but are not limited to, the following:
- Public disclosure of significant financial interests
- Monitoring of the research by independent reviewers
- Modification of the planned activities (possibly subject to sponsor approval)
- Disqualification from participation in all or part of the project
- Divestiture of significant financial interests
- Severance of relationships creating conflict.
In all cases, resolution of the conflict or establishment of an acceptable conflict management plan must be achieved before expenditure of any funds under an award.
If a conflict cannot be resolved to the investigators satisfaction, an appeal may be made to the college's Executive Vice President or President, who will consult with the investigator and the Vice President of Finance and make a binding decision.
As part of the Financial Disclosure Statement each investigator must certify that if the Vice President of Finance determines a conflict exists, the investigator will adhere to all conditions or restrictions imposed upon the project and will cooperate fully with the individual(s) assigned to monitor compliance.
Failure to properly disclose relevant financial interests or to adhere to conditions or restriction imposed by the Vice President of Finance will be considered a deviation from accepted standards of conducting research at Saint Anselm College.
Alleged violations of this policy will be investigated by the Vice President of Finance which will make recommendations for action to the Executive Vice President or President. Breaches of policy include failure to file the necessary disclosure statements; knowingly filing incomplete, erroneous, or misleading disclosure forms; or failure to comply with prescribed procedures. If a determination has been made that the policy has been violated, he/she may impose sanctions including notification of sponsor and termination of award; formal admonition; a letter to the investigator's personnel file; and suspension of the privilege to apply for external funding and/or to seek IRB approval.
The Business Office will maintain records of all disclosures and associated activities securely and confidentially. All records will be maintained for three years following the letter of termination or completion of the project or resolution of any government action involving the records. Records will not be routinely provided to sponsors unless such is an agency requirement, the agency submits a written request, or Saint Anselm College is unable to satisfactorily manage an actual or potential conflict of interest. The Grant/Contract Administrator will be responsible for communications with sponsors. Disclosure statements and associated information will not be released without notifying the investigator.
Federal Policy: The National Science Foundation (NSF) Investigator Financial Disclosure Policy and the U.S. Public Health Service (PHS) regulations in 42 CFR Part 50, and 45 CFR part 94, under the heading of Objectivity in Research are effective as of October 1, 1995, and carry the weight of federal regulation. The federal policies stipulate requirements for:
- annual financial disclosures on the part of ALL research investigators supported by NSF or PHS (defined in Section 3 with required form as Attachment 1)
- institutional certification that all proposed and ongoing NIH/NSF sponsored research is either free of conflicts of interest, or that such conflicts are adequately managed (detailed in Section 4)
- the implementation of an institutional mechanism for managing conflicts of interest in research
- keeping NIH/NSF informed if the College is unable to satisfactorily manage actual or potential conflicts of interest
- sanctions where appropriate (Section 7); and
- maintenance of records relating to this policy, for at least three years following the termination of a given project.
Human Subjects in Research
Saint Anselm recognizes the need for investigations in which human beings serve as research subjects. The college is also cognizant of its responsibility for ensuring the privacy, safety, health and welfare of subjects are adequately protected. An Institutional Review Board (IRB) has been established to review and approve the adequacy of human subject protection. Additionally, the College has established a Federalwide Assurance with regard to the conduct of human subjects research.
The policies of the college, with respect to research involving human subjects are guided by The Belmont Report, a federal government document that charges each researcher with the responsibility while conducting human subject research of demonstrating respect for persons, beneficence (maximizing benefits and minimizing risks), and justice.
The policies are based on the following principles:
- Participation in any research project must be voluntary
- The risks of participation must be acceptable when measured against the possible benefits to the participant or by the importance of the knowledge gained
- Research and training activities involving human subjects must be supervised by a qualified person
- All research programs that involve human subjects must be reviewed and approved by the IRB prior to initiation of the protocol
- Per federal regulations, all continuing research must be reviewed on an annual basis
- This applies to all research involving humans, not just clinical research and regardless of whether or not the research is funded.
Saint Anselm College IRB approved 8/18/10
Saint Anselm College ("the College") is dedicated to teaching, research, and the dissemination of knowledge to the public. The College encourages and supports faculty and students, and any other persons employed by the College, in the production of scholarly, technological, innovative, and creative works. The College is committed to protecting and promoting Intellectual Property and Academic Freedom.
This policy applies to all faculty, staff, students, and any other persons employed by the College and/or receiving funding administered by the College.
This policy will cover all forms of legally recognized "Intellectual Property" which is created at the College. For the purposes of this policy, the individual or group of individuals who authored, invented, or are otherwise responsible for the creation of this "Intellectual Property" will be referred to as the "Creator." Intellectual Property will include, but is not limited to, the following:
Under 17 US Code Section 102, Copyright law protects original works of authorship in any medium. This includes, but is not limited to, the following:
- Scholarly works (e.g. research monographs and articles, publications, research materials, textbooks, class notes, instructional materials, and materials posted on faulty Blackboard courses sites, department Web sites, and faculty Web sites);
- Creative/artistic works (architecture, art, dance, fiction, film, music, poetry, and sculpture);
- Copyrightable software; and
- Other developing areas, including but not limited to, distance learning, online courses, multi-media works, and various other forms of electronic communications;
Including, but not limited to, inventions and discoveries (e.g. devices, processes, improvements and software patentable under federal laws);
As recognized under state and federal laws; and
All data generated during research at the College, to include but not limited to:
- Research notes, research data reports, computer-generated statistical analysis, and research notebooks;
- Lab notes, results of analysis, etc., and;
- New forms of Intellectual Property that are associated with the categories above.
Creator Ownership of Intellectual Property
The ownership of Intellectual Property created or originated by the Creator shall be the sole property of the Creator. Any income or funds generated from the sale of this Intellectual Property are solely owned by the Creator. The only exception is if the Creator voluntarily chooses, in writing, to transfer this ownership right, in whole or in part, to the College (or other third-party).
College Ownership of Intellectual Property
The ownership of Intellectual Property, created or originated by the Creator, shall be owned by the College only under the following circumstances:
- The Creator has voluntarily transferred ownership rights, in whole or in part, to the College through a written document signed by the Creator and the College;
- The College and the Creator have entered into a written, signed agreement where the College has agreed to contribute to a "joint work" project with the Creator under the federal Copyright Act; and
- The College expressly directs a person(s), defined in Paragraph 2.0 of this policy, to create a specific work in the course of the person's administrative duties (i.e., faculty committee and departmental work) or as a specific requirement of said person's employment or duties.
The College shall own any and all funds for Intellectual Property solely owned by the College. Funds received by the College for the sale of Intellectual Property jointly owned by the Creator and the College shall be allocated and expended in accordance with the written provisions in Paragraphs 5.0(A) and 5.0(B) of this policy.
Interpretation, Issues, and Disputes
In implementing this intellectual property policy, there shall be the creation of an intellectual property and rights committee. This committee will comprise three (3) members from the faculty (elected annually from and by the Faculty Senate) and three (3) members from the administration (appointed annually by the president of the College). These six (6) members will elect a chair for the current academic year.
The Intellectual Property and Rights Committee shall monitor and review technological and legislative changes affecting intellectual property policy and shall report to relevant persons and administrative bodies, when such changes affect existing policies. The committee shall serve as a forum for the receipt and discussion of proposals to change existing institutional policy.
Disputes over ownership, and its attendant rights, of intellectual property will be decided by the Intellectual Property Policy and Rights Committee. The committee shall also make a determination on resolving competing faculty claims to ownership when the parties cannot reach an agreement on their own.
ITCP Approved 4/20/07
Mandatory Research Integrity Training
Saint Anselm College expects faculty, staff, and students to conduct their work, including sponsored projects and research, with the highest degree of integrity. Likewise, federal sponsors are increasingly imposing requirements for grantee institutions to demonstrate the proficiency of their investigators in the ethical considerations inherent in research. These requirements reflect a shared societal concern for the proper stewardship of public dollars in support of research, the ethical treatment of human subjects, and the humane care and use of animals in research. Saint Anselm College shares these commitments and therefore puts forward the following training requirements. This policy constitutes minimum standards set forth by Saint Anselm College. Specific sponsors may have more stringent training requirements, in which case investigators supported by those sponsors are required to adhere to those requirements.
There are three areas of research integrity training covered by this institutional policy:
- Responsible Conduct of Research training (for those supported under externally funded research grants)
- Protection of Human Subjects training (for all individuals conducting research with human subjects, regardless of funding source)
- Animal Care and Use training (for all individuals conducting research with vertebrate animals, regardless of funding source)
Applicability: This Responsible Conduct of Research (RCR) training requirement applies only to externally sponsored research. The policy does not apply to other types of externally sponsored/funded projects. For example, externally sponsored projects that are primarily creative or artistic in nature, or grants supporting instruction or service delivery are not covered by this policy. This policy also does not apply to internally funded research.
This requirement applies to all individuals (faculty, staff, and students) supported under externally sponsored research projects. For the purposes of this policy, the term "supported" means receiving payment for personal services (e.g., salary or wages).
This RCR training policy is in effect for all externally sponsored awards received on July 1, 2010 or after.
Requirement: All faculty, staff, and student researchers supported under externally sponsored research projects are required to complete the CITI Responsible Conduct of Research (RCR) online training course made available through the Sponsored Programs and Research website. Individuals shall register on the CITI site, affiliate themselves with Saint Anselm College, and choose the appropriate RCR course based on the individual's discipline (e.g., Humanities, Social & Behavioral Sciences, Physical Sciences etc.). Upon completion of the course, the Sponsored Programs and Research Office will automatically receive a completion notification for the individual which will be made available to external sponsors by request. Training certifications are valid for a period of three years, after which time it is the individual's responsibility to complete a "refresher" CITI module.
Sponsor funds will not be released to the Principal Investigator of a sponsored project until documentation of his/her completion of the RCR course is received. It is the Principal Investigator's responsibility to ensure each current or future member of his/her research team supported by sponsor funds (including students) also completes the training course.
Faculty, staff, and students conducting research activities not supported under externally sponsored projects are not required to complete this training, but are strongly encouraged to do so. Saint Anselm College has purchased a campus-wide membership to the CITI training site and all members of our community are encouraged to utilize this resource.
Additionally, faculty are encouraged to consider ways in which the training course may be incorporated into their course work to enhance student understanding of research ethics.
IRB Protection of Human Subjects Training
Applicability: This Institutional Review Board (IRB) training requirement applies to all faculty, staff, or students conducting activities that meet the definition of human subjects research, regardless of whether those activities are externally funded, internally funded, or unfunded. Individuals needing clarity on whether their activity meets the definition of human subjects research should contact the IRB Chair. This IRB training policy is in effect for all human subjects research protocols submitted to the IRB as of July 1, 2010 or later.
Requirement: Individuals conducting human subjects research are required to complete the CITI Institutional Review Board (IRB) online training course made available through the Sponsored Programs and Research website. Individuals shall register on the CITI site and affiliate themselves with Saint Anselm College. Upon completion of the course, the Sponsored Programs and Research Officer and the Chair of the Saint Anselm College IRB will automatically receive a completion notification for the individual which will be made available to external sponsors (if applicable) by request. Training certifications are valid for a period of three years, after which time it is the individual's responsibility to complete a "refresher" CITI module.
Faculty, staff, and students are reminded that no research with human subjects may be conducted without the advance review and approval of the Saint Anselm College IRB. IRB protocols will not be approved without documentation of the completion of the required training by the Principal Investigator. It is the Principal Investigator's responsibility to ensure each current or future member of his/her research team (including students) engaged in human subjects research also completes the training course.
Additionally, faculty are encouraged to consider ways in which the training course may be incorporated into their course work to enhance student understanding of the ethical considerations involved in human subjects research.
Applicability: This Institutional Animal Care and Use Committee (IACUC) training requirement applies to all faculty, staff, or students conducting research with vertebrate animals, regardless of whether those activities are externally funded, internally funded, or unfunded.
This IACUC training policy is in effect for all animal research protocols submitted to the IACUC as of July 1, 2010 or later.
Requirement: Individuals conducting research with vertebrate animals are required to complete the CITI Lab Animal online training course made available through the Office of Sponsored Programs and Research website. Individuals shall register on the CITI site and affiliate themselves with Saint Anselm College. Upon completion of the course, the Sponsored Programs and Research Officer and the Chair of the Saint Anselm College IACUC will automatically receive a completion notification for the individual which will be made available to external sponsors (if applicable) by request. Training certifications are valid for a period of three years, after which time it is the individual's responsibility to complete a "refresher" CITI module.
Faculty, staff, and students are reminded that no research with vertebrate animals may be conducted without the advance review and approval of the Saint Anselm College IACUC. IACUC protocols will not be approved without documentation of the completion of the required training by the Principal Investigator. It is the Principal Investigator's responsibility to ensure each current or future member of his/her research team (including students) engaged in animal research also completes the training course.
Additionally, faculty are encouraged to consider ways in which the training course may be incorporated into their course work to enhance student understanding of the ethical considerations involved in the use of animals in research.
Saint Anselm College IRB approved 8/18/10
Non Discrimination Statement
Consistent with the Benedictine, Catholic principles that sustain the mission and heritage of Saint Anselm College, no one acting on behalf of the College or in administering the affairs of the College, shall discriminate against any student, faculty, staff, vendor, or contractor on the basis of the individual's race, color, gender, religion, national origin, marital status, age, disability, sexual orientation, or veteran status.
Questions or concerns about this notice or about specific issues may be directed as follows:
Students and applicants for admission:
Dean of Students Office (603) 641-7600 or
for concerns related to athletics, Associate Director of Athletics/Title IX Compliance Officer (603) 641-7800
Faculty and staff:
Office of Human Resources (603) 641-7020 or
Office of Academic Affairs (603) 641-7250
Applicants for employment:
Office of Human Resources (603) 641-7020
Mailing address for all offices is: Saint Anselm College, 100 Saint Anselm Drive, Manchester, NH 03102-1310
Principal Investigators of Sponsored Programs
Research and other sponsored program activities are supportive of Saint Anselm College's broad educational mission and are thus conducted under the responsible control of the College's full-time tenure-track faculty. Principal Investigators (PIs) (also sometimes referred to as Project Directors) of externally funded projects are normally required to be members of the full-time tenure-track faculty.
The Vice President for Academic Affairs must approve each proposal for an externally sponsored program by signing the Proposal Review Form, and, by doing so, are indicating their approval for the PI to undertake the project. In certain instances, it may be appropriate for individuals who are not members of the full-time tenure-track faculty to serve as PIs (e.g., adjunct or contract faculty). If the PI of a proposed project is not a member of the full-time tenure-track faculty, the signatures of the Chair and Dean on the Proposal Review Form also indicate their approval of the person serving in that capacity for that project, after having carefully considered the pertinent issues, including but not limited to:
- Grants are awarded to the college, not to the individual. If the PI, for whatever reason, is no longer available, able, or willing to carry out the work of the grant, the college would need to identify another qualified individual to put forward to the sponsor as a possible replacement PI.
- PIs have fiscal oversight of the grant fund, which includes responsibility for approving expenses and signing time sheets and/or effort reports for employees paid from the grant.
- Sponsors typically require a variety of reports throughout the award lifecycle, including financial and technical reports. The completion of the reports is the responsibility of the PI. The college must be certain that any technical reports can be completed should a PI become unavailable to do so.
In the event that a non-tenure track faculty member is approved to serve as a PI on a grant, an appropriate Co-PI must also be named who is a full-time tenure-track faculty member (or a full-time administrator, where appropriate, such as a Chair, Dean, or Assistant Dean).
Some externally funded programs are clearly of an administrative, as contrasted with an academic or scholarly, nature and should be headed by a full-time staff member. In this case, the appropriate vice president also indicate their approval of the individual serving as PI by signing the Proposal Review Form.
Visiting graduate students, post-docs, and faculty generally do not serve as PIs or Co-PIs. In some cases, an externally funded program may require that one of these individuals be listed as a PI or Co-PI, or there may be another legitimate cause to consider a waiver of this restriction. In such cases, the Office of Sponsored Programs and Research should be contacted well in advance of the proposal deadline so that the case may be discussed and considered with the appropriate college personnel. It should be noted that any PI, Co-PI, or investigator is bound by all Saint Anselm College policies throughout the life of any award.