Support for researchers in a changing landscape

Thousands of faculty, staff, and postdoctoral scholars must regularly disclose their outside professional activities to satisfy federal regulations and Stanford policies. This summer, the Office of the Vice Provost and Dean of Research (VPDoR) launched a Research Compliance Project in response to faculty feedback, with initiatives spanning five key areas – processes, strategy, systems, training, and culture.

The Research Compliance Project follows a university-wide assessment of the policies, procedures, and systems that researchers rely on. The assessment brought together leadership from schools, departments, and many research support offices across campus. It also included numerous interviews and a faculty survey to gather feedback and improvement ideas.

The initiatives also build on enhancements made over the last five years to strengthen Stanford policies and help faculty comply with the changing regulatory requirements while continuing to foster a culture of academic freedom in research and scholarship. Under the leadership of Kathryn “Kam” Moler, vice provost and dean of research, these enhancements have helped strengthen systems and processes at the central level and across schools.

“Our researchers collaborate across disciplines, institutions, and international borders,” said Moler. “The Research Compliance Project initiatives will make it easier for researchers to make appropriate disclosures and comply with other rules so that they can maintain those collaborations and develop cutting-edge ideas that can benefit scholarship and the experience of our students.”

Ten working groups will shepherd the initiatives, along with a steering group led by senior associate deans from four schools. The project aims to make it easier for faculty and other researchers to understand and meet compliance obligations and enhance staff capacity and knowledge in schools and administrative units. In the coming years, the initiatives will:

• Streamline processes across the sponsored research lifecycle to ensure university-wide offices and schools can help researchers adapt to new regulatory requirements and provide better support in the areas of disclosures at the time of grant submission, export control rules, research security, and conflict of interest/commitment procedures.

• Improve systems to update the university’s Outside Professional Activities Certification System (OPACS), making it more user-friendly and better integrated with other Stanford IT systems.

• Align university-wide strategy with a coordinated research risk management approach that clarifies how roles and responsibilities are shared between the VPDoR and schools.

• Enhance training to ensure current and new staff are up-to-date and positioned to support researcher disclosures.

• Strengthen a culture of transparency and communications to foster greater clarity of compliance-related policies and practices among faculty, staff, and researchers.

Five years of growth and progress in research compliance

The Research Compliance Project builds upon ongoing efforts by the VPDoR over the past five years to strengthen and bring greater clarity to processes for the academic community. These efforts have included a suite of new programs, services, and training opportunities, such as the following:

• Facilitated international agreements across borders: In 2019, the VPDoR created the Global Engagement Review Program (GERP) to advise faculty and the administration on foreign influence risks associated with certain types of engagements, gifts, affiliations, and visitors. GERP, a program that faculty may elect to use, has implemented a tiered review process to guide and advise faculty by evaluating risk and leveraging university resources to manage an appropriate resolution.

• Expanded guidance for human subject research: To strengthen the university’s accountability in relation to research involving human subjects, the VPDoR and Office of General Counsel added internal and external independent experts to the university’s Institutional Conflict of Interest Committee.

• Established data governance and management support for pre- and post-award: In 2021, the VPDoR hired a Research Data Governance and Privacy officer to assist researchers in navigating issues of privacy, openness in research, and data management. The role has been instrumental in helping faculty respond to various new data-related rules, including the new data-sharing requirements from the National Institutes of Health (NIH). In addition, a dedicated Data Use Agreement team was established in the Office of Research Administration in 2021 in an attempt to improve the efficiency with which these agreements are negotiated and executed.

• Leveraged technology to improve export control processes: The VPDoR invested in new technology to support export control practices, allowing teams to streamline the identification of parties the federal government classifies as “restricted.” The updated processes ensure more robust compliance while reducing the burden on researchers and administrators.

• Updated guidance, tools, and training in response to new federal requirements: To boost understanding of and compliance with growing lists of federal requirements, the VPDoR has continually updated guidance by introducing new templates for faculty use with disclosures, conducted education and awareness outreach sessions and this year introduced a new COI/COC training course for researchers.

To achieve these changes over the past five years, the VPDoR leadership team collaborated broadly to gain consensus on strategies, explore iterative solutions, and, most importantly, gain faculty and other researcher buy-in. As Moler’s tenure ends, the success of this approach has set up the community for success and continual improvement.

“Over the past five years, our goal has been to ensure that faculty are aware of their responsibilities and to make it as easy as possible for them to meet those responsibilities when they work beyond campus,” said Moler. “In collaboration with our partners across campus, we try to have clear policies, smart practices, and accessible training programs for our faculty and staff.”

Continuing commitment to promote openness, engagement, and collaboration

Stanford’s history of innovation and discovery is rooted in upholding the values of openness, international engagement, and collaboration with external partners. Many Stanford research policies are designed to protect these values.

Over the past decade, the federal government has increased its focus on issues related to improper foreign influence over research, conflicts of interest, and theft of technology and intellectual property. The result has been more robust guidelines and the introduction of new rules. For example, in early 2021, an important White House security memorandum directed all federal agencies to redouble their efforts to boost research security. Key funding agencies, including the National Institutes of Health and the National Science Foundation, responded with new regulations.

Moler will pass the baton to the incoming vice provost and dean of research this fall to continue steering the balance between meeting Stanford’s obligations and making compliance as smooth as possible.

“Overhauling our conflict of interest and conflict of commitment policies last Spring was a critical step,” said incoming Vice Provost and Dean of Research David Studdert. “There was a good deal of faculty, staff, and student involvement in that process, as there should be because this is more nuanced than just adopting new rules dictated to us by the government. Many of the requirements reflect or intersect with our longstanding policies and principles, some of which were developed by the Faculty Senate many decades ago.”

In the coming years, maintaining the highest degree of integrity and compliance while striving to keep the rules and processes transparent and easy to follow and increasing support for faculty research will remain major priorities.

“Fostering a state-of-the-art compliance culture is not about simply placing more requirements on busy researchers,” said Studdert. “It’s about presenting a clear path for someone to fulfill their obligations and explaining why it matters.”