Here at Jefferson Medical College, we have recently amended the bylaws to
incorporate compliance measures.  This includes disciplinary measures for
failure to submit required reports (including conflict of interest, effort
reports, etc) in a timely fashion.  The disciplinary measures span the
spectrum from termination of sponsored projects to suspension without pay to
termination of faculty appointment.  In conjunction with this, the
University has a disciplinary policy for non-faculty which closely mirrors
the changes in the bylaws.  These changes are incorporated into our
mandatory research education and, so far, we have not had to impose any
penalties.  I'm sure that soon, however, someone will test the system.

Lee McDaid
Asst. Compliance Officer for Research
Thomas Jefferson University
Philadelphia, PA

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