Policy:       

The purpose of this policy is to establish guidelines regarding incentive payments that may be paid by industry research sponsors directly to Creighton University employees. (See Creighton University Policy #2.2.8, Extra Salary Payments for Exempt Employees, see attached)

Background

Occasionally, an industry research sponsor may desire to encourage Creighton University research personnel to increase their level of support for the research sponsor's program. Creighton University and the Department of Medicine encourage active participation in industry sponsored research projects. However, payment made directly to employees of the university may adversely impact the University's ability to ensure fair and equitable compensation among all employees.

Procedures:

1.      All Creighton Department of Medicine employees are required to disclose to the Principal Investigator and/or the Department Administrator any special compensation arrangements offered by an industry research sponsor including case awards, prizes in the form of merchandise, sponsored travel, except as required for conduct of studies or contracts, and any other form of incentive. This policy does not apply to official travel to attend official investigator meetings to discuss research initiatives.

2.      The Department Administrator and/or the principal investigator should ensure that all correspondence and information regarding incentive arrangements are forwarded to Grants Administration for their review in determination of appropriateness with existing University guidelines.

3.      All income and prizes become the property of Creighton University and shall be considered as income related to grant funded research projects. Any funds received will be deposited to the restricted research fund account and recorded as revenue from the study sponsor.

4.      The principal investigator mar request that research study employees be provided additional compensation as a special payment for their services. The principal investigator may request the special payment utilizing an HR58 and must state the specific amount and include a written justification to support the request. This request will be reviewed by the department, school and university subject to normal personnel policies and procedures.

5.      Any prizes in the form of merchandise or travel will be also disclosed by the principal investigator to Grants Administration through the Department of Medicine Administration. Prizes awarded will become the property of Creighton University and placed under the control of the principal investigator.

6.      Any compensation in the form of cash payments, merchandise or travel may be subject to IRS reporting requirements.