Research Compliance Spring 2017 Newsletter

NIH Researchers – Annual Disclosures are Due!

All investigators who are seeking or have obtained HHS research support must submit their annual update beginning on Thursday, June 1st.  Any disclosures submitted prior to Thursday, June 1st will not count towards the annual update for FY18.

Please keep in mind the following requirements:

  • Any HHS investigator, or anyone who intends to be an investigator on a future proposal to an HHS agency, must submit an annual disclosure no later than July 31, 2017.
  • Annual disclosures from last year will not be current after July 31, 2017 and must be updated in USC’s conflict disclosure system (“diSClose”) by that date.
  • Any previously disclosed relationships must be updated, regardless of whether there are any changes, with current information.
  • Any previously disclosed relationships that are no longer active should be removed.
  • Investigators need to complete their annual disclosures in order to submit new proposals or access continuation funding on an existing award.
  • Disclosures posing potential conflicts of interest will be reviewed by the Conflict of Interest Review Committee (CIRC) in accordance with USC’s Conflict of Interest in Research policy.
  • Investigators must personally submit their disclosures.  Disclosures cannot be delegated to others, who would not be expected to know an investigator’s disclosable financial interests.

For new investigators, more information about Conflict of interest training can be found here:

diSClose may be accessed at  In order to log in, a USC NetID and password are needed.  The USC NetID is the first part of the USC e-mail address, and is the same ID used to access other USC applications like Kuali, Workday, Blackboard, and myUSC.

If you need any help logging in to diSClose (including your USC NetID or password), please call the Help Desk at (213) 740-5857.

If you have questions, contact the Office of Culture, Ethics and Compliance at (213) 740-8258 or

Meeting NIH’s RCR Training Requirement: INTD 500

The NIH requires that all trainees, fellows, participants, and scholars undergo in-person training in the responsible conduct of research.  The training requirement applies to all NIH Institutional Research Training Grants, Individual Fellowship Awards, Career Development Awards (Institutional and Individual), Research Education Grants, Dissertation Research Grants, or other grant programs with a training component that requires instruction in responsible conduct of research as noted in the Funding Opportunity Announcement. (NIH RCR Requirement:  NOT-OD-10-019)

The Keck School is pleased to again offer INTD 500: Responsible Conduct of Research (RCR), a one-week course that satisfies NIH RCR training requirements. The class is open to all faculty, staff, postdoctoral fellows, masters and graduate students conducting research.  Faculty, staff, and postdoctoral fellows and masters students auditing the course will receive a certificate of completion at the end of the course.

Lecture and discussion topics include: scientific integrity, misconduct and fraud in science, data acquisition and management, collaborative research, responsible authorship, conflicts of interest, innovation advancement and patents, animal welfare, human subjects, mentor/mentee responsibilities and professionalism in scientific relationships.

The course will be offered at McKibben Hall (MCH 149) between July 10 through July 14, 2017, from 9 AM – 11 AM, Monday through Friday (Session # 40690).

The NIH requires that in-person training be renewed every four years.  One option to satisfy the renewal requirement is to serve as a mentor for INTD 500 class discussions.  If you are interested in pursuing this option, please contact Donna Spruijt-Metz (

This course does not require D-clearance to register.  To sign-up to audit the course, send an email to Alexandra Lipari at (postdoc and MS students only).  Any questions about the content of the course can be directed to Dr. Spruijt-Metz.

You can read more about the training requirement here:

New International Collaborations and Export Controls Policy

USC has issued a new policy on International Collaborations and Export Controls.  The policy was developed in cooperation with the Academic Senate, the Senate/Provost University Research Committee, and a special task force of faculty and staff, and is designed to  help faculty, staff, and students comply with federal regulations that may apply to a variety of USC-related activities, including research, instruction, healthcare, student outreach, and other partnerships and affiliations.

In developing the policy, faculty and staff carefully considered how best to balance the needs of protecting academic values, offering flexibility in developing relationships that increase USC impact, and meeting legal requirements.  Among other issues, the policy addresses:

  • Creation of a standing faculty committee to advise on research projects that restrict dissemination of research results and/or foreign nationals (faculty, staff, students) from accessing research data or participating in research projects;
  • Obtaining approval from the Office of the Vice President for Strategic and Global Initiatives before establishing an overseas physical presence or international partnership with any overseas university, institution, or governmental entity, excluding sponsored research agreements and technology licenses; and
  • Guidance on doing business with foreign governmental officials in accordance with the Foreign Corrupt Practices Act (FCPA).

The policy also provides guidance on international travel to countries sanctioned by the Office of Foreign Assets Controls (OFAC) (e.g., Cuba, Syria, Iran, Sudan, Crimea region of Ukraine), information security practices to protect the security and confidentiality of information taken overseas in connection with university-related travel, and exporting of items overseas.

The policy can be found here:

NSF Office of Inspector General (OIG) Audit Reports

The NSF OIG recently published final audit reports for Purdue University and UC San Diego, two institutions who, like USC, were included in the NSF OIG’s audit initiative.  Of note, both audit reports contain findings in areas that the NSF OIG focused on during its field work at USC.

Major findings included:

  • equipment, materials, and supplies expenses unreasonably purchased near award expiration
  • insufficiently documented travel charges
  • unreasonable travel

In both reports, the OIG stated that, “[a]ccording to NSF policy, a grantee should not purchase items of equipment, computing devices, or restock materials and supplies where there is little or no time left for such items to be utilized in the actual conduct of the research.”  There are exceptions – if a no-cost extension is granted or if the purchase is to replace broken equipment necessary to finish the research, such charges are likely allowable if they are well documented and reasonable.

With regard to travel charges, the OIG found that the universities had not demonstrated “a clear benefit and necessity to the award” for the questioned trips and disallowed the charges.  The OIG focused on travel that was not budgeted in the award, not mentioned in progress or final reports, and with no clearly documented benefit to the award.

To address this risk, USC investigators must only charge sponsored projects for reasonable travel expenses and articulate a specific business purpose, particularly when the trip was not specifically budgeted for in the award.

You can access the audit reports here:

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