Fiscal & Grants Management Policies

Grants Management Policy

GIFTS and GRATUITIES
In order to avoid a conflict of interest or the appearance of a conflict of interest, at no time should an employee solicit or accept gifts from a vendor or contractor or from a potential vendor or contractor except as described below.

Unsolicited personal gifts valued at $25.00 or more cannot be accepted by employees, and should be returned immediately to the donor. If the value of the gift is undetermined it should be returned. Ordinary business courtesies, such as payment for a modest lunch or dinner, are acceptable provided it does not exceed the value listed above. Gifts which are promotional items without significant value, and which are distributed routinely by the vendor to clients, are also acceptable.

Gratuities or gifts of money to the employee cannot be accepted at any time and should be returned immediately to the donor. Employees who have questions regarding this policy should confer, in writing, with their supervisor (or AIHEC’s Finance & Administration Director) to determine an appropriate course of action.

All employees are subject to this policy and are expected to comply fully. Instances of deliberate breach of policy, or failure to comply with the policy, will be reported to AIHEC’s President and CEO for appropriate action.

HUMAN RESEARCH PARTICIPANTS
Sponsored research involving human subjects, which may include people who are being interviewed and/or electronically recorded, has strict guidelines intended to protect these individuals. Personnel involved in such research need to be informed on how to ensure proper protection of their rights. Proposals that include human research participants must be approved by an Institutional Review Board (IRB) prior to being submitted. A copy of the IRB Guidebook developed by the Department of Health and Human Services (DHHS) is available on-line. Access the full Code of Federal Regulations text defining Protection of Human Subjects regulations as specified by DHHS.

Many federal agencies involved in sponsoring research involving human subjects, have adopted the same set of regulations, referred to as the "Common Rule." The National Science Foundation (NSF) Web site has a page on Human Subjects that is both easy to use and understand and a FAQ's page to help people interpret these regulations.

Grant applications made to the National Institute of Health must provide assurance that all key personnel have been educated in how to ensure proper protection of human subjects. An online course designed to help individuals attain and verify this education can be accessed through the National Institute of Health Web site.

OMB CIRCULARS
The Office of Management and Budget (OMB) has declared that all tribal colleges, "...regardless of whether they are part of an Indian Tribal government..." must follow circular A-21, in addition to A-110 and A-133. There is a similar circular, A-87, entitled "Cost Principles for State, Local and Indian Tribal Governments" that does not apply to tribal colleges and universities.