Compliance

All employees at Duke share responsibility for financial compliance. This includes reporting instances of financial non-compliance in accordance with applicable Federal regulations and Duke University policies and procedures. Refer to GAP 200.080 through 200.420 for financial compliance procedures.

Financial non-compliance can include fraudulent or non-fraudulent behavior.

There are many ways to address non-fraudulent compliance issues, such as questions or disputes resulting from differences in interpretation of regulations and/or procedures. Examples include questions regarding use of general ledger accounts, maintaining adequate documentation, allowable and unallowable costs, etc.

For non-fraudulent financial compliance questions/issues, employees may use resources such as sponsor regulations, University policies and procedures and/or contacting the network of informed individuals such as the Principal Investigator, Departmental Administrator or Grant Manager, Business Manager, Chair or Dean. An individual will need to use their own discretion depending on the role, the issue and the relationship with members of the department. If your questions/issues remain unresolved or if it seems inappropriate to contact the people listed above, you may contact the Office Sponsored Programs.

Fraud includes, but is not limited to, inappropriate activities or behavior resulting in personal gain. Some examples include; charging Duke or Duke Sponsored Projects for personal meals or mailing of personal packages, using improper description of expense and associated general ledger accounts to disguise the actual nature of the expense, preparing erroneous time cards, etc.

Instances of possible fraud must be reported to Internal Audit regardless of the financial value involved. If it is feasible or appropriate, the  Office Sponsored Programs, Principal Investigator (PI), Financial Administrator, Business Manager, Chair and/or Dean may also be notified.

The ultimate formal financial accountability for sponsored projects rests with Duke University and is delegated to the Principal Investigator (PI). A Financial Administrator will share accountability with the PI and will be responsible for first line financial administration of sponsored projects. The term Financial Administrator encompasses Department or Research Administrators, Business Managers and Financial Designees. Departments overseeing the sponsored projects are responsible to ensure that sponsored projects have the appropriate administrative/financial support, employees are appropriately trained and provide communication pathways to address compliance concerns. Financial Administrators are accountable both to the PI for facilitating the orderly conduct of research and the appropriate academic and financial administrators for ensuring fiduciary compliance.