9.16 / Depository for Representations and Certifications
The purpose of this policy is to establish a Responsible Party for each
Representation and Certification requirement, an index of Representations
and Certifications to monitor renewals and facilitate audits, a
list of Compliance Areas and compliance responsibilities as they relate to
and Certifications, and a central depository of all
This policy is applicable to any University employee who is asked to
certify, assure or make a written or legally binding representation as to
whether or not the University is in compliance with any federal, state or
local law, regulation, or order.
For purposes of
this policy only, the following definitions shall apply:
and Certifications” means a certification, assurance, verification, written
representation, or any other attestation that is deemed a binding statement
made on behalf of the University. Representations
and Certifications may include such language as “I certify to,” or “I
attest, under perjury of law,” or “By my signature, I verify that.”
Representations and Certifications may be requested to be completed
in writing, by electronic communication, through online portals or any other
means of recording.
B. "Responsible Party” means a University employee authorized
to certify that the University is in compliance with laws affecting the
employee’s designated Compliance Area.
"Compliance Area” means a designated subunit within the University, or an
affiliated entity. A Compliance Area
may include one or more individuals, departments, divisions, institutes,
centers, groups, and/or organizations based primarily on their
responsibilities and expertise.
Areas and Responsibilities
Research Compliance Office (RCO) is responsible for maintaining a list of
Compliance Areas and all responsible compliance obligations as set forth in
applicable laws, regulations, grants, contracts, policies or other mandates.
This list shall also identify the designated Responsible Party for the
applicable Compliance Area or compliance responsibility. The identity of the
Designated Responsible Party is provided to Research Compliance by the head
of each compliance area.
before January 1 of each year, the Responsible Party, or designee(s), must
certify in writing that the University is in compliance with the
designated compliance obligations for that Compliance Area.
Requests for Representations and Certifications
and Certifications must be forwarded to the Research Compliance Office
and, if applicable, to the reviewing contract department.
RCO or its designee shall work with the Office of the General
Counsel to accurately complete all Representations
and Certifications and complete any other tasks of the RCO.
Completed Representations and
Certifications shall be submitted to RCO at firstname.lastname@example.org for indexing into the depository.
The Office of the General Counsel shall serve as the custodian of
records for all completed Representations and Certifications. Completed Representations and Certifications
shall be kept a minimum of five years following the execution date.
August 8, 2017