Office of Sponsored Projects Policies

compliance transparency and policies

Applicable External?Policies

The?Office of Management and Budget, Grants Management?(OMB), working cooperatively with Federal agencies and non-Federal parties, establishes government-wide grants management policy and guidelines through the code of Federal Regulations (CFR). The policy is adopted by each grant making agency and inserted into their Federal regulations.

Smithsonian, as a non-profit organization, follows the Uniform Guidance 2 CFR 200.

Indirect?Costs Policies and Rates

NASA is the cognizant agency for SI government indirect cost rates.? Two indirect cost rates, the Grants and Contracts Overhead Rate and the General and Administrative Rate are used for all SI-Washington based government grants and contracts.

A unit-specific, indirect cost rate has been authorized for the Smithsonian Environmental Research Center (SERC).?

Government indirect cost rate characteristics and application procedures are found in Smithsonian Directives 304 and 318.

For inquiries regarding the government rates, please contact the Office of Sponsored Projects (OSP) at 202-633-7110.

The Smithsonian Institutions's Negotiation Agreement with NASA?(PDF) is available for download.

Compliance?Policies

Responsible Conduct of Research

Federal and Smithsonian Institution policy, SD 607, requires training in the Responsible Conduct of Research for all students, interns, post-doctoral fellows supported by awards from the National Science Foundation (NSF), National Institutes of Health (NIH) or Public Health Service (PHS). The RCR topic areas include: Research Misconduct, Data Management, Conflict of Interest, Collaborative Science, Responsible Authorship, Mentoring, Peer Review, Lab Animals, Human Subjects.

Financial Conflict of Interest

Federal and?Smithsonian Institution policy, SD 608, requires disclosure of significant financial interests by individuals responsible for the design, conduct or reporting of research funded by the National Science Foundation (NSF), National Institutes of Health (NIH), or Public Health Service (PHS.) Institutions are required to provide a?Public Report?on the existence and management of any financial conflicts of interest, in accordance with 42 CFR Part 50 and 45 CFR Part 94.

Enforcement and Sanctions

SI employees can be subject to the disciplinary process of the Institution if they fail to fully and truthfully disclose FCOI situations, or fail to comply with any stipulated plan for managing the disclosed conflict.

References

Misconduct in Research

Federal and Smithsonian Institution policy, SD 604, defines Misconduct in Research as: fabrication, falsification, or plagiarism in proposing, performing, or reviewing research or in reporting research results.

Contact Smithsonian¡¯s Research Compliance Officer (ResearchCompliance@si.edu) for guidance on these topics.?

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