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Why is Keeping the Appropriate Documentation Important?

Because your inventory could be audited, you should retain documents and notes that would help you recall the items being reported. Sufficient documentation to support the coding of your space, especially for space coded to Organized Research (OR), must be maintained. Documentation is important to support coding decisions in the event of audit by Internal Audit, CMA, external auditors, the Department of Health and Human Services, and other sponsoring agencies.

Example 1

A research lab used 100% for Dr. Smith’s NIH-funded research. The sole occupant of the lab is a Research Assistant (RA) who receives part of his salary from the NIH-funded grant and the remainder from a fellowship. Per discussions with Dr. Smith and the RA, it is determined that while in the lab the RA’s activities were all in support of the sponsored project, thus is 100% Organized Research. Therefore, in this case, the occupant’s salary funding is not an accurate reflection of this room’s activity, and the functional coding of this room should be 100% OR.

Example 2 - Looking at the activities in the room:

A laboratory room is used for a sponsored research project. Is the room 100% OR? No. Why? The Principal Investigator (PI), a technician, and two graduate RAs occupy the room. The PI also teaches, but the PI’s presence in the lab is to perform the research, not to grade papers, which the PI commonly does in his or her office. The RAs and technician are present to perform research for the PI. So far, so good… However, any non-research activity, if it occurs, should also be reported by function in the room coding. For example, the RAs use the lab for their classroom-related teaching activities because they were not assigned a carrel or other office space in the department. Thus a portion of the room would have to be coded to Instruction, even though the funding of the room is all through the sponsored project. As with all functional reporting, this use of space should occur with some regularity rather than sporadically in order to estimate a percentage of use.