SageFox specializes in both formative and summative program evaluation and research on educational projects. We can both help with the development of a grant proposal or come in as partners on an existing project. In both circumstances, we would work with you to develop a research or evaluation plan that is tailored to your project. This would include:

• Co-development of a logic model to deeply understand the approach the project will take to realize its objectives and goals

• Development or adaptation of instruments to measure the project objectives

• Implementation of these tools, including surveys, tests, focus groups, interviews, classroom observations, etc.

• Regular reporting of outcomes to your team and providing suggestions for increasing the effectiveness of the project

• Helping your team think through the consequences of the evaluation or research

• Supporting the reporting to the funding agency

• Helping disseminate the results of your project

Our focus is on providing information that will help improve the project as it moves forward and makes important decisions about future growth. As such, we involve all major stakeholders in the information-gathering process and collaborate with project leadership to make sense of their feedback.

Summative evaluation is meant to provide an overview of whether and how your project has met its stated goals. Our focus is not only on providing information that tells you how well you have met the objectives of the project but also on trying to understand why you may not have met certain goals. As such, we prefer to collaborate with your team not only in gathering the summative data but also in interpreting what it means in the context of your project. SageFox’s collaborative approach and on-going communication means there are no surprises in summative reporting.

We believe research should furthers the state of knowledge in the fields of education and evaluation while being of use to educational practitioners in developing and implementing projects. As such, we focus not only on the best way to answer a research question but also on how it may inform future projects in the field. We have performed research both as principal investigators on dedicated research grants and also closely collaborate in dissemination efforts following program evaluations.

Although we can work with an existing project, we can be more valuable to you if we can be part of the team developing the initial grant proposal. We suggest that you contact us early enough that we can use our experience with other projects to help you frame your grant and ensure that the evaluation or research component is integrated well into the rest of the proposal.

Once a grant is funded, our preferred relationship with our clients is one where we work very collaboratively and where the communication level is high enough that we can respond well to the project‘s changing needs.

Typically, an evaluator should cost about 10% of the overall project budget, depending on the nature of the work. For educational research, this proportion may be higher depending on what proportion of the project is based on research.

INTRODUCTION

This policy governing financial conflict of interest applies to all Investigators employed by SageFox Consulting. In the event a financial conflict of interest is discovered, all relevant activities may be suspended until the financial conflict of interest is resolved or other action deemed appropriate is implemented. Violation of any part of these policies may also constitute cause for disciplinary or other administrative action pursuant to Institutional policy.

DEFINITIONS

Conflict of Interest Administrator means the individual at SageFox who advises on conflict of interest matters.

Family means any member of the Investigator’s immediate family, specifically, any dependent children and spouse.

Financial Interest means anything of monetary value received or held by an Investigator or an Investigator’s Family, whether or not the value is readily ascertainable, including, but not limited to: salary or other payments for services (e.g., consulting fees, honoraria, or paid authorships for other than scholarly works); any equity interests (e.g., stocks, stock options, or other ownership interests); and intellectual property rights and interests (e.g., patents, trademarks, service marks, and copyrights), upon receipt of royalties or other income related to such intellectual property rights and interests.

Financial Interest does NOT include:

salary, royalties, or other remuneration from the Institution;

income from the authorship of academic or scholarly works;

income from seminars, lectures, or teaching engagements sponsored by or from advisory committees or review panels for U.S. Federal, state or local governmental agencies; U.S. institutions of higher education; U.S. research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers; or

equity interests or income from investment vehicles, such as mutual funds and retirement accounts, so long as the Investigator does not directly control the investment decisions made in these vehicles.

For Investigators, Financial Interest also includes any reimbursed or sponsored travel undertaken by the Investigator and related to his/her institutional responsibilities. This includes travel that is paid on behalf of the Investigator rather than reimbursed, even if the exact monetary value is not readily available. It excludes travel reimbursed or sponsored by U.S. Federal, state or local governmental agencies, U.S. institutions of higher education, research institutes affiliated with institutions of higher education, academic teaching hospitals, and medical centers.

Significant Financial Interest means a Financial Interest that reasonably appears to be related to the Investigator’s Institutional Responsibilities, and:

if with a publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure, and the value of any equity interest during the 12 month period preceding or as of the date of disclosure, exceeds $5,000; or if with a non-publicly traded entity, the aggregate value of any salary or other payments for services received during the 12 month period preceding the disclosure exceeds $5,000; or if with a non-publicly-traded company, is an equity interest of any value during the 12 month period preceding or as of the date of disclosure; or

is income related to intellectual property rights and interests not reimbursed through the Institution.

Financial Conflict of Interest means a Significant Financial Interest (or, where the Institutional official requires disclosure of other Financial Interests, a Financial Interest) that the Institution reasonably determines could directly and significantly affect the design, conduct or reporting of Institutional research.

Conflict of Interest Administrator means the individual within the Institution that is responsible for the solicitation and review of disclosures of significant financial interests including those of the Investigator’s Family related to the Investigator’s institutional responsibilities.

Institutional responsibilities means the Investigator’s responsibilities associated with his or her Institutional appointment or position, such as research, teaching, clinical activities, administration, and institutional, internal and external professional committee service.

Investigator means any individual who is responsible for the design, conduct, or reporting of PHS sponsored research, or proposals for such funding. This definition is not limited to those titled or budgeted as principal investigator or co-investigator on a particular proposal, and may include postdoctoral associates, senior scientists, or graduate students. The definition may also include collaborators or consultants as appropriate.

Public Health Service or PHS means the Public Health Service of the U.S. Department of Health and Human Services, and any components of the PHS to which the authority of the PHS may be delegated. The components of the PHS include, but are not limited to, the Administration for Children and Families, Administration on Aging, Agency for Healthcare Research and Quality, Agency for Toxic Substances and Disease Registry, Centers for Disease Control and Prevention, Federal Occupational Health, Food and Drug Administration, Health Resources and Services Administration, Indian Health Service, National Institutes of Health, and Substance Abuse and Mental Health Services Administration.

Research means a systematic investigation, study, or experiment designed to contribute to generalizable knowledge relating broadly to public health, including behavioral and social-sciences research. The term encompasses basic and applied research (e.g., a published article, book or book chapter) and product development (e.g., a diagnostic test or drug).

CONFLICT OF INTEREST

This policy is predicated on the expectation that Investigators should conduct their affairs so as to avoid or minimize conflicts of interest, and must respond appropriately when conflicts of interest arise. To that end, this policy informs faculty about situations that generate conflicts of interest related to research, provides mechanisms for Investigators and the Institution to manage those conflicts of interest that arise, and describes situations that are prohibited. Every Investigator has an obligation to become familiar with, and abide by, the provisions of this policy. If a situation raising questions of conflict of interest arises, an Investigator should discuss the situation with the Institutional official.

DISCLOSURE OF FINANCIAL INTERESTS

All Investigators are required to disclose their outside financial interests to the Institution on an annual and on an ad hoc basis, as described below. The Conflict of Interest Administrator is responsible for the distribution, receipt, processing, review and retention of disclosure forms Regardless of the disclosure requirements, the Investigator, in his or her own best interest, is encouraged to disclose any other financial or related interest that could present an actual conflict of interest or be perceived to present a conflict of interest.

Annual Disclosures

All Investigators must disclose their Significant Financial Interests to the Institution, through the Institutional Official, on an annual basis. All forms should be submitted to the Institutional official or designee by July 1 for the previous calendar year or as determined by the sub-recipient.

Ad hoc Disclosures

In addition to annual disclosure, certain situations require ad hoc disclosure. All Investigators must disclose their Significant Financial Interests to the Institution, through the Institutional Official, within 30 days of their initial appointment or employment.

Prior to entering into sponsored projects or applications for sponsored projects, where the Investigator has a Significant Financial Interest, the Investigator must submit to the Conflict of Interest Administrator an ad hoc updated disclosure of his or her Significant Financial Interests with the outside entity. The Institution will not submit a research proposal unless the Investigator(s) have submitted such ad hoc disclosures.

In addition, all Investigators must submit to the Institutional official an ad hoc disclosure of any Significant Financial Interest they acquire during the course of the year within thirty (30) days of discovering or acquiring the Significant Financial Interest.

Travel Investigators must also disclose reimbursed or sponsored travel related to their institutional responsibilities, as defined above in the definition of Financial Interest. Such disclosures must include, at a minimum, the purpose of the trip, the identity of the sponsor/organizer, the destination, the duration, and, if known, the monetary value. The Institutional Official will determine if additional information is needed (e.g., the monetary value if not already disclosed) to determine whether the travel constitutes a Financial Conflict of Interest with the Investigator’s research.

REVIEW AND DECISION OF THE INSTITUTIONAL OFFICIAL

If the disclosure form reveals a Significant Financial Interest, it will be reviewed promptly by the Institutional Official or designee for a determination of whether it constitutes a Financial Conflict of Interest. If a Financial Conflict of Interest exists, the Conflict of Interest Administrator will take action to eliminate, reduce, or manage the conflict, as appropriate.

A Financial Conflict of Interest will exist when the Conflict of Interest Administrator or designee determines that a Significant Financial Interest could directly and significantly affect the design, conduct, or reporting of PHS-supported research. If the Conflict of Interest Administrator determines that there is a Financial Conflict of Interest that can be managed, he or she must require and approve a written management plan before any related research goes forward. The affected Investigator or the COI Committee is responsible for developing and submitting a proposed management plan, in consultation with the Conflict of Interest Administrator.

To address complex situations, oversight committees may be established by the Conflict of Interest Administrator to periodically review the ongoing activity, to monitor the conduct of the activity (including use of students and postdoctoral appointees), to ensure open and timely dissemination of the research results, and to otherwise oversee compliance with the management plan.

REPORTING TO PHS

Should any reported conflict or non-compliance require reporting to PHS, the Conflict of Interest Administrator will report in accordance with PHS regulations. If the funding for the Research is made available from a prime PHS-awardee, such reporting shall be made available to the prime awardee such that they may fulfill their reporting obligations to the PHS.

INVESTIGATOR NON-COMPLIANCE

Disciplinary Action

In the event of an Investigator’s failure to comply with this Policy, the Conflict of Interest Administrator may suspend all relevant activities or take other disciplinary action until the matter is resolved or other action deemed appropriate by the Conflict of Interest Administrator is implemented.

A Conflict of Interest Administrator’s decision to impose sanctions on an Investigator because of failure to comply with this Policy, or failure to comply with the decision of the Conflict of Interest Administrator, will be described in a written explanation of the decision to the investigator, COI Committee, and, where applicable, the IRB, and will notify the individual of the right to appeal the decision.

Retrospective Review

In addition, if the Conflict of Interest Administrator determines that a Financial Conflict of Interest was not identified or managed in a timely manner, including but not limited to an Investigator’s failure to disclose a Significant Financial Interest that is determined to be a Financial Conflict of Interest, or failure by an Investigator to materially comply with a management plan for a Financial Conflict of Interest.

Documentation of the retrospective review shall include the project number, project title, PI, name of Investigator with the Financial Conflict of Interest, name of the entity with which the Investigator has the Financial Conflict of Interest, reason(s) for the retrospective review, detailed methodology used for the retrospective review, and findings and conclusions of the review.

The Institutional official will update any previously submitted report to the PHS or the prime PHS-awardee relating to the research, specifying the actions that will be taken to manage the Financial Conflict of Interest going forward. If bias is found, the report will include a mitigation report in accordance with the PHS regulations, including a description of the impact of the bias on the research project and the plan of action to eliminate or mitigate the effect of the bias.

TRAINING

Each Investigator must complete training on this Policy prior to engaging in research funded by PHS, and at least every four years thereafter. They must also complete training within a reasonable period of time as determined by the Conflict of Interest Administrator in the event that this Policy is substantively amended in a manner that affects the requirements of Investigators, or if it is determined that the Investigator has not complied with this policy or with a management plan related to their activities.

RECORD RETENTION

The Conflict of Interest Administrator will retain all disclosure forms, conflict management plans, and related documents for a period of three years from the date the final expenditure report is submitted to the PHS or to the prime PHS awardee.

CONFIDENTIALITY

To the extent permitted by law, all disclosure forms, conflict management plans, and related information will be confidential. However, the Institution may make such information available to an agency funding research of the faculty member, to a requestor of information concerning financial conflict of interest related to PHS funding or to the primary entity who made the funding available to the Institution, if requested or required. If the Institution is requested to provide disclosure forms, conflict management plans, and related information to an outside entity, the Investigator will be informed of this disclosure.

PUBLIC ACCESSIBILITY

Prior to the expenditure of funds, the Institution will publish on a publicly-accessible website or respond to any requestor within five business days of the request, information concerning any Significant Financial Interest that meets the following criteria:

The Significant Financial Interest was disclosed and is still held by the Investigator;

A determination has been made that the Significant Financial Interest is related to the PHS-funded research; and A determination has been made that the Significant Financial Interest is a Financial Conflict of Interest.

The information to be made available shall be consistent with the requirements of the PHS policy.

REGULATORY AUTHORITY

This policy implements the requirements of 42 CFR 50 and 45 CFR 94; where there are substantive differences between this policy and the requirements, the requirements shall take precedence.