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Faculty Compliance and Reporting Responsibilities

REPA, ROC, RCR, HIPAA, Human Subjects, and Internet Password

Judy Garrard, Senior Associate Dean for Academic Affairs & Research School of Public Health

May 30, 2008 Download as PDF document

Faculty are required by the Board of Regents to file periodic reports about personal compliance with federal, state, and University policies. Some of these requirements also apply to Professional and Academic (P&A) employees, and to specific staff and students. The purpose of this communication is to summarize six of the major faculty reporting responsibilities and provide additional information and internet resources (URLs).

REPA: Report of External Professional Activities

Description. REPA is a report of all external professional activities and business engaged in by the individual outside of his/her regular university duties, regardless of compensation. The professional activities can be on a volunteer or compensated basis, with or without reimbursement of expenses. The professional external activities can be conducted anywhere, locally, nationally, internationally. In short, any external professional activity that is not part of the individual’s university responsibilities must be reported on the REPA.

Further details about REPA

Each REPA must have an associated ROC (Request for Outside Consulting) on file if the total number of consulting days during an annual appointment exceeds 12 days. (See below for description of ROC.) One of the purposes of the REPA is to review potential or actual conflict of interest at the individual or institutional level.

Who. A REPA report is required of faculty and P&A staff who hole full time (75 percent) appointments. An annual REPA is required of faculty who meet the criteria.

This URL also lists the individuals who are exempt from filing an end-of-year REPA.

How Often: REPAs must be filed annually and whenever a new reportable activity is initiated. Each new REPA must be accompanied by a ROC (Request for Outside Consulting) that has been approved by your Division Head and Associate Dean for Research.

Will I Get a Reminder? Yes. In September of every year, the University sends an e-mail message reminding all faculty to file an annual REPA report. This annual requirement must be completed by December of that year. The filing of additional REPAs during the year will be up to you.

Policy Requiring a REPA. Regents Policy is located at this URL: http://www1.umn.edu/regents/policies/administrative/Institutional_COI.htm. This policy is administered by the Office of the Vice President for Research.

ROC: Request for Outside Consulting

Description: University faculty and P&A employees with a full time appointment (75 percent or greater) must obtain prior approval to engage in outside consulting and other commitments if the employee has a total number of 12 or more days of outside consulting (for faculty and P&A staff on an ‘A’ term appointment. Prior approval can be obtained by submitting a ROC (Request for Consultant or Outside Service Agreement). If the total number of consulting days exceeds 12 during the annual term of appointment, then a ROC is required for each external activity. See the following URL for more details about filing a ROC:

Who. A ROC report is required of faculty and P&A staff before they engage in outside consulting if number of consulting days exceeds 12 for ‘A’ term employees.

How Often: ROCs must be filled before any new REPA is initiated if the total number of consulting days exceeds 12. A ROC approval form expires after 3 years.

Will I Get a Reminder? No. You will not be reminded to fill out a ROC form. However, when you file your annual or new REPA form, you are asked to provide the ROC number for each REPA activity. If you don’t have a ROC number attached to each REPA activity (if total number of consulting days exceeds 12), then your REPA hasn’t been fully disclosed.

Location of Forms. Here’s how to find the ROC form: Go to: http://egms.umn.edu/ Click: EGMS Forms > Make a Request > Scroll down to the bottom of the list in the box under Select the Type of Request: Select ROC: Request for Consultant or Outside Service Agreement > click: Make Request > the next page should give you the ROC form which you can complete online. Policy about ROC. Regents Policy on Outside Consulting and Other Commitments are located at: www1.umn.edu/regents/policies/academic/Outside_Consulting.html. This policy is administered by the Office of the Vice President for Research.

RCR: Responsible Conduct of Research

Description: The RCR is a continuing education requirement about the responsible conduct of research and scholarship at the University, with an emphasis on scientific and scholarly integrity. The RCR requirement was created by the University Senate and is administered by the Office of the Vice President for Research under their FIRST (Fostering Integrity in Research, Scholarship, and Teaching) program.

Currently, there are two levels of RCR training:

  • Core Training. RCR Core training consists of basic information. To be eligible to be a PI on any sponsored research, you must complete the RCR Core (Parts 1 and 2).
  • You only have to complete the RCR Core requirement once.
  • Continuing Education. The second RCR requirement was initiated about 3 years ago and goes beyond these basics. This RCR requirement also consists of two parts, (1) an annual review of policies and (2) an Awareness/Discussion component which must be renewed every 3 years. Registering and further information for both parts can be found at: www.research.umn.edu/first/ContEd.htm

Who. RCR training at both levels is required of all faculty and professional staff who wish to serve as a Principal Investigator on grants/contracts with internal or external funding, new faculty, graduate students or a postdoctoral fellow and the recipients of a grant or a fellowship. See the following URL that describes who must complete this requirement: www.research.umn.edu/first/EdReqs.htm

Here’s a helpful pdf chart for new investigators that tells you more about who must complete what training: www.research.umn.edu/first/EdProg.pdf

How Often. The Core RCR must be filed prior to a grant/contract award from internal or external sources and within one year of initial appointment at the University by faculty. See the following URL for requirements for Graduate Students and Postdoctoral Students: http://www.research.umn.edu/first/GradStuPostdocsEdReqs.htm Once the Core RCR training is completed, then it does not have to be repeated.

One year after completion of the RCR Core training, all faculty/professional staff/ graduate students and post doctoral students must complete the RCR Continuing Education requirements.

Will I Get a Reminder? Yes. If you are not current in the filing of your RCR requirements, you will receive an e-mail from SPA (Sponsored Programs Administration) when you submit a grant or contract proposal. The e-mail may caution you that if the grant/contract is awarded, you may not receive authorization for funding if you are not current on your RCR requirements. This is a serious warning.

Location of Forms. Here’s the URL where RCR forms are available: Core RCR Training: www.research.umn.edu/first/electroniccourses.htm

RCR Continuing Education:

  1. Annual (Information Update) reporting: www.research.umn.edu/first/contedu/
  2. Awareness/Discussion Component (required every 3 years) www.research.umn.edu/first/ContEdAwareness.htm

Policy about RCR. This policy is administered by the Office of the Vice President for Research.

Human Subjects Protection

Description. Basic training in the protection of human subjects is a federal requirement.

Who. All investigators and research personnel who, regardless of funding source, must complete this training.

How Often: This training is required only once.

Will I Get a Reminder? Yes. All new employees are required to complete Human Subjects training.

Location of Forms. Here’s the URL where Human Subjects Protection forms are available: www.research.umn.edu/first/HumanSubjects.htm Note that a paragraph is provided for you to copy at this URL when such a statement is required by a funding agency

Policy About Human Subjects Protection. This Regents Policy is located at: www1.umn.edu/regents/policies/academic/HumanSubjects.pdf. This policy is administered by the Office of the Vice President for Research.

HIPAA: Health Insurance Portability and Accountability Act Online Training

Description. HIPAA is a federal law concerning basic requirements about privacy of health information. The University’s training requirement consists of four courses:

  • Introduction to HIPAA Privacy and Security Video (video format)
  • HIPAA Security training requirements; available through the portal. Go to: www.myu.umn.edu, click on ¿my WORK LIFE tab and go to the section: U of M Privacy and Security Training to complete the following three courses: Data Security in Your Job Securing Your Computer Workstation Using University Data

Who. Every student, faculty member, researcher, and staff person who may have access to protected health information (PHI) and/or electronic protected health information (ePHI) must complete one or more online courses about privacy and data security.

How Often: Currently, HIPAA Privacy Training consists of a total of four courses.

Will I Get a Reminder? Yes. The SPH Privacy and Security Coordinator, Stefannie Anderson (stef@umn.edu), will send reminders to all new faculty, students, and staff. Individuals who have not completed HIPAA training requirements will also be contacted by Ms. Anderson.

Policy About HIPAA. Regents Policy is located at: www.fpd.finop.umn.edu/groups/ppd/documents/Policy/hippaindinfopol.cfm. This policy is administered by the Senior Vice President for Health Sciences.

Internet Password Renewal

Description. Your Internet ID (the X.500 name) and Internet password enable you to access many online tools and services at the University. As of February 2007, Internet passwords will expire after they are a year old. Information about the U of M Internet Password is found at: www.1help.umn.edu/password.html This URL also has helpful information about how to change your password and what to do if you have forgotten your password.

Who. All U of M personnel with an X.500 Internet ID, including faculty.

How Often: Annually.

Will I Get a Reminder? Yes. There is a two week notice and a three day (final) notice when your Internet password is about to expire. You can see an example of these notices at: http://1help.umn.edu/passwordnotices.html. If your password has expired, you will not be able to log onto a secure website; instead, you will be directed to a password change screen.

Location of Forms. Here’s the URL where you can change your password: www.umn.edu/dirtools?which=show&form=pw . This website also tells you when your password was last changed.

Policy About Internet Password. This requirement is part of the Regents Policy on Acceptable Use of Information Technology Resources (www.policy.umn.edu/groups/ppd/documents/policy/Acceptable_Use.cfm ) and is administered by the Office of Information Technology (www1.umn.edu/oit/mission/index.html )

How can I keep track of all these requirements?

Currently there is no single source at the University that lists all of the reporting requirements (such as these in this memo), the dates you completed them, and when the next reporting requirement for each is due. Such a website is being worked on by different administrative units in the University. In the meantime, here are sources that provide some additional information.

eResearch Central: http://eresearch.umn.edu/erc/

  1. What forms are currently available in eResearch Central? Among the forms listed are: IRB forms for specific grants/contracts and REPA forms.
  2. What are my other compliance requirements? A useful set of questions has been developed by the Office of the Vice President for Research. Based on your answers, there may be additional requirements for you. The questions can be found by going to:http://www.research.umn.edu/first/tools/ From there, click Enter.

My U Portal: www.myu.umn.edu Sign in with your X.500 unsername and password. > Click my work life (button at upper right hand corner). > Scroll down to: U of M Privacy and Security Training. This may give some of the reporting requirements and whether you have completed them.

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