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Policy No.: 8009
Effective Date: 11/01/06
Revised Date: 10/30/18
- 1 Basis for Policy
- 2 Policy
- 3 Data Security/Protected Health Information
- 4 Protected Student Financial Information (PSFI)
- 5 Business Associate Agreement
- 6 Additional Information
Basis for Policy
The purpose of this policy is to provide guidance on who is authorized to sign contracts on behalf of the University of Nebraska Medical Center; and to make clear that individuals must have specific authority, as delegated in Board of Regents Policy (RP – 6.3.1), in Executive Memorandum No. 13 and Executive Memorandum No. 14, and as specifically provided for in the UNMC Contract Signature Authority Tables to sign such contracts.
Written Agreements Required
All organizations and individuals that provide products and services to the University of Nebraska Medical Center (UNMC) shall enter into a written contract with UNMC. Pursuant to University of Nebraska Executive Memorandum No. 14, the President has delegated authority to each Chancellor to approve specific types of contracts described in Section 4 of RP -6.3.1. Pursuant to University of Nebraska Executive Memorandum No. 13 and Executive Memorandum No. 14, the Chancellor may delegate contract signature authority. Individuals with the authority to sign contracts on behalf of UNMC are listed in the UNMC Executive Memorandum 13 Contract Signature Authority and UNMC Executive Memorandum 14 Contract Signature Authority Tables. No individual shall sign a contract on behalf of the University of Nebraska Medical Center unless having specifically been delegated the authority to do so.
Executive Memorandum No. 14
|RESEARCH CONTRACTS, meaning federal awards, research grants and contracts and externally funded research related projects||Sponsored Programs Administration, 402-559-7456, https://www.unmc.edu/spa/about/contact.html|
|PURCHASES OF GOODS AND SERVICES||Procurement, firstname.lastname@example.org, https://info.unmc.edu/procurement/procurement/contracts/index.html|
|LICENSED TECHNOLOGY||UNeMed, 402-559-3274, https://www.unemed.com/contact-us/staff-directory|
|BUSINESS FUNCTIONS|| Business and Finance
When UNMC is expending funds: 402-559-5400, email@example.com, https://info.unmc.edu/procurement/procurement/contracts/index.html
|ACADEMIC AGREEMENTS||Academic Affairs, 402-559-5130, https://www.unmc.edu/academicaffairs/compliance/affiliation-agreements.html, https://www.unmc.edu/academicaffairs/, https://www.unmc.edu/academicaffairs/about/index.html|
|All Others||See Contract Signature Authority Tables: Executive Memorandum 13 Contract Signature Authority by position,|
Direct any questions related to the Contract Signature Authority to Sarah Gloden Carlson, Chief Compliance Officer at 402-559-9576.
Contract Types and Approvals
In compliance with Federal regulations, an individual designated as Authorized Organization Representative (AOR) is the only official authorized to sign on behalf of the institution. Signature by the AOR signifies the university agrees to comply with regulations and laws. Sponsored Programs Administration is the authorized signature official of UNMC for sponsored programs grants and contracts.
Purchases of Goods and Services
Procurement is responsible for contracts where university funds are spent. The Board of Regents Policies and Bylaws provide thresholds that trigger bidding requirements, signature authority and other. Contracts for goods and services utilizing state funding must be reported through a state database under LB 429 (Legislative Bill). Procurement ensures that information security requirements are met for all purchases.
UNeMed focuses on promoting the advancement and commercialization of UNMC technologies. UNeMed signs agreements such as MTAs, CDAs, and Licensing Agreements where rights to UNMC intellectual property are utilized.
Agreements involving University stewardship and management of resources are signed by Business and Finance.
Academic Affiliation Agreements are required for all organizations accepting UNMC students and for all students who come to UNMC from other educational institutions for clinical experience (Office of Health Professions Education). Academic Affiliation Agreements are approved by the Office of the Vice Chancellor for Academic Affairs. Contact your college representative responsible for drafting and negotiating Academic Affiliation Agreements or Academic Affairs at 402-559-5130 with questions.
Data Security/Protected Health Information
UNMC as part of an Affiliated Covered Entity is obligated to protect patient information under HIPAA. Any UNMC contract that involves the use of protected health information (PHI) for services, research and other needs to ensure that procedures and policies are followed to secure PHI.
When contracting outside UNMC and Nebraska Medicine for equipment purchases or transfer of PHI electronically, a security review is required by Information Security.
Protected Student Financial Information (PSFI)
Executive Memorandum No. 26 describes protections of Student Financial Information required under Gramm Leach Bliley Act (GLBA), and protection of credit card information received in the course of business. When an activity requires use of protected financial information under Executive Memorandum No. 26, a GLBA Addendum must be added to the contract (the Addendum is attached as an exhibit to Memorandum 26).
Business Associate Agreement
A Business Associate Agreement is required in association with the contract for equipment, services or other where a person or entity is performing functions or activities on behalf of a covered entity (UNMC, Nebraska Medicine, College of Dentistry, etc.) or a subcontractor that creates, receives, maintains or transmits PHI on behalf of the covered entity. The Business Associate Agreement template can be located at https://www.unmc.edu/hipaa/forms/index.html. Refer to the Business Associate Decision Tree as needed.
- Chief Compliance Officer
- Assistant Vice Chancellor for Business and Finance
- Business Associate Agreements and Addendums Procedures
- Business Associate Agreement template
- Academic Affiliation Agreements
- Section 6.4 of the Bylaws of the Board of Regents of the University of Nebraska Board of Regents Policy on Administrative Approval of University Contracts (RP – 6.3.1)
- University of Nebraska Executive Memorandum 13, Delegation of Administrative Authority to Approve Academic-Administrative Personnel Actions
- University of Nebraska Executive Memorandum 14, Delegation of Administrative Authority to Approve Certain Types of University Contracts, and Requirements for Submittal and Execution of Contracts Requiring Approval by the Board of Regents
- University of Nebraska Executive Memorandum No. 26, Information Security Plan
- University of Nebraska Executive Memorandum No. 27, HIPAA Compliance Plan
- Health Insurance Portability and Accountability Act of 1996 (HIPAA) [45 CFR §164.502(e)(1)]
- Gramm-Leach-Bliley Act(GLBA) 12 CFR §225.28]
- Contract Signature Authority Tables
- IRS Publication 15-A
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