Important Announcements

Nondiscrimination Policy Update

Boston Medical Center Health System complies with applicable Federal civil rights laws and does not discriminate on the basis of age, race, color, national origin (including limited English proficiency and primary language), religion, culture, physical or mental disabilities, socioeconomic status, sex, sexual orientation and gender identity and/or expression. BMCHS provides free aids and services to people with disabilities and free language services to people whose primary language is not English.

To read our full Nondiscrimination Statement, click here.

Research Enterprise and Related Policies

Because we don't all think alike, we've "shelved" our policies under functional categories and sub-categories to help you find quickly the policy you seek.*  

When you click on your first policy below, you will be prompted to log in using your BMC email address and password.  All BMC policies are also accessible through  PolicyTech* and most of those pertaining to sponsored programs (SPs) are categorized under "Research (39),"  accessible via the "Browse" function. 

If you cannot locate the policy you seek, please reach out for assistance.

Research Financial Conflict of Interest

Following federal regulation, BMC posts its research financial conflict of interest (RFCOI) policy publicly.  The policy follows 42 CFR 50, Subpart 5, entitled "Promoting Objectivity in Research."  

Pre-award

Pre-award Considerations

Proposal development and submission requires attention to numerous general and financial SP requirements to ensure adequate and compliant budgeting

Screening for Ineligible/Excluded Personnel

Allowable Costs

Cost Sharing

Indirect Cost Rate (F&A) and Indirect Cost Standard Operating Procedure

Financial Conflicts of Interest, Research

Independent Contractor (HR)

Procurement of Supplies, Equipment, Services (Supply Chain)

Travel and Expense (HR)

Proposal Submission

Proposal Submission

Award Preparation

Pre-award and Pre-contractual Expenditures

Clinicaltrials.gov Requirements

Subawards

Subawards (when BMC is prime awardee)

Sponsored Program Awards Finance

General: Proposal Development Through Closeout

General SP finance policies apply to budgeting, other proposal submission requirements, project set-up, and post-award requirements

Allowable Costs

Indirect Cost Rate (F&A) and Indirect Cost Standard Operating Procedure

Cost Sharing

Equipment Management

Procurement of Supplies, Equipment, Services

Travel and Expense

Financial Conflicts of Interest, Research

Prior to Award Acceptance

Pre-award and Pre-contractual Expenditures

Post-award

Time and Effort Reporting

Cost Transfer

Overspending

Fund Monitoring

Program Income

Petty Cash

Financial Reporting

Closeout

Residual Balances and Discretionary Funds

Record Retention

Clinical Research Billing and Finance

Coverage Analysis

Billing and Claims Submission (General)

Clinical Research

Clinical research SPs, including industry-sponsored clinical trials, are also subject to SP finance policies.  Please see the section above

Systems Requirements

Participant Compensation (ClinCard)

Required Use of Velos-CT (Clinical Research Management System)

ClinicalTrials.Gov Requirements

Research Billing and Finance

Coverage Analysis

Billing and Claims Submission (General)

Ethics and Study Participation

Human Research Protections Program/Institutional Review Board

Ethics in Human Research

Records Management

Record Retention

Agreements

The Research Enterprise is developing a single policy to address a range of SP agreements types, which will be added here upon BMC approval

Subaward Agreements

Independent Contractor (HR)

Contract Approval (Fiscal Management)

Reporting Requirements

Time and Effort Reporting

Clinicaltrials.gov Reporting

Financial Reporting

FFATA (Federal Funding and Transparency Act) Reporting

Income Generated by a Research/Sponsored Program

Conflicts of Interest

Significant Financial Conflicts of Interest in the Conduct of Research

Conflict of Commitment

Conflicts of Interest (General)

Institutional Conflicts of Interest in the Conduct of Research

Other

Animal Research/IACUC Guidance The related policy requires BU log-in

Export Controls

Institutional Biosafety (and Biosecurity)

Record Retention

Research Core Facility/Recharge Center

Scientific Misconduct Allegations

FAQs

Why do many research policy titles refer to “Sponsored Programs” instead of “Research”?

Many but not all research policies also apply to non-research sponsor programs (SPs), eg, a clinical or other service program. SPs range widely in type, but they share with research a many compliance requirements stipulated by awarding agencies and/or federal or other laws and regulations. In other words, research projects are a subset, albeit the largest subset, of BMC SPs.

I’m may have misunderstood policy requirements related to one of my responsibilities. How can I be sure? What can I do about it?

If you have any doubt that your activities may not align with BMC policy, first congratulate yourself for catching a potential error. Everyone errs sometimes. Becoming aware of a possible misunderstanding of requirements and seeking to address evidences commitment to compliance

Please re-read the Policy Statement of the policy that you may have misapplied. If that doesn’t clear things up, contact the SP policy manager, who will meet with you to identify next steps. Ask for urgent attention if you need to engage in the activity soon.

What if I don’t fully understand the process specified to follow to adhere to the policy requirements?

The Procedure section of each RO policy provides a high-level description of the process.  If you need help interpreting it, please contact the SP policy manager. She will clarify the steps outlined in the section.

If, instead, you seek process details that the policy doesn't reference, please go to the relevant Research Enterprise team page(s). The Sponsored Programs Administration and Sponsored Programs Finance home pages provide quick links to many process descriptions, and the Clinical Trial Office home page provides a flowchart, FAQs, and a left-hand menu link for clinical research systems FAQs.  

If you do not readily find what  you need, contact the relevant team for assistance. All RO webpages include a link to contact the team(s).  The policies themselves list the responsible ROs team(s) that can identify process details.

As policy job aids become available, they will be posted on this page.

My eyes glaze over whenever I read policy. Isn’t there some alternative way to identify BMC or BMC/BUMC requirements?

You are not alone – many people are intimidated by policies and with good reason: sometimes they are not written for ready comprehension. 

In the last two years, BMC SP policies have been updated for simplicity, use of natural language, brevity, and concision. Please try them out: they may change your mind about policies.  

If, however, you would like to review the policy with the RO policy manager, please do not hesitate to reach out.

If, instead, you would like to discuss any concerns about the policy, you may want to contact the relevant RO team  All RO webpages include a link to contact the team(s) and all RO policies list the responsible team(s).

Follow these links to Sponsored Programs Administration, Sponsored Programs Finance, and Clinical Trial Office