Associate Vice Provost for Research Administration and Development
Assistant Director for Research Administration and Development
For this issue of the Pulse, we wanted to learn more about processing and management of Data Use Agreements (DUAs) at other institutions. We were interested in finding out which offices review DUAs, who has the primary responsibility to sign them, as well as whether institutions monitor DUAs after they are signed. We will continue to periodically check the “pulse” of the research administration community on various topics. Look for the next column in the SRA Catalyst in the coming months.
A Data Use Agreement (DUA) establishes who is permitted to access a limited data set (stripped of certain identifiers), as well as the nature of permitted uses and disclosures by the recipient. Institutions who hold data often require a DUA for researchers to access desired data sets. For this issue of the Pulse, we were interested to find out which offices review DUAs and which office has primary responsibility, as well as whether institutions monitor DUAs after they are signed. This anonymous survey was distributed to the subscribers of the RESADM-L listserv.
The survey was open between June 27th and July 11th, 2018 and collected 69 responses. It is possible that more than one response came from some of the institutions represented by the survey participants. Below, we describe what we learned from our colleagues.
The overall response to this survey was not as robust as to our previous Pulse surveys, with the number of responses we received about half of our usual response rate. We suspect this is due to the smaller number of research administrators who interact with the DUA process versus the other processes we previously explored. Despite the smaller number, most respondents of our survey were familiar with DUAs. Specifically, over 36% work with DUAs, an additional 20% know a lot about DUAs, and 38% know some about DUAs. Only 6% (4 respondents) stated that they were unfamiliar with DUAs and do not play any role in processing DUAs. We believe that DUAs are an important and growing issue at the institutional level and suspect that these numbers will increase with time.
Of those respondents who engage with DUAs, 34% review them, 28% sign, 22% receive occasional DUAs and forward them to another office. An additional 11% perform other functions, such as negotiating DUA terms, drafting DUAs, requesting DUAs, as well as working with other offices to address issues in the purview of those other offices. Overall, sixteen survey participants (23%) reported performing more than one DUA-related function.
Review of DUAs
We learned that at 87% of respondents’ institutions, more than one office reviews DUAs. Among those offices are Research Administration (38%), Legal (23%), Technology Transfer (16%), Compliance & Oversight (14%), and Information Technology (6%). Responses “Other” included input from Principal Investigator (PI) or delegate as well as input from department, IRB for outgoing NIH databases DUAs, and comments along the lines of “it depends on the DUA and the risk associated with it.” This mix of offices interacting with DUAs is reflective of the nature of DUAs – they do not squarely fall into one area. As they involve research and are a contract, it is not surprising that among our respondents DUAs are most often sent by faculty and other constituents to research administrators.
Which office reviews DUAs (you can select more than one answer)?
Signing of DUAs
The majority of our respondents (72%) reported that DUAs are signed at the institutional level in their organizations. About 15% were not sure if their institution has a standard approach, and 3% are in the process of creating one. About 10% of survey participants answered that DUAs are not centrally signed at their institutions. Given that a DUA commits a researcher’s home institution as a whole to its stewardship, we believe that it is a best practice that they be reviewed and signed by a central office.
Does your institution have a standard approach regarding who signs DUAs?
Primary responsibility for DUAs
Among respondents’ institutions, over half (59%) place primary responsibility for DUAs at Research Administration/Sponsored Programs offices. Other offices with primary responsibility included Technology Transfer (13%), Compliance & Oversight (10%), and Legal (8%). Most of those who selected the response “Other” listed more than one office depending on the type of DUA. Two additional responses for “Other” included “Administrative” office and the response “no one knows.” As stated above, there seems to exist some uncertainty among institutions about where DUA authority should lie as evidenced by the lack of a permanent home for them. While Research Administration is a logical home, it is possible that our survey overstates the percentage of institutions giving primary responsibility to Research Administration audiences, given our source of respondents.
Monitoring DUAs after they are signed
Lastly, we asked if DUAs are monitored after they are signed. Among our respondents such monitoring takes place only in 18% of the institutions. This is not a surprise, given the relative newness of this issue with the advent of big data, the lack of strong federal funder incentive to track outcomes, and the variety of offices where this responsibility resies. However, should data providers or federal funders take a larger interest, or if the conditions of a DUA are breached, the lack of follow-through could become a pain point for institutions.
While not on every research administrator’s radar, DUAs and who receives, signs, and tracks them are becoming an increasingly hot topic. Time will tell if administration of DUAs becomes another task for research administration, or if it falls to other central offices.
We will continue to periodically check the “pulse” of research administrators on various topics.
If you have any topics or questions that you want to see addressed in Pulse in the future, please let us know. Send feedback, ideas, questions, and inquiries to Sarah Marina at firstname.lastname@example.org.