Policies

Public Information Policy

• The Graduate School maintains a dedicated website where all pertinent information and policies are publicly available: https://gradschool.stjude.org.  The website serves as the primary source of academic and non-academic policies of the Graduate School, so it is continually updated with all information related to the operation of the Graduate School and is maintained by the St. Jude Communications group and website professionals.
• The website has a ‘Resources’ section that provides access to the latest Academic Calendar and Catalog:  https://gradschool.stjude.org/students/resources.html.
• The website lists all the school’s Policies and Procedures including those related to Academics.  The Academics Policies are very comprehensive and clearly explain the grading policies that are consistently applied across all curricula and degree programs (See Section 80.22: Academic Evaluation, Grades and Grading, under Academic Policies, below)  
• The annual cost of attendance at the Graduate School is assessed in two equal amounts in the fall and spring terms.  The cost of attendance is limited to the assessment of the current tuition charge of $20,000.00 only, no other fees are assessed to enrolled students.  The tuition rate is the same across all degree programs and is the same for all enrolled students regardless of mode of delivery of curriculum.  The Graduate School applies a full tuition scholarship of $20,000.00 in two equal installments in the fall and spring terms to the student account of each enrolled student in each degree program.  The full tuition scholarship is the same across all degree programs and is the same for all enrolled students regardless of mode of delivery of curriculum.  In the event that a student receives an external grant award, the detail terms of the grant award will dictate the amount of tuition charges that will be assessed against the grant for payment of tuition with any remaining balance due covered by the Graduate School in the form of a partial tuition scholarship.  The portion of the tuition charge assessed to the external grant is subject to the terms of the refund policy.

St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences (“Graduate School”) operates on the semester system with the academic year divided into fall and spring semesters. Fall semester is from July 1 through December 31. Spring semester is from January 1 through June 30. The academic calendar is developed with input from the course leaders and takes into account the observed holidays as noted in 80.20.001. Changes are updated in the Learning Management System (LMS), the Catalog and the website. Changes to the academic calendar are immediately posted in the LMS.

80.20.001: Observed Holidays

The Graduate School observes the following holidays:

• New Year’s Day (January 1)
• Martin Luther King Jr. Day (third Monday in January)
• Memorial Day (last Monday in May)
• Independence Day (July 4)
• Labor Day (first Monday in September)
• Thanksgiving (fourth Thursday in November)
• Day After Thanksgiving (fourth Friday in November)
• Christmas Day (December 25)
• Day Before or After Christmas (December 24 or 26)

If a holiday occurs on a Saturday or Sunday, the Graduate School will observe the holiday on the same day that the Tennessee state government observes it. Generally, a holiday that falls on Saturday will be observed the preceding Friday, and a holiday that falls on a Sunday will be observed the following Monday. Consistent with the Graduate School’s commitment to create an academic community that is respectful of and welcoming to persons of differing backgrounds, the Graduate School makes every reasonable effort to allow members of the Graduate School to observe their religious holidays without jeopardizing the fulfillment of their academic obligations.

Course leaders must provide course syllabi prior to the start of the course that specify dates of lectures, examinations and due dates of assignments. It is the student’s responsibility to review these syllabi promptly and to consult the course leaders to discuss possible conflicts and plans to resolve them.

80.20.002: Spring Break

Spring Break is observed for first-year doctoral and master’s  students only and is scheduled in the curriculum. After completing the first year, a doctoral student may obtain prior permission for Spring Break from his/her thesis advisor.

• The Graduate School offers courses leading to degrees at the master’s and doctoral level.
• A master’s student who successfully completes all coursework and their thesis is awarded a terminal Master of Science degree.  A master’s student who does not successfully complete all coursework and their thesis is dismissed from the program.
•  A doctoral student who successfully completes his/her Candidacy Examination is awarded a transitional Master of Science degree and advances to candidacy.  A doctoral student who does not successfully complete their Candidacy Examination, and who is otherwise in good standing academically, may be awarded a terminal Master of Science degree based on progress achieved, as determined by the Dean, and is dismissed from the program.
• A doctoral student who advances to candidacy and successfully completes and defends their dissertation is awarded a PhD degree.

80.21.001: Credit Hour and Semester Definition

The U.S. Department of Education defines a credit hour as the amount of work represented in intended learning outcomes and verified by evidence of student achievement that is an institutionally established equivalency that reasonably approximates not less than:

(1) one hour of classroom or direct faculty instruction and a minimum of two hours of out-of-class student work each week for approximately fifteen weeks for one semester or trimester hour of credit, or ten to twelve weeks for one quarter hour of credit, or the equivalent amount of work over a different amount of time; or (2) at least an equivalent amount of work as required in paragraph (1) of this definition for other activities as established by an institution, including laboratory work, internships, practica, studio work, and other academic work leading to the award of credit hours.

The Graduate School also follows the federal definition of a semester, which is approximately 15 weeks long.

80.21.002: Credit Hour Assignment

• The standard for a one semester credit hour course is one class hour (50 minutes) of direct instruction and a minimum of two class hours (100 minutes) of out-of-class student work/student academic engagement activities each week during the standard semester (15 weeks). This equates to a total of 750 minutes of direct instruction and 1,500 minutes of out-of-class student work per standard semester (15 weeks). A course offered in fewer than 15 weeks shall contain the same total hours (contact hours, preparation time, content, and requirements) as the same course offered in the standard 15-week semester.
• While minutes of work and contact time can provide guidance in the establishment of credit hour equivalencies, it is understood that the student achievement associated with any credit hour can only be measured adequately in terms of documented qualitative and quantitative outcomes. The successful completion of a credit hour will always take into consideration expectations based on degree level, discipline, the type of learning experience (e.g., didactic, clinical, practica, or internships), and the mode of delivery (e.g., face-to-face or online). This definition is a minimum standard that does not restrict graduate faculty from setting a higher standard that requires more student work per credit hour.
• A course offered in fewer than 15 weeks shall contain the same total hours (contact hours, preparation time, content, and requirements) as the same course offered in the standard 15-week semester. Credit for the Graduate School’s block courses is calculated for a course to contain the same number of hours as if the course were scheduled for a full semester. Shortened courses provide adequate time for graduate students to complete homework assignments. For laboratory rotations, the hours per week are considered to take place in the laboratory.  
  • Block Courses: Block courses earn anywhere from 1 to 4 credit units each. A typical module course is a combination of lecture and homework. [Example of Genes to Proteins, which is a 4-credit hour course taught in two 3-hour blocks on MWF over 5 weeks: (64 hours of lectures, exams, and mentoring + 92 hours homework) = 156 hours. 156 hours x 60 minutes = 9,360 minutes. 9,360 minutes / 50 minutes (DOE hour equivalent) = 187.20 hours.]
    
  • Laboratory Rotations: Laboratory rotations in the Biomedical Sciences MSc/PhD program occur in the Fall (one rotation) and Spring (two rotations) and earn 3 credits each. [Example: 40 hours x 6 weeks = 240 hours x 60 minutes / 50 minutes = 288.00 hours.] 
  • Distance Education Courses: For distance education courses, the number of hours for required recorded lectures that students must watch are counted as direct instruction time. The amount of time required for all the courses is documented by the instructor and collected by the program director.

80.21.003: Course Numbering

The Graduate School courses are labelled with a seven-character field.  The first three characters represent an alphabetic prefix that defines the program to which each course is attached.  The fourth character indicates courses earned toward a degree level.  The fifth and sixth characters indicate the numbering of courses.  The seventh character indicates the term the course is offered.  

Examples:

BMS9301

‘BMS’:  Biomedical Sciences   ‘9’:  Doctoral level   ‘30’:  Sequence of course   ‘1’:  Fall term

GCH8132

‘GCH’:  Global Child Health   ‘8’:  Master’s level   ‘13’:  Sequence of course   ‘2’:  Spring term

80.21.004: Academic Catalog

Students are governed by the academic regulations of the catalog in effect at the time of their admission.  The academic catalog is updated annually for new programs, changes to the current programs, and for policy additions and updates.  Students must complete the degree requirements as outlined in the catalog that was in effect at the time of their enrollment or readmission to the Graduate School.  Students must become thoroughly familiar with the Graduate School’s current academic regulations as defined in the catalog.  Individual departments where students are performing their dissertation research may have additional requirements that the student must also know and comply with. Changes to the academic catalog will be considered only when appropriate documentation is recorded by the Registrar and reviewed and approved by the SVP/COO.

80.21.005: Prerequisites

The Graduate School defines a prerequisite as a course that must be completed with a satisfactory grade before enrolling in another course or being admitted to a certain program.

All prerequisites are listed in the academic catalog under a course description and on the curriculum pages. Students will not be allowed to enroll in a course without completing the necessary prerequisites.

80.21.006: Registration

All students are registered by cohorts through the process of auto-enrollment.  Auto-enrollment is a registration process whereby the Registrar enrolls the students prior to the start of classes of each term.

80.21.007: Lectures

It is required that all students will attend the scheduled lectures provided either in-person or online.  Any student who is unable to attend a scheduled lecture must email the Registrar, who in turn, will notify the instructor and course leader(s).  As noted in 80.27.008, recordings of the lectures will be available for those students who are unable to attend a scheduled lecture.

Key points related to lectures are:

• Lectures are prepared ahead of time and uploaded into the LMS by the lecturer.  This gives students the opportunity to review the material in advance of the start of class and to prepare questions;
• As directed by the lecturer, students must be prepared to present portions of any research paper that will be discussed in lectures;
• All in-person lectures are recorded and uploaded within 48-72 hours and are appropriately stored for subsequent viewing.  In-person lectures and content will remain available for the duration of each course.  At the conclusion of each course, the recordings will no longer be available to enrolled students;
• Recordings of lectures are not a substitute for regular attendance at in- person lectures.

80.21.008: Online Etiquette and Communication

The classroom and learning management system are academic environments and certain behaviors are expected when you communicate with your peers and your instructors. These guidelines for online behavior and interaction are known as “netiquette”.

General Guidelines

• When communicating online, you should always:
• Treat your instructor and classmates with respect in email or any other form of communication;
• Use your instructor’s proper title (e.g., Dr. Smith or, if in doubt, Mr. or Ms. Smith);
• Use clear and concise language;
• Remember that all graduate level communication should have correct spelling and grammar (this includes discussion boards);
• Avoid using slang terms and texting abbreviations;
• Use standard fonts and a font size of 12 point;
• Avoid using the caps lock feature;
• Limit or avoid altogether the use of emojis;
• Be cautious when using humor or sarcasm as tone is often misunderstood in an email or discussion post and your attempt at humor might be taken seriously or sound offensive;
• Do not send personal and/or confidential information – remember Student Privacy and Confidentiality and HIPAA.

Email Netiquette

In addition to the above mentioned guidelines, when you send an email to your instructor, teaching assistant, or classmate, you should:

• Use a descriptive subject line;
• Be brief;
• Avoid attachments unless you are sure your recipients can open them;
• Use plain text instead of HTML;
• Sign your message with your name and return email address;
• Think carefully before you send the email to more than one person. Does everyone need to see your message?;
• Be sure you really want everyone to receive your response when you click, “reply all” ;
• Do not forward an email message from someone else without their consent.

Discussion Board Netiquette and Guidelines

When posting on the discussion board in your online class, you should:

• Make posts that are on topic and within the scope of the course material;
• Take your posts seriously and review and edit your posts before sending;
• Be as brief as possible while still making a thorough comment;
• Always give proper credit when referencing or quoting another source;
• Be sure to read all discussion points in a thread before replying;
• Do not repeat someone else’s post without adding something of your own to it;
• Avoid short, generic replies such as, “I agree.” You should include why you agree or add to the previous point;
• Always be respectful of others’ opinions even when they differ from your own;
• When you disagree with someone, you should express your differing opinion in a respectful, non-critical way;
• Do not make personal or insulting remarks;
• Be open-minded.

• The doctoral students’ grades during the first year of the curriculum are based on a combination of examinations (50%), problem sets (40%) and participation (10%).  These percentages apply consistently to all courses except for courses that are Pass/Fail as defined in the Academic Catalog.
• The master’s students’ grades are based on examinations, assignments and participation. The weights for the three areas may vary across master’s level courses – see relevant syllabus.
• The grading scale, as defined in 80.22.004, is the same across all degree programs.  

80.22.001: Examinations

All students

• Depending on the length and content, a course may have more than one examination;
• Lecturers design their own style of examination questions and format;
• Course Leaders and the Associate Deans must review the examination questions for level of difficulty, clarity, and fairness;
• Course Leaders are responsible for ensuring that Instructors score their examination question(s) within three (3) business days and that the Instructors provide comments to help the student understand where he or she may have had difficulty.

On-Campus

• Examinations take place in the Graduate School Lecture Room and are proctored.  Students may leave the room for personal breaks only with permission of the proctor but must continue to abide by the Academic Code of Conduct when absent from the room;
• Students may approach the proctor to clarify a question, but the proctor is under no obligation to provide an answer and may seek help as necessary from the lecturers.  The proctor will share any clarifications with all students;
• All answers to examinations are to be written on the provided bar-coded paper that facilitates marking by the lecturers.

Online

• Examinations are administered electronically through the LMS;
• Safeguards are in place to verify the student’s identity during an examination. The Graduate School requires two-factor authentication for accessing the LMS. In addition to network credentials, the student will provide a token of information that only the student would have immediately on hand, such as a code sent via SMS message, voice call, or correctly answering randomized security questions specific to the student. In addition to the two-factor authentication, additional security measures are needed for examination integrity;
• Instructors are expected to include an additional verification method within the examination to verify the student identity during the exam. This verification could require the student to take or record a picture or video of themselves or IDs during the examination using the webcam on the student issued laptop;
• For examinations that require an additional level of monitoring of examination integrity, instructors must also utilize an online proctoring service that is integrated with the LMS. The online proctoring service will verify the student’s identity prior to providing the student access to the examination site. During the examination, the proctor may monitor the students in real time via webcams;
• Examination availability on the course site will be restricted to the testing period established by the instructor;
• Students complete the final answers by themselves, free of consultation;
• Students abide by the Honor Code;
• Students submit the completed problem sets or assignments by the requested time;
• Online students may contact the course leader for assistance.
• Instructors mark the assignments and examinations and provide written comments to help the student understand where he or she has answered well or poorly.
• All feedback on examinations must be provided online through CrowdMark.

80.22.002: Problem Sets/Assignments - PhD

Problem sets and other assignments test students in detail on specific topics and provide opportunity for background reading and library research.  Postdoctoral mentors can assist the onsite students and students may work together.

The following apply:

• Instructors design problem sets and assignments to be completed in a reasonable time up to half a day including background reading;
• Students complete the final answers by themselves, free of consultation;
• Students abide by the Honor Code;
• Students submit the completed problem sets or assignments by the requested time;
• Instructors mark the problem sets or assignments and provide written comments to help the student understand where he or she has answered well or poorly.

80.22.003: Student Participation

Participation in lectures, group discussions, paper discussions, presentations, and other means of instruction are regarded as a key facet of the Graduate School training.  Course leaders will assign a participation grade based on feedback from the lecturers.

80.22.004: Grade Scales

Students will be awarded grades for all coursework. The grades are determined according to the following scale of the combined scores:

A+ (98-100), A (90-97), A- (85-89), B+ (81-84), B (73-80), B- (70- 72), C+ (67-69), C (62-66), C- (60-61), F (0-59), will be issued at the conclusion the course. Pass, Fail, I, W, X.

For calculating the GPA (see 80.24.006), letter grades are associated with numeric values as follows: A+ (4.0), A (4.0), A- (3.7), B+ (3.3), B (3.0), B- (2.7), C+ (2.3), C (2.0), C- (1.7), F (0.0).

Pass/Fail

A student’s earned grade in a course designated as Pass/Fail will be a “Pass” if the student has earned a course grade of C (62 or above). A student’s earned grade in a course will be “Fail” if the student has earned a course grade F (below 62).  A Pass/Fail grade is not used in calculating a student’s GPA but a grade of “F” is used in calculating a student’s GPA.

When a student earns a “Pass” in a course that is designated as Pass/Fail, the credits from that course count toward the degree requirements, but the credits are not used in calculating the student’s GPA.

A student who receives a “Fail” grade in a Pass/Fail course will immediately be placed on academic warning as successful completion of the degree requirements will be at risk.  The credits of any failed course will not be counted toward the degree requirements.  A student will have the opportunity to earn a “Pass” in a course where the student received a “Fail” with the successful completion of an individualized academic plan designed in consult with the Associate Dean (or designee) and the relevant Graduate Faculty member.      

I – Incomplete

A student may initiate an Incomplete when an extenuating circumstance prevents the student from completing course work during the semester. Before an “I” is assigned, the student is responsible for writing an agreement with the course leader(s) that details the requirements that the student must meet to change the "I" to a letter grade. An “I” is not included in the calculation of the GPA.  An “I” will convert to a failing grade if the incomplete work is not made up before the end of the next semester which may jeopardize the student’s continued enrollment in the graduate program.

W – Student-Initiated Withdrawal

This mark is given to a student who initiates the process to officially withdraw from the Graduate School during the time specified in the academic period. "W" does not satisfy prerequisites and is not included in the calculation of GPA.

 X – Missing Grade

This mark is given to a student as a result of a missing course grade from the instructor.  This grade does not affect the student's GPA and a replacement grade will be collected by the Registrar, as soon as possible.  

80.22.005: Grade Point Average (GPA) Calculation

To determine a student’s progress toward a degree and scholastic standing, the GPA is calculated at the end of each semester and immediately, prior to graduation. This calculation relies on quality points derived from the grade assigned to each course. Grades are available online at the close of each semester.

Formula:

GPA = Total quality points earned divided by credit hours associated with the quality points awarded

 Example:

A student has successfully completed the Genes to Proteins course (4 credits) with a grade of A- (3.7 points) and Cell Biology course (3 credits) with a grade of A  (4.0 points).

Quality Points:

Genes to Proteins = 4.0 x 3.7 = 14.8

Cell Biology = 3.0 x 4.0 = 12.0

            Total Quality Points = 14.8 + 12.0 = 26.8

Total Credits = 7

GPA = 26.8/7 = 3.828

80.22.007: Candidacy Examination – PhD

The examination format and rules and regulations are as follows:

• The Chair of the examining committee cannot be the dissertation advisor, but the dissertation advisor must be present;
• The student submits the written Candidacy Examination and Defense document by email to the Registrar at least two weeks before the examination.  The Registrar will be responsible for emailing the document to each committee member;
• The student will leave the room, and the Committee will have initial discussions about the student, the project and performance in the laboratory and the written examination document;
• The Committee invites the student to return and present his/her PowerPoint presentation without interruption for no longer than 25 minutes;
• The Committee members conduct the oral examination for no longer than 1.5 hours;
• The student’s PI may ask questions and make comments with permission of the Committee Chair;
• No additional slides are allowed for the oral examination. The student must be prepared to sketch diagrams to support explanations and may return to a slide to address a question specific to that slide.
• After the oral examination is completed, the student is excused and the Committee votes Pass or Fail on (1) the written and PowerPoint documents, and (2) the oral examination.  The Committee then votes Pass, Fail or Provisional on the overall examination;
  • Pass – the student has successfully completed the examination;
  • Fail – the student must submit a full rewritten proposal and schedule an oral re-examination within one month;
  • Provisional – the student is required to submit a rewrite and may or may not be required to schedule an oral reexamination within one month. The Committee Chair may ask for additional requirements.
• The student is invited to return to the examination room, and the Committee Chair will provide feedback and inform the student of their grade.  Other committee members may also offer feedback.

80.22.008: Satisfactory Academic Progress

Students are required to demonstrate satisfactory academic progress (SAP) toward degree completion. Academic progress is measured at the end of each academic semester. Students must have a minimum GPA of 3.0 to graduate.  Milestones required to comply with SAP for each program are described below.  Overall performance will be assessed by the Associate Dean of each respective program and if a student fails to comply with SAP, a report of the findings will be discussed with the student and placed in the student’s file.

The grade scale is as follows: A+ (98-100), A (90-97), A- (85-89), B+ (81-84), B (73-80), B- (70- 72), C+ (67-69), C (62-66), C- (60-61), F (0-59), Pass, Fail, W (Withdrawal), I (Incomplete), X (Missing Grade).  A grade will be issued at the conclusion of each course.

Transitional MSc in Biomedical Sciences

• Complete all courses and maintain an overall GPA of 3.0 (on a 4.0 scale) or better;
• Participate in non-credit bearing workshops and seminars;
• Complete three six-week laboratory rotations during the first two semesters. Submit weekly progress reports and make a final presentation at the end of each rotation;
• Select a dissertation advisor and laboratory to begin dissertation research by the end of the second semester;
• Finalize the Dissertation Committee during the early part of the third semester;
• Pass the Candidacy Qualifying Exam by end of June of the fourth semester. The examination includes preparation and oral defense of a grant application based on the proposed dissertation research.

PhD in Biomedical Sciences

• Successfully complete the Transitional MSc in Biomedical Sciences and ‘Advance to Candidacy’;
• Submit a grant application to an outside funding agency to support the proposed research with assistance from the dissertation advisor no later than the end of the fifth semester;
• Schedule bi-annual meetings with the Dissertation Committee;
• Conduct independent research and submit for publication a minimum of two manuscripts. Ideally, one of the publications will be a first author publication;
• Maintain an overall GPA of 3.0 (on a 4.0 scale) or better;
• Ideally before the end of the fifth year, successfully draft and conduct an oral defense of the dissertation and make all necessary revisions.

MSc in Global Child Health

• Complete all courses and maintain an overall GPA of 3.0 (on a 4.0 scale) or better;
• Participate and satisfactorily complete all assignments and examinations;
• Participate in non-credit bearing workshops and seminars during experiential learning intersessions;
• Select a thesis advisor, topic, and committee during the early part of the third semester;
• Attend scheduled meetings with the Thesis Committee;
• Draft and conduct an oral defense thesis and make all necessary revisions to the thesis by the end of the fourth semester.

MSc in Clinical Investigations

• Complete all courses and maintain an overall GPA of 3.0 (on a 4.0 scale) or better;
• Participate and satisfactorily complete all assignments and examinations;
• Participate in mandatory workshops and seminars;
• Select a thesis advisor, topic, and committee during the early part of the third semester;
• Attend scheduled meetings with the Thesis Committee;
• Draft and conduct an oral defense thesis and make all necessary revisions to the thesis by the end of the fourth semester.

Academic Sanctions

Failure to meet SAP requirements will result in an academic sanction: Academic Warning, Academic Probation or Academic Dismissal.

Academic Warning

The warning sanction alerts the student and the Graduate School of the student’s need for academic improvement. Measures of poor performance include, excessive absences, failures to participate in mandatory workshops and seminars, or hold committee meetings.   These issues will be reviewed by the Associate Dean of the respective program. The student will receive notification of failure to meet minimum standards of performance and/or engagement and must meet with the Associate or Assistant Dean to discuss and determine next steps. Selection of a dissertation advisor is a key required milestone. 

Academic Probation

Students who fall below an average GPA of 3.0 are placed on academic probation for one semester.  If the student raises their GPA to the required minimum standard of 3.0 during that semester, then they will be released from probation.

Intervention Measures are initiated as soon as low grades are noted in a single course to prevent probation, and continue during probation to assist students in raising their GPA:

1. Regular check-in meeting with the Associate/ Assistant Dean of their respective program.
2. A plan for corrective action will be devised.
3. The student advisor will maintain status updates on the Corrective Action Plan.

Academic Dismissal

If the student’s performance does not raise the GPA to 3.0 by the end of the first semester of probation, the student will be dismissed from the Graduate School.  The Dean and Associate Dean of the respective program may decide to allow the continuation of probation for one semester in exceptional circumstances. If at the end of the second semester of probation the grade point average is still below 3.0, the student will be dismissed from the Graduate School.  During the probation period, the student will be given the option to withdraw before facing academic dismissal.  The Graduate School will offer coaching to aid in the decision and assist the student in determining next steps.

80.22.009: Attendance

Students are required to attend all lectures in each course. A student who cannot attend a lecture for any reason, must notify the Course Leader, Instructor, and the Assistant Dean as soon as possible.  All absences will be noted in the Graduate School records.  In unusual and exceptional circumstances, students may request an excused absence in advance. Excused absences can be requested from the Assistant or Associate Dean of the respective program.

Lectures are recorded and will remain available for the duration of each course. Lecture recordings are not a substitute for regular attendance but may be used as a substitute if the absence is justified.

Onsite student attendance is defined by the presence of the student. Student attendance in the distance learning component of each course is defined as active participation. These courses will, at a minimum, have weekly mechanisms for student participation, which can be documented by any or all of the following methods:

• Completion of tests or quizzes
• Discussion forums
• Submission/completion of assignments
• Communication with the instructor
• Logging in and watching lectures (or downloading them to watch)
• Other course participation

As a component of attendance, student email, course announcements and discussion forums should be checked frequently (daily is recommended). The student is solely responsible for checking updates related to the course.

Attendance is monitored and excessive absences and/or late arrivals will lead to academic sanctions. Absences will be reviewed by the Associate Dean of the respective program.

80.22.010: Grading Timing and Release

The deadline for all grading (Assignments, Examinations, and Participation) is three (3) business days from the date the student’s work is due or submitted.  The Registrar is responsible for collecting, recording, and reporting grades on behalf of the Graduate School.  The Graduate School will release the grades once all the grades for students in the class are received and reviewed internally.

80.22.011: Grade Appeals

Appeals for final course grades must be submitted to the relevant Associate Dean before the end of the following semester. Any grade standing beyond that period is not available for review and will remain on the transcript. Students are advised to discuss concerns about grades and academic progress with their advisors at the earliest possible time.

Process for Formal Final Course Grade Appeal

1. When appealing a grade, the student should provide a written statement of the violation; description of attempts to resolve complaint; documentation regarding policies including but not limited to the course syllabus; and documentation of coursework associated with the complaint.
2. The Associate Dean shall provide a time-stamped and dated copy of the formal student course grade appeal to the instructor(s). The Program Director will then request input and/or response from the instructor(s).
3. The Associate Dean may convene an ad hoc special review committee to advise on any dispute.
4. The Associate Dean shall review all documentation and respond in writing to the student within thirty calendar days of receiving the formal course grade appeal. The Associate Dean will place, in writing, the final decision to the student and instructor(s), and grade appeal committee or the reason for any delay in decision. The decision of the Associate Dean can be appealed to the Dean.
5. Appeals to the Dean must be submitted in writing within ten calendar days of the postmarked response from the Associate Dean. The Dean or his/her designee must respond to the student appeal within thirty calendar days. The decision of the Dean or his/her designee is the final decision. No further appeal is possible.
6. The SVP/COO retains all grade appeal records permanently.

The decision/resolution at the institutional level is considered final. However, students in the state of Tennessee may appeal a decision to the Tennessee Higher Education Commission licensure staff at 404 James Robertson Parkway, Suite 1900, Nashville, TN 37243; phone: (615) 741-5293, if the student does not feel that the issue has been adequately addressed.

80.22.012: Incomplete Grades

With the Dean’s approval, incomplete grades may be issued when the semester ends and a student’s work is academically acceptable, but for a valid reason the student has been unable to complete all required work. To remove an incomplete grade, the student is expected to complete all uncompleted work by the time agreed upon with his/her advisor, or by the end of the next semester at the latest.

Incomplete grades are indicated on a student’s transcript as an “I,” which will be replaced with the appropriate grade and credit awarded when the student completes the work, as approved by the course faculty or research faculty advisor, as appropriate. If the grade has not been changed by the end of the following semester, the “I” will be replaced with an “F,” which will be calculated into the student’s GPA. Reversal of the “F” grade may be possible, if the work is subsequently completed and reversal is recommended by the student’s advisor. This option would be granted only in extraordinary circumstances and with the Dean’s approval.

80.22.013: Class Cancellation

A class may be cancelled up to two weeks before the start date. If an entire session of classes is cancelled prior to the beginning of the semester, students will be given the opportunity to take the classes to complete the degree. Should an unavoidable event such as an epidemic, natural disaster, civil unrest, or threat of terrorist activity result in partial or complete cancellation, the current situation will be evaluated to determine the appropriate plan in moving forward.

Syllabi inform students about what is expected of them to meet course requirements and is provided to the students via the LMS. Syllabus content must be in accordance with requirements as set forth by the Southern Association of Colleges and Schools Commission on Colleges (SACS COC) and the Tennessee Higher Education Commission (THEC).

80.23.001: Mandatory Course Information

• Name of Course Leader(s) and lecturers;
• Course Leader(s) office number and location, department affiliations, and phone numbers;
• Times and locations for Course Leader(s) office hours;
• Course number, section, and title;
• Semester (fall or spring) and year;
• Prerequisites and any other enrollment requirements;
• Overview of the scope, purpose of the course, and course description;
• Due dates for problem sets and examinations;
• Method(s) for submitting problem sets and assignments;
• Date and format of examination(s);
• Explanation of the grading rubric of assignments, problem sets, examination(s) and participation;
• Required and optional texts and other resources;
• Copyright usage policy;
• Expected student objectives for the course.

80.23.002: Course Materials

• Course materials include, but are not limited to, lecture presentations, lecture recordings, required and recommended readings, links to papers and relevant sites, and JoVE links.
• Course materials may not be shared once the course is completed.

80.23.003: Submission of Coursework

Coursework must be submitted by the dates specified by the instructor and as detailed on the syllabus and in the LMS course calendar.  Grace periods will only be granted in exceptional circumstances (e.g. illness, personal, or family issues) and at the discretion of the course leader, in consult with the relevant Associate Dean.  Computer failure is not accepted as a reason for missing an assignment deadline and students are expected to back up their data at regular intervals to avoid losing their work.  All students are strongly encouraged to make use of the shared drive to back up data and coursework.  Loaner laptops are available upon request.

80.24.001: Degrees and Degree Completion

Master of Science Degree in Global Child Health – Terminal (  30 credit hours)

• To be awarded a master’s degree, a student must:
  • Successfully complete all coursework and examinations;
  • Have satisfactory attendance and participation in the required workshops, seminars, and experiential learning activities;
  • Submit a master’s thesis with oral defense before the student’s thesis committee.
• Each student is expected to successfully complete all coursework, assignments, and examinations during the two years of the program.
• Students are encouraged to start exploring topics for the thesis in the first two semesters.
• The thesis defense must be completed by May 15 of the fourth semester.  A student who fails the defense of his/her thesis will be allowed to repeat the defense once before June 15 in the student’s fourth semester.  A second failing grade will result in termination from the program.

Master of Science Degree in Biomedical Sciences – Transitional (57 credit hours)

• A student who successfully completes first- and second-year curricula and defends the Candidacy Examination with a passing grade will be awarded a transitional Master of Science degree in Biomedical Sciences and will advance to candidacy.

Master of Science Degree in Biomedical Sciences - Terminal (57 credit hours)

A student who decides to leave the program prior to obtaining their PhD degree or does not successfully pass their Candidacy Exam and is unable to complete his/her PhD studies may apply to the Associate Dean and Dean for a terminal Master of Science degree in Biomedical Sciences. To be considered for a terminal master's degree, the student must:

• Successfully complete the first-year core curriculum;
• Complete at least one year of full-time research; and
• Write and successfully defend their candidacy exam based on their research.

Once the Associate Dean and Dean approve the request for a terminal master's degree, the student will write and submit their candidacy exam and defend it during an oral examination administered by his/her Dissertation Committee. If the student's Dissertation Committee, Associate Dean and Dean approve the amount and quality of the student's work and agree that it rises to a master's level of research and academic accomplishment, a terminal master's degree is awarded to the student.

Doctoral Degree in Biomedical Sciences (93 credit hours)

• The Graduate School will award the doctoral degree upon the successful completion of the following requirements:
  • First-year courses and accompanying examinations and problem sets (two semesters);
  • Three laboratory rotations and clinical assignments;
  • Satisfactory attendance and participation in the required journal clubs, seminars, and laboratory meetings;
  • Pass Candidacy Examination (end of the fourth semester);
  • Submit a grant application;
  • Have two research manuscripts published or accepted for publication in a peer-reviewed journal (ideally, one first-author);
  • Complete dissertation research;
  • Write a dissertation; and
  • Pass the oral defense of the dissertation.

• Each student is expected to complete all coursework, three laboratory rotations, and clinical assignments during the first two semesters;
  
• The third and fourth semesters are devoted to research and enhanced preparation for the Candidacy Examination;
• To attain doctoral degree candidacy status, the student must have passed all requirements to take the Candidacy Examination by the end of the fourth semester;
•  In consultation with the Associate Dean and Dean, each student will select a Dissertation Committee members by the beginning of the third semester;
• A student who fails the Candidacy Examination or the oral defense of the thesis will be alowed to repeat once.

80.24.002: Degree Completion Time Limit

• Students are expected to complete the doctoral degree within five years, with six years as the maximum time allowed including any leaves of absence;
• Students are expected to complete the master’s degree within two years, with three years as the maximum time allowed including any leaves of absence;
• If a student has been approved to withdraw from the program and then is re-admitted, the period of withdrawal will not be included in the time to degree.  Any exceptions to this policy require the approval of the Dean.

80.24.003: Intent to Graduate

An Intent to Graduate form must be submitted to the Graduate School at the beginning of the semester in which the student expects to complete a degree.

80.24.004: Degree Conferral

Degree conferral is an institutional action that represents a student’s completion of the requirements necessary for a degree.  All students must file the Degree Completion Form to be considered for degree conferral.  Degrees at the Graduate School are conferred in June of each year – generally, a Commencement Exercise will occur in conjunction with the conferral of degrees but my be scheduled later by the Dean and SVP/COO to accommodate schedules of participants.  A student who has had their terminal degree conferred - doctoral or master’s - will be assigned ”graduate” status, which will prohibit his/her registration in a subsequent semester.

80.24.005: Experiential Credit

Experiential credit will be considered on a case-by-case basis for students who are admitted into the doctoral program and typically reflects prior experience in research, clinical care and industry.  Experiential credit will be reviewed and granted by the Graduate Council. Experiential credit will not be considered for students who are admitted into the Master of Clinical Investigations and Global Child Health programs.

80.24.006: Transfer Credit

Transfer credit may be granted for a student transferring into the Graduate School from another program. The transfer credit request will be evaluated by the Graduate Council, prior to student enrollment. After the conclusion of the evaluation, the Graduate Council will submit a recommendation to the Associate Dean of the respective program. The maximum number of transfer credits will vary across programs.

80.24.007: Transferability of Credit to Other Institutions

The St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences is a special purpose institution. The purpose is to fundamentally advance global health and to find cures for pediatric catastrophic diseases by enhancing education across disciplines and training future leaders and innovators, including researchers probing the molecular basis of disease and therapy, medical practitioners conducting clinical and translational research, and health professionals improving health care systems worldwide. Students should be aware that transfer of credit is always the responsibility of the receiving institution.  Whether or not credits transfer is solely up to the receiving institutions.  Any student interested in transferring credit hours should check with the receiving institution directly to determine to what extent, if any, credit hours can be transferred.

Read our Transferability of Credit Disclosure Compliance Statement

80.24.008: Transfer into the Graduate School from other Programs

• A graduate student at another institution may not transfer into the Graduate School unless accompanied by a St. Jude-recruited and THEC-approved Research Graduate Faculty member;
• International doctoral students cannot transfer into the Graduate School currently;
• Students who transfer with a St. Jude-recruited THEC-approved Research Graduate Faculty member may only transfer into the doctoral program and not into the master’s program;
• Transfer student applicants must pass background and registry checks and drug screen prior to final admission into the Graduate School;
• A doctoral student who has completed his/her Candidacy Examination at another institution may not transfer into the Graduate School but may complete the research for a PhD degree at St. Jude through an agreement between St. Jude and the home institution, and the student’s dissertation advisor. The Graduate School has no formal role in the student’s training.  However, the student may informally participate in lectures and presentations with permission of the SVP/COO and the Graduate Faculty member(s) overseeing and conducting the course(s);
• A doctoral student at another institution who has not passed his/her Candidacy Examination may formally apply to transfer into the Graduate School if the dissertation advisor is a member of the St. Jude Research Graduate Faculty;
• Prior to accepting a transfer student, the Dean, SVP/COO, Associate Dean, dissertation advisor, and other designees will review the transfer applicant’s academic and student record and evaluate the student’s prior graduate-level coursework for academic credit at the Graduate School.  Key factors for academic credit evaluation include level and content of prior coursework, comparability to Graduate School courses, and relevance to the Graduate School curriculum;
• For a doctoral student who has been approved to transfer from another institution, a plan will be formulated to complete their graduate training.  The student must complete necessary courses in the first-year curriculum as determined by the Dean, Associate Dean, SVP/COO, dissertation advisor, and other designees of the student’s prior graduate-level coursework.  Depending on when in the academic year and in the stage of the student’s graduate studies the transfer occurs, and with the Dean’s approval, the requisite sections of the Graduate School curriculum may be completed in the student’s second year.
• Transfer students are required to complete three distinct laboratory rotations.  Rotations completed at the student’s prior institution may count towards this requirement;
• Irrespective of prior training, a transfer student must complete the Graduate School’s translational course and writing course, pass the Candidacy Examination, and submit a grant application;
• Candidacy Examinations occur during the spring semester of the student’s second year and the grant proposal is submitted after passing the Candidacy Examination. The Dean and dissertation advisor may adjust timing for a transfer student’s Candidacy Examination accordingly;
• Once formulated, the dissertation advisor will present the training plan of the transfer student to the Graduate Council.  The Graduate Council will provide feedback on the training plan to the Dean prior to his/her approval;
• Accepted transfer students will receive the full benefits that the Graduate School provides to students in the same degree program;
• Accepted transfer students are required to follow the Graduate School Policies & Procedures.

80.25.001 Selection of Dissertation Advisors - PhD

• Students are required to perform three six-week rotations in the first-year curriculum. The rotations are designed to accomplish four objectives: (1) provide hands-on laboratory experience within the St. Jude research environment; (2) allow the students to evaluate the faculty and their research topics and laboratory environments for potential dissertation research; (3) allow faculty to evaluate the students for potential acceptance into their laboratories for dissertation research; and (4) allow the students to complete, write-up, and orally present three six-week projects.
•  Students are required to rotate in three different laboratories and preferably in at least two different departments. Exceptions will be approved by the Dean. Students may only formally organize the next scheduled rotation in the curriculum, but students are free to discuss potential rotations with faculty and explore their interests and options at any time and should do so as early as possible in the first year. Faculty must inform potential rotation students of their willingness to be dissertation advisors during the following year.
• When a rotation has been agreed upon by the student and the faculty member, the match must be submitted to the Dean and the relevant department chair for approval at least two weeks prior to the rotation start date. The student and the faculty will 1) identify a project suitable for graduate level research; 2) arrange laboratory space, equipment, supplies and mentor; and 3) identify training necessary to conduct the research.
• Each student will maintain a bound laboratory notebook to 1) record all laboratory activities, source data, and dates, and 2) provide weekly journal entries that summarize the student’s activities and progress. At the completion of each rotation, the original notebook will remain with the faculty member who supervised the graduate student, and a copy will be forwarded and stored electronically in the student record. 
• At the end of the rotation, each student will prepare a PowerPoint presentation to be orally delivered in a formal Graduate School event that is open to all graduate students, members of the Graduate Faculty, and members of the participating laboratories. The Registrar will retain the final PowerPoint file stored electronically in the student record. 
• Students will be provided a supplies budget from the Graduate School for each rotation and may access the budget for individual purchases only with permission from the Research Graduate Faculty advisor.
• After the third rotation, and not before, each student must identify a faculty dissertation supervisor from one of their three rotations. The selected faculty member is not obligated to accept the student who may then be required to select their second or third choice laboratories. The final match must be recorded, signed by the dissertation advisor, student, Dean, and department chair, and placed in the student record at the Graduate School.
• If a student does not identify a dissertation advisor after the third rotation, the student will be formally placed on warning status. A review committee will be convened to discuss the situation comprising the Dean, the Associate Dean, the SVP/COO, and three members of the Graduate Council. There are two possible outcomes from this meeting; 1) the student is dismissed from the program or 2) a fourth rotation will be organized during the summer after completion of the first-year curriculum. If the latter, the review committee will select the faculty dissertation advisor after discussion with the student and potential dissertation advisors. The department chair must also approve the placement before the permanent assignment begins. Presentation of the fourth project will be conducted in a closed session with the review committee and the fourth rotation advisor.
• If a dissertation advisor cannot be identified after the fourth rotation, there are two possible outcomes; 1) the student is dismissed from the program or 2) the student will be assigned a Research Graduate Faculty dissertation advisor who is willing to oversee the student’s PhD project pending the approval of the relevant department chair. Any student who does not accept the assignment decision will be dismissed from the program.

80.25.002: Dissertation Advisors - PhD

• Only members of the Research Graduate Faculty can serve as dissertation advisors;
• The graduate student must conduct his/her research under the supervision of the dissertation advisor;
  
• Oversee and direct graduate student research and guide the graduate student to successful completion of the student’s PhD degree;
• Establish the dissertation committee and, apart from the Candidacy Examination (see 80.22.007), Chair the dissertation committee;
• The dissertation advisor and the dissertation committee together decide when a graduate student has successfully completed the requirements to receive his/her PhD;
• Oversee, monitor, and grant permission to use the supplies and travel budget granted to the graduate student by the Graduate School.

80.25.003: Dissertation Committees - PhD

• Comprises a minimum of four members, including the dissertation advisor; 
• Any member of the Graduate Faculty may serve on the dissertation committee;
• At least two members of the dissertation committee must be Research Graduate Faculty at the rank of Associate or Full Member; 
• Only one Assistant Member may serve on the dissertation committee, including the dissertation advisor;
• Only one Clinical Graduate Faculty may serve on the dissertation committee;
• Only one Adjunct Faculty Member may serve on the dissertation committee;
• A fifth member may be added at any time to provide supplemental expertise by written request of the dissertation advisor and with approval of the Dean and Associate Dean. The fifth member must hold a PhD or MD degree or equivalent and can be either (1) any member of the Graduate Faculty at any rank, (2) any member from the St. Jude Faculty who is not on the Graduate Faculty, or (3) a recognized leader in a field relevant to the thesis project as an external expert from an outside institution. The latter would be classified as a Visiting Instructor (see 80.36);
• All members of the dissertation committee are voting members;
• At least three members of the dissertation committee including the dissertation advisor must be present at each meeting. Remote ‘call ins’ are allowed but discouraged;
• During the student’s second year, the dissertation committee will meet as necessary to finalize and examine the ‘Candidacy Examination’;
• During subsequent years, the dissertation committee must meet with the graduate student biannually, assess student progress via the student’s formal research presentation, and submit a formal report and recommendation (Biannual Student Progress Form - PhD) to the Dean together with a final copy of the graduate student presentation;
• Additional meetings may be arranged at the request of the student or one or more dissertation committee members; 
• The dissertation advisor and the dissertation committee decide together when a graduate student has successfully completed the requirements to receive his/her PhD;
• After full review of the student’s academic record, and in consultation with the Dean, Associate Dean and the SVP/COO, the dissertation advisor and the dissertation committee may determine that the graduate student’s level of achievement does not meet the standards required to award a Doctoral degree (see 80.24.008) and warrants the student leaving the program with a Terminal or Transitional Master’s degree (see 80.27.001). 
• Any requested changes to the dissertation committee must be submitted to the Dean and Associate Dean in writing by the dissertation advisor (or the advisor’s Chair) with a full explanation for review and approval.

80.25.004 Selection of Thesis Advisors – Global Master’s

• The student’s third and much of the fourth semester are devoted to research and enhanced preparation for the thesis and defense;
• A thesis advisor will be selected to oversee the preparation of the thesis;
• The thesis advisor will oversee the selection of the Thesis Committee and chair the Committee.

80.25.005 Thesis Advisors – Global Master’s

• Only members of the Graduate School Faculty may serve as thesis advisors;
• The graduate student must work on his/her project proposal under the supervision of the thesis advisor;
• The thesis advisor oversees and directs graduate student research and project proposal preparation and guides the graduate student to successful completion of the MSc degree.

80.25.006 Thesis Committees – Global Master’s

• The Thesis Committee consists of at least three members;
• The thesis advisor chairs the thesis committee; the Chair must be a member of the Graduate Faculty.
• At least two members of the Thesis Committee, including the Chair, must be from St. Jude;
• At least one member of the thesis committee must be a Graduate Faculty at the rank of Associate or Full Member; 
• Only one Adjunct Faculty Member may serve on the thesis committee, but cannot serve as Chair;
• The third member must hold a MSc degree or higher and can be either (1) any member of the Graduate Faculty at any rank, (2) any member from the St. Jude Faculty who is not on the Graduate Faculty, (3) any member of the St. Jude staff that is an expert in the field of study, or (4) a recognized leader in a field relevant to the thesis project as an external expert on the committee from an outside institution. The latter would be classified as a Visiting Instructor (see 80.36);
• A fourth member may be added at any time to provide supplemental expertise by written request of the thesis advisor and with approval of the Dean and Associate Dean; 
• All members of the thesis committee are voting members;
• The thesis committee assists in preparing the project proposal, meets with the graduate student regularly during their second year, assesses student progress via the student’s formal research, concept paper, and proposal presentation, then submits a formal report and recommendations (Biannual Student Progress Form - MSc) to the Dean together with a final copy of the graduate student presentation; 
• After full review of the student’s academic record, and in consultation with the Dean and Associate Dean, the thesis advisor and the thesis committee determine successful completion of the requirements to receive his/her MSc degree;
• After full review of the student’s academic record, and in consultation with the Dean and Associate Dean, the thesis advisor and the thesis committee may determine that the student’s academic progress does not meet the standards required to award a Master’s degree and warrants the student leaving the program. 
• Any requested changes to the thesis committee must be submitted to the Dean and Associate Dean in writing by the Chair with a full explanation for review and approval.

80.25.007 Faculty unable to continue as PhD dissertation advisors

Research Graduate Faculty understand and acknowledge that they are obligated to be dissertation advisors for the duration of their students’ studies, which is typically 4-5 years per student.  The Graduate School does not allow a Research Graduate Faculty member to be considered as a dissertation advisor if he or she is known to, or considering to, leave St. Jude Children’s Research Hospital in the near future.  However, unforeseen events can lead to unanticipated departure of faculty from St. Jude; events include, amongst others, recruitment to another institution, non-renewal of the St. Jude contract following scheduled evaluation of performance, illness and/or death, change in career path, retirement, and dismissal from the institution.  The policies below apply to PhD students in their 2nd – 5th year whose dissertation advisor leaves

80.25.008: Junior Graduate Student Moves with Advisor - Institution Provides PhD Training

• Advisor can invite the student to relocate to the graduate school of that institution:
• This policy will typically apply to students in their 2nd and 3rd years;
• The Graduate School will provide transcripts and other requested information to the new institution, but it is the new institution’s discretion to approve and accept credits;
• The new institution may require the student to meet other mandatory needs of their curriculum; examples include repeating or taking additional coursework and retaking the qualifying examination according to the new institution’s policies and standards;
• The Graduate School provides no financial support or medical benefits for the student.

80.25.009: Junior Graduate Student does not Move with Advisor

• Students in their 2nd and 3rd years who wish to remain at the Graduate School and/or cannot relocate to a graduate school at the advisor’s new institution may select another dissertation advisor from the Research Graduate Faculty;
• The transition should occur quickly to avoid undue delay to the student’s progress;
• A four-week rotation will be necessary if the student has not previously rotated in the new advisor’s laboratory, and a second four-week rotation is allowed if the match proves to be unsuitable;
• If the qualifying examination has been successfully completed, a retake is not necessary;
• If the examination has not been completed, it must be based on the new project and a delay will be granted to allow sufficient time to acquire the necessary knowledge and research data;
• The required NIH grant application will be delayed as necessary;
• A new dissertation committee will be convened.  Members of the original committee may remain on the new committee, but the departing advisor may not continue as a committee member.

80.25.010: Senior Graduate Student Moves but Remains Enrolled in the Graduate School

• If close to completing their PhD, the student is encouraged to apply to relocate to the advisor’s new institution to complete their dissertation research and obtain their PhD from the St. Jude Graduate School;
• Permission must be obtained from the Dean;
• The dissertation advisor is responsible for obtaining permission from the new institution and making the necessary arrangements;
• The student will continue to receive a stipend and health care benefits from the St. Jude Graduate School, but support for supplies and travel will not be provided.  The advisor will be billed at the new institution for these costs;
• The student will keep the formed dissertation committees, return to the St. Jude Graduate School for scheduled committee meetings and defend their dissertation at the St. Jude Graduate School;
• The dissertation advisor must attend the PhD defense, but may participate in committee meetings via teleconferencing with WebEx to review documents and data;
• The dissertation advisor is responsible for dissertation-related travel expenses;
• The dissertation advisor is responsible for required tuition fees at the new institution.

80.25.011: Senior Graduate Student Remains in the Graduate School

• If the student is close to the completion of his or her PhD degree but cannot relocate with their advisor, he or she must identify a member of the Research Graduate Faculty who can facilitate the completion of the PhD in a timely manner:
• The Department Chair and the departing advisor (if available) will play an important role in identifying the most appropriate Research Graduate Faculty member;
• Ideally, the student’s project can continue in the new laboratory and the departing advisor can remain on the dissertation committee and provide mentorship and guidance;
• If that is not feasible, the new project should be closely related to the original project, involving similar techniques, concepts and fundamental mechanisms.  The dissertation committee membership can be modified if necessary;
• If a new project is necessary, data, results and publications from the original project can be included in the dissertation document.

80.25.012: Graduate Student Discontinues Graduate Education

• A student who does not wish to continue their PhD studies upon departure of their advisor can leave the Graduate School with a terminal MS degree;
• The student must have completed all the requirements for the MS degree as described in policy 80.27.001.

80.25.013: Selection of Thesis Advisors – Clinical Investigations

• Students enroll in thesis hours in the third semester of coursework, and during the fourth semester their time is predominantly devoted to researching, writing, and defending the thesis.
• A Thesis Advisor will be selected to oversee the preparation of the thesis.
• The Thesis Advisor will oversee the selection of the Thesis Committee and serve as the Chair of the Thesis Committee.

80.25.014: Thesis Advisors – Clinical Investigations

• The primary Thesis Advisor must be a member of the St. Jude Graduate School Faculty at the rank of Member or Associate Member.
• The Thesis Advisor oversees and directs graduate student research and guides the graduate student to successful acceptance of the thesis for the completion of the MSc CI degree.

80.25.015: Thesis Committees – Clinical Investigations

• All students enrolled in the MSc In Clinical Investigations must submit the Thesis Committee Selection form by May 1 of their first year in the program.
• The Thesis Committee is comprised of at least 3 St. Jude Graduate School faculty members:
  • The primary Thesis Advisor who must hold the rank of Member or Associate Member
  • One representative from the student’s academic field of interest at any faculty rank
  • One epidemiologist or biostatistician from the Department of Biostatistics or the Department of Epidemiology and Cancer Control at any faculty rank
  • Additional members may be added at any time to provide supplemental expertise via a written request from the Thesis Chair and with approval of the Associate Dean(s) and Dean. These members may be extramural from the St. Jude Graduate School.
• All members of Thesis Committee are voting members.
• Students are required to meet at least quarterly with the Thesis Committee during their second year of the program (i.e., 3^rd and 4^th semesters).
• After final approval of the Thesis and a full review of the student’s academic record, and in consultation with the Dean and Associate Dean(s), the Thesis Advisor and Thesis Committee determines the student’s successful completion of the requirements for the MSc degree.
• In situations when the student’s Thesis work as evaluated by the Thesis Committee does not meet the standards required to award the academic degree, the student may revise the submitted work. After discussion with the Thesis Advisor the student may submit for consideration the revised work to the Thesis Committee.
• Any requested changes to the Thesis Committee must be submitted for review and approval to the Dean and Associate Dean(s) in writing by the Committee Chair with a justification for the proposed modifications.

The Graduate School provides a range of academic support programs, services, and activities that are designed to promote student learning and academic success. They enhance the educational and personal development experience(s) of students at all levels, contribute to the achievement of teaching and learning outcomes, and help students to meet their academic goals and requirements.

80.26.001: The St. Jude Biomedical Library and Library Services

The Biomedical Library is an essential Graduate School resource that serves the entire St. Jude research community 24 hours a day, 7 days a week.  The library has a large reference book collection. Books and journal selections represent the ongoing needs and subject areas of research at St. Jude including pediatrics, oncology, infectious diseases, genetics, cell biology, hematology, pharmacology, virology, neurobiology, and global health.  The library staff is available to answer questions in person, by phone, or by email Monday to Friday.  Located adjacent to the Graduate School, the library represents a virtual and actual extension to the school.  Specific services provided to the Graduate School by the Biomedical Library are as follows:

• The library staff has negotiated and will continue to negotiate contracts with journal vendors that allows graduate students full access to journal articles;
• Book chapters and journal articles not available in the library can be obtained from other library collections or commercial vendors upon request via interlibrary loans.  These loans are photocopies that are delivered electronically to the requestor’s desktop;
• The library maintains an ‘Alert Service’ that can deliver a customized monthly listing of bibliographic information directly to a student’s computer or mailbox;
• Maintains a fully comprehensive online service that students can use to browse and search through more than 4,000 different full-text journal titles from their computers;
• Library staff members assist graduate students with customized literature searches. The library’s Web page also supports the graduate student research by providing links to PubMed and other databases;
• Negotiates and maintains the Journal of Visual Experiments (JoVE) resource (see below).

80.26.002: JoVE Scientific Video Journal

JoVE is an online resource that graduate students are granted access through the Biomedical Library and, as with other online resources, its use is limited to enrolled students. JoVE creates and publishes videos of scientific experiments and techniques for STEM education at the graduate and postgraduate level.  The videos originate from top laboratories around the world, are peer reviewed, and PubMed-indexed.  JoVE videos are designed to speed scientific research by teaching advanced techniques to facilitate scientific reproducibility and productivity.  The Graduate School subscription allows its students to have unlimited access to the JoVE System.  Course leaders can consult with JoVE personnel to coordinate videos with lectures.

80.26.003: The Graduate School Textbook and Reprint Library

The Graduate School textbook library is solely for use by the graduate students and the graduate faculty. The textbooks in the library are purchased based on the curriculum and the instructors’ and students’ needs and suggestions to provide access to basic course material and relieve financial burden to the students and faculty.  Rules of use are:

• Requests for new textbooks can be made by the graduate faculty or a graduate student;
• All requests must be approved by the SVP/COO;
• Books must be checked out with the Registrar;

The Graduate School houses the St. Jude Reprint Library, a unique resource of bound copies of every journal article that has been produced by St. Jude Children’s Research Hospital researchers dating from 1962.  The bound copies cannot be removed from the Graduate School. The Reprint Library is formally maintained by the St. Jude Biomedical Library staff.

80.26.004: Postdoctoral Mentoring

Postdoctoral mentors work in conjunction with the graduate faculty and ensure that students understand the course material, complete assignments, and become independent learners.  Mentors work within the following guidelines:

• Students come to the mentoring sessions fully prepared and with appropriate questions;
• A student assignment must be completed by the student independently and not during the mentoring session;
• A mentor cannot complete a student assignment and may only provide guidance and help the student to understand the material;
• A mentor is not responsible for any student’s final grade.
• A mentor can refuse to assist a student who does not attend the mentoring session as scheduled or with the expected level of preparation;

Mentors are chosen by the lecturers and approved by the course leaders and the Associate Dean.  If requested by the lecturer, the mentor may be required to attend the lecture(s) and/or complete the student assignment in advance of distribution to prepare for a mentoring session.

The Registrar schedules mentoring sessions based on information provided by the lecturers and the course leader(s).

Distance learning students may seek mentoring support by contacting the Associate Dean and the respective course leaders.

80.26.005: Specialized Training Courses and Training Opportunities – PhD

• The first-year curriculum is comprehensive and does not specialize in any one topic.  Specialized training begins in earnest in year 2 when the student chooses his/her dissertation advisor and research topic.
• Students may attend specialized training in their 2nd and 3rd years with funding from the Graduate School.
• The Graduate School and/or the dissertation advisor will provide a letter of recommendation to all students who have been approved for advanced training.
• To access advanced training and resources:  The dissertation advisor submits the request, justification, and budget, including travel and accommodation, to the SVP/COO with explanation for the need of the training.  The SVP/COO reviews the request and grants permission for the student to attend the training.

80.26.006: Student Teaching Opportunities – PhD

A Teaching Assistantship (TA) is not required of students in the Graduate School; however, the Graduate School recognizes the benefits of TA experience and are committed to providing this experience.

• A TA may contribute to the development of a graduate student and is consistent with an important goal of the Graduate School to train future academics;
• TA opportunities may include undergraduate teaching at Rhodes College or other local universities, assisting postdoctoral mentors in the Graduate School, and teaching Pediatric Oncology Education (POE) students in the laboratory of the thesis advisor;
• Teaching opportunities do not negate the responsibilities and obligations of the student to his/her graduate academics and research;
• A student may accept TA duties during their 3rd and 4th year in the PhD program;
• A student may not commit to TA duties during the academic year in which he or she expects to defend their dissertation;
• The student must obtain the permission of his/her dissertation advisor and the Dean before seeking a teaching opportunity;
• The dissertation advisor, in consult with the Associate Dean, may reduce the time commitment or suspend TA duties altogether if the student’s academic progress falters;
• The student must abide by the rules and requirements set forth by the Graduate School and the institution where the TA activities will take place;
• A TA must work under the supervision of an experienced faculty member as a means of developing teaching skills in the academic discipline;
• Oversight of the TA is the obligation of the experienced faculty member who is responsible for verifying the appropriate credentials, submitting student evaluations to the Graduate School, and reporting endorsements of and issues with the TAs performance to the Graduate School.

80.26.007: Internships – PhD

The Graduate School supports internships during the student’s training. To ensure the experience is educational and eligible to be considered an appropriate internship for a graduate student, the following criteria must be met:

• The dissertation advisor submits a request to the Dean for a student to apply for an internship with a full description of the host institution, training and experience to be received, and justification for interning at the host institution;
• The host institution provides a letter of support addressed to the Dean;
• The host institution must be in the U.S;
• The scope is fully defined in writing with a stated beginning and end and clearly defined learning objectives and goals related to the student’s academic training;
• Appropriate resources, equipment, and facilities that support the stated learning objectives and goals must be provided by the host institution;
• The Dean may refuse permission at his/her discretion if the internship is deemed to be of limited value to the student’s education;
• The skills or knowledge learned must be transferable to other settings;
• A seasoned professional with expertise and educational and/or professional background in the field of the experience must supervise the intern;
• The student’s advisor must provide routine feedback every two months at a minimum;
• A student may not commit to an internship before his/her fourth year in the program or during the academic year in which he or she expects to defend their dissertation;
• The internship will generally be one semester but may extend for the academic year;
• The student will receive full stipend and health insurance coverage during the internship, and the stipend cannot be supplemented by the host institution;
• Support for student housing will be negotiated between the Graduate School, the dissertation advisor and the host institution, and approved by the SVP/COO;
• An industry internship must be an extension of the research training and may not simply advance the operations of the employer or be the work that a regular employee would routinely perform.

80.26.008: Lecture Recordings

Attendance in all Graduate School lectures are mandatory. If a student is unable to attend a lecture, the student is required to notify the Registrar who, in turn, informs the lecturer.  The student is able to view the lecture recording housed in the LMS. Lectures should be used as learning tools to reinforce and review the lecture content. Lecture recordings are not a substitute for regular attendance at in- person lectures and will capture:

• The lecturer’s voice, PowerPoint presentation, any questions and answers during the lecture, and discussion of papers;
• Examination preparation, review of complex ideas, and clarification to support learning;
• Lecture recordings are only available for enrolled, degree-seeking students of the Graduate School.

80.27.001: Statement of Academic Integrity

• Academic integrity is the pursuit of scholarly activity in an open, honest, and responsible manner. All students shall act with personal integrity; respect other students’ dignity, rights, and property; and help create and maintain an environment in which all can succeed.
• Dishonesty of any kind will not be tolerated. Dishonesty includes, but is not limited to, cheating, plagiarism, and fabricating or falsifying information or citations; facilitating acts of academic dishonesty by others; having unauthorized possession of examinations; submitting work of another person as the student’s own or work previously used without informing the instructor; and tampering with the academic work of other students.
• The Graduate School uses iThenticate to screen documents (including papers, theses, dissertations, etc.) for copied text to ensure originality and the proper use of citations.  iThenticate is an anti-plagiarism software that runs the uploaded document against the world’s top published works and 70+ billion current and archived webpages.

80.27.002: Academic Freedom and Responsibility

• Academic freedom is the unrestricted search for knowledge and truth and its free expression in the academic community. Academic freedom is vital to the acquisition and dissemination of knowledge for the benefit of the faculty, educational officers, students, administrators, the institution, the academic community, and the public. All members of this community must be able to pursue knowledge and express and defend their viewpoints in an atmosphere of mutual respect.
• Persons engaged in research, dissemination of knowledge, and student advisement and advocacy are entitled to full freedom in research and in the publication of the results. Any academic related and creative activities are subject to the Graduate School policies.  Faculty and students are entitled to freedom in the classroom in discussing their subject, maintaining awareness of the relevance of their contribution to the course or to the mission of the Graduate School. Quality education requires a climate of academic freedom and academic responsibility.
• Professional responsibility is the logical correlative of academic freedom. As members of a profession possessing the right of self-government, the academic community has an obligation to define the rights and responsibilities necessary for research and teaching. All members of the academic community are responsible for conducting themselves in ways that will promote the achievement of the purposes for which academic freedom exists.  All members of this community shall be free from institutional censorship and retributive measures in response to exercising academic freedom. Scholars and educational officers shall attempt at all times and in good faith to be accurate, exercise appropriate restraint, show respect for the opinions of others, and clarify that they are not speaking for the institution.

80.27.003: Research Misconduct - Purpose and Scope

• To protect scientific research integrity in the Graduate School and St. Jude and to comply with federal regulatory requirements under 42 C.F.R. Part 93 regarding reporting and investigating allegations of Research Misconduct.
• This policy applies to all research activities conducted under the auspices of the Graduate School and includes but is not limited to “Institutional Members”.
• Entities with which the Graduate School has consortium or contractual arrangements and who receive U.S. Public Health Services (PHS) support through the Graduate School or St. Jude shall have an assurance on file with the Office of Research Integrity (ORI), and internal policies in compliance with 42 CFR 93 regarding procedures for investigating and reporting possible Research Misconduct to ORI.
• The Graduate School and St. Jude have more stringent standards than the narrow definition of research misconduct defined in the federal regulations and may find conduct to be actionable under its standards even if the action does not meet the federal definition of research misconduct.
• Conduct that does not meet ORI’s definition of Research Misconduct but warrants investigation and action by the Graduate School and St. Jude under this policy includes:
  • intentional or reckless disregard for, or significant and substantial departure from accepted research practices, applicable federal regulations, IRB directives on the appropriate and ethical conduct of human subjects’ research, IACUC directives on the appropriate and ethical conduct of animal research, or recognized research ethics;
  • falsification of academic or professional credentials; and
  • submission to journals or research sponsors of work product that contains intentional or reckless material misstatements or omissions. 
• A finding of research misconduct may occur if there is a significant departure from accepted practices at the Graduate School and St. Jude that were committed intentionally, knowingly, or recklessly and proven by preponderance of the evidence.
• Research Misconduct occurring more than six years prior to submission of the allegation will not be investigated unless there is compelling reason to do so, including:
  • the alleged Research Misconduct was not reasonably discoverable at an earlier time;
  • the Respondent has continued or renewed conduct allegedly constituting Research Misconduct that occurred before the six-year limitation; or
  • the Research Misconduct poses a current threat to the health and safety of patients, animals, and/or employees. 

80.27.004: Acronyms and Definitions

• Ad Hoc Committee of Investigation - Senior St. Jude faculty members who the RIO and Deciding Official appoint to examine and evaluate relevant facts and determine whether Research Misconduct has been committed and, if so, by whom.
• Allegation - Any written or oral statement or other communication of possible Research Misconduct made to a Graduate School or St. Jude Official. The four phases of responding to an Allegation are initial assessment, Inquiry, Investigation, and resolution.
• Complainant - An individual who makes an Allegation of Research Misconduct.
• Deciding Official – The individual at St. Jude who makes final determinations on Research Misconduct proceedings and any responsive St. Jude actions.  The Deciding Official at St. Jude is the President and CEO.  He/she may work with the Dean to coordinate actions and responses.
• Good Faith Allegation - A claim of wrongdoing made with the honest belief that Research Misconduct may have occurred.  An Allegation is not in good faith if it is groundless or made with knowing or reckless disregard for information that would negate the claim.
• IACUC - Institutional Animal Care and Use Committee.
• Inquiry - Preliminary information-gathering and initial fact-finding by the RIO and Legal Services in compliance with 42 CFR 93.307-309 to determine whether an Allegation or apparent instance of Research Misconduct warrants an Investigation.
• Institutional Member(s) - A person who is employed by, is an agent of, or is affiliated by contract or agreement with an institution. Here, the institution is the Graduate School, and Institutional Members may include, but are not limited to, graduate students, graduate faculty mentors, research mentors, instructors and staff.
• IRB - Institutional Review Board.
• Investigation - Formal development of a factual record and the examination of that record leading to a decision not to make a finding of research misconduct, or to a recommendation for a finding of research misconduct, which may include a recommendation for other appropriate actions, including administrative actions.
• ORI - The Office of Research Integrity within the U.S. Department of Health and Human Services that oversees and directs Public Health Service (PHS) research integrity activities on behalf of the Secretary of Health and Human Services and the American public.
• Research - A systematic experiment or study to determine the safety and effectiveness of medications, devices, diagnostic products, and treatment regimens intended for human use (clinical research), or to contribute to general and specific scientific knowledge (basic and applied research) relating broadly to public health.  Involves discovering, developing and characterizing the underlying biological mechanism of diseases and their treatments. 
• Research Integrity Officer (“RIO”) - The individual at St. Jude who is responsible for working with the Office of Legal Services (“Legal Services”) to assess Allegations, determine when Allegations warrant an Inquiry, and if there is sufficient evidence of potential Research Misconduct to warrant an Investigation. The RIO oversees Inquiries and Investigations. The Deciding Official appoints the RIO for St. Jude.
• Research Misconduct - is defined by the ORI regulations as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Research misconduct does not include honest error or differences of opinion.
  • Fabrication is making up data or results, and recording or reporting them;
  • Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record; and
  • Plagiarism is the appropriation of another person’s ideas, processes, results, or words without receiving permission and not giving appropriate credit to the creator.
• Respondent - The person(s) against whom an Allegation of Research Misconduct is directed or the person(s) whose actions are the subject of an Inquiry or Investigation. 
• Retaliation - An adverse action taken against a Complainant, witness, or Committee member by members of the Graduate School and/or St. Jude in response to a Good Faith Allegation of Research Misconduct, or good faith cooperation with a Research Misconduct proceeding.
• St. Jude Official – A St. Jude member with the authority to respond to Allegations of Research Misconduct.  Such officials include the President and CEO, Research Integrity Officer, members of Legal Services, and Compliance Office (“Compliance”).

80.27.005: Policy

Research Misconduct issues involving the Graduate School will be investigated by St. Jude officials. The Research Integrity Officer (RIO) at St. Jude is responsible for assessing Research Misconduct Allegations, determining when Allegations warrant Inquiries, recommending Investigations or administrative actions based on inquiry conclusions, and overseeing Inquiries and Investigations. The Deciding Official appoints the RIO for St. Jude. The RIO works with Legal Services, Compliance, and Human Resources to implement the institution’s Research Misconduct policies and procedures. At his/her discretion and as dictated by the circumstances, the RIO will inform the Dean, SVP/COO and relevant Associate Dean of the investigation, how it is proceeding and if any information is required from the Graduate School.

80.27.006: Procedure

The procedures and conditions of Research Misconduct proceedings at St. Jude are fully described in policy 70.05.001.      

• Reporting Misconduct Allegation
  • When reporting a misconduct allegation, the reporting individual should provide the following: complainant’s name and contact information, a clear description of the problem or complaint, appropriate supporting documentation that is directly related to the complaint, a description of any subsequent actions taken by the complainant or the institution, and a description of the desired outcome;
  • If an individual is unsure whether a suspected incident falls within the definition of Research Misconduct, he or she may confidentially and informally consult the RIO about the suspected misconduct;
  • An individual who is not comfortable bringing his or her concerns to the RIO may direct those concerns to any St. Jude or Graduate School Administrator, who is then required to immediately and confidentially forward the Allegation to the RIO;
  • Institutional Members shall report suspected Research Misconduct to the RIO, a St. Jude Official or the SVP/COO.  When an Official or the SVP/COO receives an Allegation, he or she shall notify the RIO immediately; and
  • The RIO will accept any Allegation, discuss the circumstances with Legal Services and Compliance, if the Allegation requires investigation by or input from Compliance, and respond to the individual.
• Research Misconduct Initial Review and Inquiry
  • A respondent has a right to a thorough, competent, objective, and fair response to Allegations of Research Misconduct;
  • Complainant, respondent, and witness(es) interviews shall take place privately and may be recorded;
  • If after the initial review of the alleged facts, or after the Inquiry, the RIO  and Legal Services determine that circumstances described do not meet the definition of Research Misconduct, the RIO will refer the individual or concern to the SVP/COO for resolution of the concern in consultation with the Dean and appropriate Associate Dean;
  • If an Allegation is not made in good faith, the RIO and Legal Services will work with the SVP/COO, the Complainant’s advisor, HR, and other individuals as appropriate to determine if disciplinary action should be implemented; 
  • If after the initial review of the alleged facts, the RIO and Legal Services determine that the Allegation is sufficiently credible and specific and an Inquiry is warranted, the RIO shall notify the Respondent in writing immediately. If the Inquiry results in facts that require further scrutiny, the RIO will recommend to the Deciding Official that an Investigation should be conducted;
  • An Inquiry shall be completed within 55 calendar days of the initial Allegation, unless circumstances warrant a longer period;
  • The RIO will take custody of the research records, review the evidence, and prepare and submit an Inquiry Report to the Respondent and Deciding Official. The Respondent will have five (5) calendar days to review the report and submit a response to the RIO; and
  • After reviewing the Inquiry Report and Response, the Deciding Official will determine within 30 calendar days of receiving the Report whether the evidence warrants an Investigation, even if the Complainant does not wish to pursue the Allegation.
• Ad hoc Committee of Investigation
  • The RIO and Deciding Official appoint the Committee. The Committee consists of senior St. Jude faculty members with appropriate scientific expertise, and who do not have unresolved personal, professional, or financial conflicts of interest with those involved with the Inquiry or Investigation (RIO, Complainant, Respondent, witnesses);
  • The Dean and SVP/COO may be asked to comment on the Committee membership to identify potential conflict of interest issues within the Graduate School;
  • The Deciding Official appoints the Committee Chair, who is responsible for maintaining a detailed record of the Committee’s actions;
  • During the Investigation, St. Jude will take necessary action to protect public health and safety, federal funds, the research integrity process, and reputations; and
  • Upon conclusion of the Investigation, the Committee will write its findings in an Investigation Report, which is provided to the Deciding Officer and Respondent. The Respondent may write a rebuttal within 30 calendar days of receiving the Committee’s Report for the Committee to consider. The Committee may modify its findings in an Addendum to the Report based on new facts provided in the Respondent’s Response. The Committee may recommend administrative actions to the Deciding Official. The Report, Response, and Addendum, and recommended administrative actions are provided to the Deciding Official for final determination, and to ORI according to federal regulations;
  • Duty to Cooperate with Research Misconduct Proceedings.  Institutional Members are required to participate in Research Misconduct proceedings and shall provide relevant evidence of the Allegations to the RIO and Legal Services. If an Institutional Member refuses to cooperate according to this policy and its related procedures, the Deciding Official may impose disciplinary actions, up to and including termination from employment at St. Jude.
• Protection of the Complainant, Respondent, and Others
  • Disclosure of the identity of Respondents, Complainants, and records or evidence from which research subjects might be identified in Research Misconduct proceedings is limited, to the extent possible, to those who need to know, consistent with a thorough, competent, objective, and fair Research Misconduct proceeding, and as allowed by law. Provided, however, that St. Jude must disclose the identity of Respondents and Complainants to ORI.  The rights and reputation of Respondents, Complainants, and research subjects identifiable from research records or evidence, and all other parties involved in Research Misconduct proceedings shall be protected throughout the proceedings, to the extent possible without compromising public health and safety.  Legal Services will work with the RIO and institutional leadership during an Inquiry and an Investigation to determine how best to share information and findings with necessary agencies and parties, and with the Graduate School;
  • St. Jude prohibits retaliation for making an Allegation. In accordance with institutional policy 70.01.006 “Non-retaliation for Reporting Suspected Non-Compliance,” no one shall suffer Retaliation for making an Allegation in good faith or for providing evidence or testimony during Research Misconduct Proceedings. The RIO and Legal Services will verify that an Allegation is made in good faith;
  • Respondent has a right to an Advisor. At Respondent’s request and faculty’s consent, a St. Jude faculty member in good standing and with no conflicts of interest in the matter may act as an advisor to a Respondent, and with notice to the RIO may accompany the Respondent as an observer of interviews or meetings where the Respondent’s presence is requested or required;
  • The advisor can be a member of the Graduate Faculty or the Graduate School staff;
  • If at any time during a Research Misconduct Proceeding, information is obtained that reasonably indicates that criminal violations may have occurred, the RIO must notify Legal Services within 24 hours. Legal Services will assess alleged criminal or civil violations on a case-by-case basis to ascertain relevant facts and determine the best course(s) of action. If the violations are likely to have occurred, Legal Services and the RIO will notify ORI, and any other appropriate parties (such as a funding agency or law enforcement), as appropriate; and
  • Resolution of an Investigation by the Deciding Official may include a finding that administrative action is necessary and a retaliation prevention plan for Committee members, witnesses, and Complainant(s) is needed. If no Research Misconduct is found, a plan to restore the Respondent’s reputation shall be developed.
• Administrative and/or Disciplinary Actions for Findings of Research Misconduct
  • If the Deciding Official determines that the alleged Research Misconduct is substantiated, he/she will decide on the appropriate administrative or disciplinary actions to be taken with the Respondent, up to and including termination from employment at St. Jude. The RIO will notify and make reports of those actions, and any documentation needed to restore the scientific record, to ORI and other parties and agencies as required;
  • If the Deciding Official determines that an Allegation was not made in good faith, he/she will decide on the appropriate administrative or disciplinary actions to be taken with the Complainant, up to and including termination from employment at St. Jude; and
  • The final report and disciplinary action will be provided to the Dean for independent Graduate School actions.  The Dean, SVP/COO and appropriate Associate Dean will decide on the disciplinary action up to and including termination from the Graduate School.
• Record Retention
  • Regardless of the outcome, after completion of a Research Misconduct Investigation and related actions, the RIO and Legal Services will prepare a complete file, including the records of the Inquiry and Investigation and copies of all transcripts, documents, and other materials furnished to the RIO or the Committee (the “Records”), and will transfer the Records to the Office of Legal Services for retention;
  • The Records shall be retained in a secure manner for seven years;
  • ORI and other authorized government personnel will be given access to the Records as required by law and in accordance with applicable St. Jude policies; and
  • The Dean and SVP/COO will be given access to the Records as necessary.

There are four categories of Graduate Faculty in the Graduate School, each with expectations and restrictions regarding graduate student teaching and mentoring, and graduate school administrative participation.  All members of the Graduate Faculty must:

• Participate in graduate student teaching in his/her area of specialty;
• Assist in recruiting students to the Graduate School and promoting the Graduate School to potential applicants and educational institutions;
• Be approved by the Tennessee Higher Education Commission (THEC);
• Hold a degree equal to or higher than the degree course being taught.

80.30.001: Research Graduate Faculty

• St. Jude Research Faculty at the rank of Assistant Member, Associate Member, or Member;
• Directs an independent research program at St. Jude; and
• Holds a PhD, MD, MD/PhD, or equivalent degree.

80.30.002: Clinical Graduate Faculty

• Member of the St. Jude Clinical Faculty at the rank of Assistant Member, Associate Member, or Member;
• Participates in patient care and treatment at St. Jude;
• Leads St. Jude clinical research programs; and
• Holds an MD, MD/PhD, or equivalent degree.

80.30.003: Graduate Educator

• Member of the St. Jude Faculty at the rank of Research Associate, Instructor, Assistant Member, Associate Member, Member, or Emeritus; or
• Member of St. Jude staff overseeing research, clinical, or educational programs and activities at St. Jude.  Examples include Core Directors, Laboratory Directors, Program Leaders, and Clinical Directors;
• May direct an Independent Research, Clinical or Policy Research program at St. Jude;
• Holds a PhD, MD, MD/PhD or equivalent degree to teach in the PhD program; or
• Holds a master’s degree or equivalent or higher to teach in the Master’s programs.

80.30.004: Adjunct Graduate Faculty

• Graduate Faculty member from outside institutions who contributes to the teaching and mentoring within the Graduate School;
• From a university, medical school or equivalent, must be at the Lecturer, Senior Lecturer, Assistant, Associate or Full Professor level or equivalent;
• From industry or government institutions or equivalent, must occupy a leadership position and either direct a research group and/or oversee a program;
• Can be retired or have Emeritus status;
• Can be an individual from a non-US institution.

80.30.005 Full- and Part-Time Graduate Faculty Status

• Full-time graduate faculty status is granted to those faculty who
  • Serve as a course leader;
  • Teach courses in their area of expertise;
  • Supervise a student’s PhD dissertation/MSc thesis research; and/or
  • Serve on Graduate School committees, including student dissertation and thesis committees as well as on the Graduate School’s standing committees.
• Part-time graduate faculty status is granted to those faculty who make significant contributions through teaching, supervision of MSc thesis research and other service to the Graduate School, but who are not yet qualified to serve as the research advisor for PhD students.
  • All adjunct faculty are considered part-time faculty but may serve as course leaders.

All members of the Graduate Faculty must participate in the activities of the Graduate School.  Graduate Faculty must be willing to devote the necessary time to ensure, (1) the academic success of the students, and (2) the development and growth of the Graduate School.

80.31.001: Research Graduate Faculty

• Teach graduate students their relevant subject matter or expertise;
• Periodically serve as a course leader;
• Accept first-year PhD students for laboratory rotations;
• Accept a PhD graduate student into the laboratory and serve as a dissertation advisor;
• Accept a Masters student for a thesis project and serve as a thesis advisor;
• Serve on other graduate student dissertation and thesis committees;
• Serve on Graduate School administrative committees, notably the Graduate Council, the Curriculum Committees, and the Admissions Committees;
• Participate in two-person Scholastic Oversight Teams that mentor PhD students during their first year in the program;
• Attend Graduate Faculty meetings;
• Attend mandatory Graduate Faculty training courses.

80.31.002: Clinical Graduate Faculty

• Teach graduate students their relevant subject matter or expertise;
• Periodically serve as a course leader;
• Serve on PhD dissertation committees but not as the advisor;
• Serve as a Masters thesis advisor and/or committee member;
• Contribute to the Topics in Clinical and Translational Research PhD course;
• Serve on Graduate School administrative committees, notably the Graduate Council, the Curriculum Committees and the Admissions Committees;
• Participate in two-person Scholastic Oversight Teams that mentor PhD students during their first year in the program;
• Attend Graduate Faculty meetings;
• Attend mandatory Graduate Faculty training courses.

80.31.003: Graduate Educator

• Teach graduate students their relevant subject matter or expertise;
• Serve as course leaders for the Masters in Global Child Health Program;
• Serve on graduate student thesis and/or dissertation committees; may serve as a Masters thesis advisor;
• Serve on Graduate School administrative committees, notably the Graduate Council, the Curriculum Committees, and the Admissions Committees;
• Participate in two-person Scholastic Oversight Teams that mentor PhD students during their first year in the program;
• Attend Graduate Faculty meetings;
• Attend mandatory Graduate Faculty training courses.

80.31.004: Adjunct Graduate Faculty

• Teach graduate students their relevant subject matter or expertise;
• Serve as course leaders if required to do so;
• Serve on graduate student thesis and/or dissertation committees but not as their dissertation advisor;
• Attend Graduate Faculty meetings if available;
• Attend mandatory Graduate Faculty training courses.

80.31.005: Legal Obligations

• Graduate School Faculty Members have a legal responsibility under the Student Privacy Policy to protect the confidentiality of student education records. A Faculty Member may have access to student information only for legitimate use in the completion of their responsibilities as a Faculty Member.
• Student education records are considered confidential and therefore Faculty Members may not release any student records or identifiable student information to anyone outside of the Graduate School (including family members, other institutions, etc.) without written consent from the student.
• Faculty Members should consult the Graduate School Registrar with any questions.

• All members of the Graduate Faculty are formally defined as ‘Instructors’;
• Instructors are classified as ‘Full Time’ or ‘Part Time’ depending on their level of contribution to the Graduate School;
• Prior to applying to THEC, the Dean and the GFARC (see 80.33.001) will determine Full Time or Part Time status of an applicant depending on the expected level of contribution to the Graduate School.  Level of contribution will be judged by the candidate’s GFARC application (see 80.33.002);
• Full Time or Part Time status will be reviewed annually by the Dean and the GFARC, and modified as necessary. 

80.33.001: General

• Research Graduate Faculty, Clinical Graduate Faculty and Graduate Educators are employed by St. Jude Children’s Research Hospital and leased to the Graduate School.  They receive no financial compensation from the Graduate School;
• Adjunct Graduate Faculty are not employed by St. Jude Children’s Research Hospital.  They cannot be considered for membership of the St. Jude Children’s Research Hospital Faculty at any level. They are eligible to receive financial compensation from the Graduate School for teaching and mentoring contributions;
• All appointments and reappointments to the Graduate Faculty must be reviewed and approved by the Graduate Faculty Appointments and Reappointments Committee (GFARC);
• All appointments to the Graduate Faculty must receive final approval from the Dean.

80.33.002: Research Graduate Faculty, Clinical Graduate Faculty and Graduate Educator

• St. Jude faculty and staff who meet the criteria described in 80.30 may request Graduate Faculty status;
• Requests to join the Graduate Faculty must be made by submitting the Graduate Faculty Initial Appointment Form, a curriculum vitae, and the Alternative Credentials form, if applicable, to the Coordinator of the Graduate School.  The information will provide the basis necessary to evaluate the applicant’s qualifications and include (1) the type of Graduate Faculty position being sought (Research, Clinical, or Educator); (2) the specific contributions that the applicant will make to the Graduate School; (3) how the applicant being Graduate Faculty will benefit the Graduate School and the graduate students; and (4) the applicant’s acceptance of the duties and expectations for the position being sought.  The initial appointment form requires the approval of the applicant’s department chair;
• The applicant must request an official transcript for the terminal degree be sent directly to the Graduate School;
• Requests to join the Graduate Faculty are reviewed by the Graduate Faculty Appointments and Reappointments Committee (GFARC), which submits a recommendation to the Dean;
• The Dean approves Graduate Faculty status and reserves the right to decline a request;
• Final approval is required by THEC;
• Must sign the Media Consent form that defines how they and the Graduate School may use and distribute all teaching material;
• Appointments are for three years and can be renewed following GFARC review and approval.

80.33.003: Adjunct Graduate Faculty

• Requests must be made by the relevant Associate Dean using the GFARC Adjunct Graduate Faculty Appointment Form.  The request must include (1) the applicant’s CV, (2) a description of the contribution that will be made to teaching and mentoring, and (3) a completed Alternative Credentials form if the applicant does not hold a terminal degree or if additional credentialing is required;
• If employed full-time, signed permission to participate is required from the employer;
• Requests must initially be approved by the Dean of the Graduate School, and the President and CEO of St. Jude Children’s Research Hospital;
• If approved, the application is then passed to the GFARC for review and approval;
• Upon GFARC approval, the applicant will then be submitted for THEC approval;
• Financial compensation for contributions to teaching will be calculated and approved by the SVP/COO;
• Must sign the Adjunct Graduate Faculty Agreement form, the Content Development form (if applicable), and the Media Consent form that defines how they and the Graduate School may use and distribute all teaching material;
• Appointments are for three years and can be renewed following GFARC review and approval.

80.33.004: THEC Requirements

• Once approved, all Graduate Faculty applicants must submit official transcripts to the Coordinator of the Graduate School for THEC certification;
• The applicant must complete the ‘Application for School Personnel’ form for THEC certification.  The Dean will sign the application and forward it to THEC;
• The applicant will become a member of the Graduate Faculty only when THEC grants approval;
• If a transcript and/or certificate is not attainable for an applicant with a non-US degree, the Graduate School will require documented proof from a recognized US authority (such as the World Education Services) stating that the applicant’s degree is equivalent to the same degree offered by a US institution. 

80.33.005: SACSCOC Requirements for Faculty Credentials

The Graduate School is committed to granting graduate faculty status to qualified faculty members to carry out the mission of the institution and meet the standards required by the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC). Academic credentials (i.e. earned degrees) are the most important qualification for faculty; however other types of qualifications may prove to be appropriate. All graduate faculty (Research Graduate Faculty, Clinical Graduate Faculty, Graduate Educator, and Adjunct Graduate Faculty) must have the appropriate credentialing to teach a course in the Graduate School. The appropriate credentialing and process of justification and documentation are outlined in this policy.

Per SACSCOC Standard 6.2.a (2018 version): For each of its educational programs, the institution justifies and documents the qualifications of its faculty members.

Per SACSCOC Faculty Credential Guidelines: When an institution defines faculty qualifications using faculty credentials, institutions should use the following as credential guidelines: Faculty teaching graduate and post-baccalaureate coursework must have an earned doctorate/terminal degree in the teaching discipline or a related discipline.

Table 1 provides a quick reference guide for faculty credentialing.

Qualifications: Graduate faculty members must meet requirements in this faculty credentialing policy.  Associate Deans are responsible for ensuring all faculty meet the credentialing requirements of program accrediting agencies. All faculty – Research Graduate Faculty, Clinical Graduate Faculty, Graduate Educator, and Adjunct Graduate Faculty – must meet the faculty qualification standards.  This includes instructors who teach in-person and online.

Terminal Degrees: For purposes of credentialing, the PhD is the terminal degree required by SACSCOC to teach at the graduate level. However, the following doctoral‐level degrees relevant to the biomedical sciences are also considered the terminal degree:

• Doctor of Business Administration (DBA)
• Doctor of Education (EdD)
• Doctor of Engineering/Engineering Science (DEng/DESc/DES)
• Doctor of Nursing Practice (DNP)
• Doctor of Nursing Science (DNSc)
• Doctor of Psychology (PsyD)
• Doctor of Public Health (DPH, DrPH)
• Doctor of Science (DSc/ScD)
• Doctor of Social Work (DSW)
• Juris Doctor (JD)

The following relevant master’s degrees are considered the terminal degree in their respective disciplines:

• MLIS, MLS, MSLS, MSIS ‐ Master of Library and Information Science, Master of Library Science, Master of Science in Library Science, Master of Science in Information Science 
• MSW, MSSW ‐ Master of Social Work, Master of Science in Social Work

Alternative Qualifications (per SACSCOC guidelines): In some circumstances, individuals may request graduate faculty membership based on alternative qualifications if one of the following two standards are met: 

• The faculty member has a record of demonstrated, long-term professional experience (including scholarly publications and presentations) and/or professional licensure (where applicable).
• The faculty member has formal academic training in a closely related discipline, and the faculty member is requesting approval to teach a course with competencies directly related to the faculty member’s trained discipline.  

Certification of Qualifications: Requests are considered on a course-by-course basis by completing and submitting the Alternative Qualifications form and supporting documents (e.g. official transcript, curriculum vitae, certificates, and licenses) to the Associate Dean.  The Associate Dean will forward the completed Alternative Qualifications form and supporting documents to the Graduate Faculty Appointments and Reappointments Committee (GFARC – see policy 80.37) for review, who will provide a recommendation to accept or reject the request to the Dean.  Formal approval of an alternative qualifications request can only be given by the Dean.  

Faculty Credential Records Requirements: The Graduate School maintains a record of faculty credentials for every faculty member in the Graduate School Operations Coordinator’s office, including an official transcript for the terminal degree, and may include any other relevant degrees, such as master’s and bachelor’s degrees, a curriculum vitae, and any supporting credentialing documents, including certificates and licenses. For purposes of accreditation, transcripts are considered official only if they are sent directly from or on behalf of the granting institution to the Graduate School.

Annual Review of Credentials: Annually, the Dean requires all faculty to submit an updated curriculum vitae and ensure current certifications and licenses are on file with the Graduate School Operations Coordinator.

Faculty Rosters: The Faculty Roster is a SACSCOC required report listing (1) all courses and workshops held during the academic year, (2) instructor of record for each, and (3) the instructor’s credentials, including information justifying the instructor’s credentials for the specific courses and workshops.  Associate Deans are required to submit an approved Faculty Roster form and syllabi to the Graduate School Operations Coordinator no later than 30 days prior to the start of the upcoming fall and spring semesters and summer and winter intersession workshops.  The form should include all full-time and part-time faculty. The faculty rosters will be maintained internally to ensure compliance.

Linked documents: Alternative Qualifications form, Faculty Roster form

80.34.001: Ongoing Evaluation

• At the beginning of each course, each Graduate Faculty will receive the guidelines by which they will be evaluated by the course leader and students using an online course evaluation solution. The course leader will provide an evaluation of each Graduate Faculty at the conclusion of the course. This evaluation is based on the individual as a Graduate Faculty member and as a part of the overall course. 
• At the conclusion of the course, each student is required to evaluate the Graduate Faculty against a considered and appropriate series of questions and provide an assessment; space is allocated for expanded comments.
• Once both evaluations have been completed, the data will be compared for gap analysis and student/faculty perception. Data from the evaluation is provided to the Graduate Faculty member, the course leader, the Associate Dean and the Dean. The results are used to improve the overall program by:
  • Promoting excellence in the teaching/learning process;
  • Meeting the educational needs of students and community by continually monitoring instructional performance;
  • Providing a constructive framework for evaluating Graduate Faculty performance by identifying areas of strength and areas for improvement in classroom instruction; and
  • Providing a basis for professional growth and development.
• The Dean and relevant Associate Dean will make recommendations of improvement to specific Graduate Faculty members, as needed.
• The Curriculum Committee of each program will review faculty and course evaluation data annually and pass along to Grad Council for further review.  

80.34.002: Three-Year Evaluation

The performance of each member of the Graduate Faculty will be formally reviewed every three years by the GFARC, and the reports will be forwarded to the Dean for appropriate action.  Factors that will be assessed in the review and may be grounds for dismissal if deemed unsatisfactory are as follows:

• Continuing membership of the St. Jude faculty;
• Contribution to graduate student teaching;
• Contribution to graduate student mentorship;
• Participation in mandatory training and professional development;
• Willingness to accept graduate students for laboratory rotations;
• Willingness to assist graduate students in their thesis projects;
• Willingness to be dissertation and thesis advisors;
• Participation in graduate student events, graduate school promotion, and graduate student recruitment;
• Service on Graduate School committees;
• Abiding by the rules of the Graduate School and its Policies & Procedures; and
• Professional conduct.

Guest lecturers are ad hoc experts from other institutions who can enrich graduate student training.  Also, St. Jude has many guest lecturers who are willing to contribute to the education of the students via lectures, workshops, and informal discussions.  Guest lecturer participation in the Graduate School activities are governed by the following:

• Hold a PhD, MD, MD/PhD or equivalent degree to provide instruction in the PhD program;
• Hold a master’s degree or higher to provide instruction in the Master’s program;
• Not members of the Graduate Faculty and do not require THEC approval;
• The Dean, relevant Associate Dean and the SVP/COO review and approve Visiting Instructors;
• Cannot be a member of Graduate School committees;
• Can be members of dissertation and thesis committees;
• Must sign the Media Consent form that defines how they and the Graduate School may use and distribute all teaching material;
• Receive honoraria from the Graduate School for participation in lectures, but not for membership of dissertation or thesis committees.

80.36.001: Mission

The Graduate School delegates certain powers and responsibilities, with respect to graduate education, to the Graduate Council.  The Graduate Council represents the Graduate School faculty and the St. Jude Children’s Research Hospital senior administration in the consideration of policies and procedures that affect the academic environment, student services, and the direction of the Graduate School. The Graduate Council seeks to preserve and protect a Graduate School climate that promotes scholarship, innovation and discovery, and embraces the Mission, Values and Vision of the Graduate School.

80. 36.002:  Guiding Principles

• Governance procedures are consistent with the requirements of the Graduate School, St. Jude Children’s Research Hospital, the Tennessee Higher Education Commission (THEC), the Tennessee Student Assistance Corporation, and the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC);
• Governance procedures incorporate appropriate representation from the leadership and multiple disciplines at St. Jude Children’s Research Hospital;
• The governance process encourages continuous improvement;
• Processes leading to decision-making are based on open discussion, transparency, shared governance, and iterative consensus development.

80.36.003: Roles and Responsibilities

• The Graduate Council’s duties are to set policy for the Graduate School in accordance with the Operating Agreement. Such policy includes:
  • The review and approval of new or substantively revised graduate courses;
  • The review of, and recommendation to, the Board of Trustees of any new proposal for a graduate degree program, program track and/or graduate certificate program to ensure consistency with existing programs;
  • Periodically review the programs and their curricula to make appropriate recommendations for their revision, continuation, deactivation, or termination;
  • Establish general standards for graduate student admission and for the satisfactory completion of advanced degrees;
  • As it relates to graduate education, undertake other functions and responsibilities it may deem appropriate as formally requested by the Dean of the Graduate School.
• At least once every two (2) years, the Graduate Council shall review each graduate degree  program in consultation with the Dean.  The aim of the review is to assess the effectiveness of the curriculum of each graduate degree program in achieving its goal, and to make recommendations for improvement.  A subcommittee of the Graduate Council, based on expertise in the subject matter, will be formed to conduct each review and each subcommittee can be expanded to include relevant graduate faculty as required.  Each degree program will be asked to prepare a report of their program’s progress, vision for the future, and student outcomes.  The subcommittee will summarize the reviews for the Graduate Council to discuss and make recommendations to the Dean regarding the changes envisioned for each degree program. The following checklist will be used as programs prepare for their Graduate Council reviews:
  1. Description of the degree program (from web or handbook)
  2. Brief statement of mission, goals and objectives
  3. Milestones of the program
  4. Syllabi for courses
  5. Results of student surveys including course evaluations
  6. Description of survey(s) and other tools utilized to solicit feedback
  7. Executive summary

80.36.004: Membership

The Graduate Council consists of thirteen (13) voting members and seven (7) ex-officio members.

• Standing Members (8 total):  The Dean of the Graduate School, the President and Chief Executive Officer of St. Jude Children’s Research Hospital, the Executive Vice President and Scientific Director, the Executive Vice President and Chair of Global Pediatric Medicine, the Executive Vice President and Clinical Director, the PhD Program Associate Dean, the MSc Global Child Health (GCH) Program Associate Dean, and the MSc Clinical Investigations (CI) Program Associate Dean;
• Rotating Members (5 total): Four (4) select Graduate School faculty and one (1) Graduate School student shall be rotating members of the Graduate Council.  The group of four (4) faculty comprises one (1) PhD faculty, one (1) MSc GCH faculty, one (1) MSc CI faculty, and one (1) faculty from any of the three programs. The President of the Graduate Student Association (GSA) is the student member;
  • The maximum term of membership of the Rotating Members of the Graduate Council shall be two (2) years. Terms will be staggered so that two Rotating Members are appointed each year.
  • The Graduate School faculty shall hold an election in the May faculty meeting preceding the academic year to select two (2) new Rotating Members. 
  • Consecutive terms are not allowed, but former Rotating Members can serve again after a two (2) year break.
  • The President of the GSA will rotate each year with the election of a new President.  The Vice President of the GSA will attend (and vote) if the President is unable to attend.
• Ex-officio Members (7 total): The SVP/COO of the Graduate School, the Assistant Dean of the PhD program, the Assistant Dean of the MSc GCH program, the Assistant Dean of the MSc CI program, the Coordinator of Graduate School Operations (who records the minutes), the Registrar, and the Senior Counsel from the Office of Legal Services.  The Ex-Officio Members are non-voting members;
• The Dean of the Graduate School will Chair the Graduate Council.  On an annual basis, the Chair will make a report to the Graduate Faculty of the school’s activities during the preceding year.  This report will first be reviewed and approved by the Graduate Council. 

80.36.005: Meetings

• Meetings shall be held monthly;
• Meeting agendas (including date, time, and location) and any supporting materials shall be prepared by the Chair and distributed to the Graduate Council Members at least seven (7) business days in advance of the meeting. Any member of the Graduate Council may have an item placed on the agenda by submitting a written request to the Chair ten (10) business days in advance of the meeting;
• Special Meetings may be called by the Chair or by petition of a majority of the members of the Graduate Council.  Notices of Special Meetings will be sent at least seven (7) business days prior to the event and will state the purpose of the meeting;
• Meetings can only be attended by Graduate Council Members.  Guest participants will only be included with an invitation from the Chair;
• A quorum is defined as having participation from at least 50% of the voting members.

80.36.006: Voting Privileges and Procedures

• All Standing and Rotating Graduate Council Members, as defined above, are eligible to vote;
• Votes may take place in-person, virtually, or electronically, during a meeting or as a stand-alone event;
• A positive vote of more than half of present voting members is required to pass a measure;
• Voting via proxy is not permitted.

80.37.001: Mission

The GFARC shall have the responsibility of reviewing applicants for an initial appointment to the Graduate School Graduate Faculty and reviewing existing Graduate Faculty for reappointment.  Graduate Faculty members have clearly defined expectations (80.31), and the GFARC ensures that these expectations and obligations will be undertaken by newly appointed Graduate Faculty and continue to be undertaken through reappointed Graduate Faculty.  A key goal of the GFARC is to align the missions and strategic plans of the Graduate School, St. Jude Children’s Research Hospital, and the participating basic research, global, and clinical departments.

80.37.002: Guiding Principles

• Governance procedures are consistent with the requirements of the Graduate School, St. Jude Children’s Research Hospital, the Tennessee Higher Education Commission (THEC), the Tennessee Student Assistance Corporation and the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC);
• Governance procedures incorporate appropriate representation from multiple disciplines at St. Jude Children’s Research Hospital;
• The governance process encourages continuous improvement of the review process;
• Processes leading to decision-making are based on open non-biased discussion, transparency, shared governance, and iterative consensus development;
• Reviews of existing and potential Graduate Faculty are not influenced by any political, financial, religious, sexual, personal or nepotistic factors.

80.37.003: Roles and Responsibilities

• Review Graduate Faculty applications and recommend acceptance/rejection/probation to the Dean.  If acceptance is recommended, advise the Dean on whether the appointment should be full-time or part-time (80.30.005).  Successful applications will be forwarded to THEC for approval through the Coordinator of Graduate School Operations.  An important component of the application is the proposed involvement in the student teaching and mentoring, which must be clearly described and realistic;
• Review existing Graduate Faculty every three years for continuing membership and report the recommendation for continued appointment to the Dean. If continuing membership is recommended, advise the Dean on full-time or part-time status.  If the status is changed, the Coordinator of Graduate School Operations will inform THEC.  Factors to be considered include but not limited to are:
  • Participation in didactic activities.
  • Participation in clinical teaching and/or shadowing.
  • Functioning as a Course Leader.
  • Contributing as a Scholastic Oversight Team member.
  • Participation in Graduate School committees.
  • Dissertation Advisor (PhD).
  • Thesis Advisor (MSc).
  • Dissertation committee(s) member (PhD).
  • Thesis Project committee(s) member (MSc).
  • Hosting student laboratory rotations (PhD).
  • Active participation in student recruitment.
  • Attendance at student presentations (poster sessions, workshops, journal clubs, etc).
  • Attendance at Graduate Faculty meetings.
  • Attendance at Graduate Faculty training sessions.
• Review external applications for Adjunct Graduate Faculty appointments. The proposed role must be fully described, and documented support from the relevant Associate Dean is mandatory.  See 80.33.003 for more details;
• Make recommendations to the Dean as to the review process to continually improve the procedure of selecting Graduate Faculty;
• Prepare summary reports for the Dean and the Board of Trustees as requested.

80.37.004: Membership

The GFARC consists of seven (7) voting members.

• The Dean will appoint the Chair of the GFARC who must be at the Full Member faculty level at St. Jude Children’s Research Hospital;
• There are six (6) additional members who must be at the Full or Associate Member faculty level at St. Jude Children’s Research Hospital and selected in the following manner: two (2) by the Dean and the Chair; two by the Graduate Faculty by vote; two by the President and CEO of St. Jude Children’s Research Hospital or his/her designee;
• The SVP/COO and the Institutional Researcher of the Graduate School are ex-officio non-rotating members and are non-voting. 

The term limit for the Chair is four (4) years and three (3) years for members.  Consecutive terms are not allowed, but former members can serve again after a two (2) year break.

80.37.005: Meetings

• Meetings shall be held at regular intervals as determined by the Dean and the Chair;
• Meetings can only be attended by GFARC members; 
• Meeting agendas (including date, time, and location) and supporting materials shall be prepared by the Dean, SVP/COO and Institutional Researcher, and distributed to GFARC members at least five (5) business days in advance of the meeting;
• Special Meetings may be called by the Chair, the Dean, the President and CEO of St. Jude, or by petition of a majority of members of the GFARC.  Notices will be sent by the SVP/COO at least three (3) business days prior to the event and will state the purpose of the meeting.
• A quorum is defined as having participation from at least 50% of the voting members.

80.37.006: Voting Privileges and Procedures

• Votes may take place in-person, virtually, or electronically, during a meeting or as a stand-alone event;
• A vote of more than half of present voting members is required to pass a measure;
• Voting via proxy is not permitted. 

80.38.001: Mission

The Curriculum Committee for each degree granting program shall have the responsibility for developing, reviewing and updating as necessary the program’s curriculum. The goals of each Curriculum Committee are to align the missions and strategic plans of the Graduate School and St. Jude Children’s Research Hospital, to identify core competencies and learning objectives, and to ensure that the curriculum is structured to meet them.

80.38.002: Guiding Principles

• Governance procedures are consistent with the requirements of the Graduate School, St. Jude Children’s Research Hospital, the Tennessee Higher Education Commission (THEC), the Tennessee Student Assistance Corporation, and the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC);
• The Committee will function under the Policies and Procedures set by the Graduate School, which is responsible for implementing and managing courses and faculty evaluations;
• Governance procedures incorporate appropriate representation from multiple disciplines at St. Jude Children’s Research Hospital;
• Curriculum management allows for an appropriate balance between Graduate School  oversight, and initiative and innovation from the course leaders and teaching faculty within each program;
• The governance process encourages continuous improvement of the curriculum review process;
• Processes leading to decision-making are based on open discussion, transparency, shared governance, and iterative consensus development.

80.38.003: Roles and Responsibilities

• Curriculum Design
  • Review the program competencies and ensure that courses align with them.
  • Ensure vertical and horizontal integration, balancing the weight given to each aspect of the curriculum design based on the expertise and focus areas of St. Jude Children’s Research Hospital and accreditation guidelines.
    i.   Horizontal Integration - foundational concepts of the subject matter linking knowledge and experiences.
    ii.  Vertical Integration - the sequence of courses rationally builds concepts and theories to facilitate student learning.
• Curriculum Evaluation Functions
  • Monitor, review and evaluate individual courses for quality and effectiveness to the highest of professional and academic standards.
  • Make recommendations on curriculum course structure based on student feedback, student course evaluations, and evaluations from instructors and course leaders.
  • Review and approve new course proposals.
  • Evaluate aggregate data (overall course and faculty evaluation data) annually.
  • Recommend subsequent action and a mechanism to monitor the action, when necessary.
  • Communicate concerns and required follow up action to the Course Leaders and Curriculum Committee Chair, through the Dean if considered necessary.

80.38.004: Membership

Each degree program has the freedom to choose their own committee membership.  However:

1. The Associate Dean will Chair the committee and,
2. The SVP/COO, the Assistant Dean, and the Institutional Researcher of the Graduate School are ex-officio non-rotating members and are non-voting.

80.38.005: Meetings

• Meetings shall be held at regular intervals as determined by the Chair;
• Meeting agendas (including date, time, and location) and any supporting materials shall be prepared by the Chair and distributed to the Curriculum Committee Members at least five (5) business days in advance of the meeting. Any member of the Curriculum Committee may have an item placed on the agenda by submitting a written request to the Chair seven (7) business days in advance of the meeting;
• Special Meetings may be called by the Chair, the Dean of the Graduate School, or by petition of a majority of the members of the Curriculum Committee.  Notices of Special Meetings will be sent at least three (3) business days prior to the event and will state the purpose of the meeting;
• Meetings can only be attended by Committee Members.  Guest participants will only be included with an invitation from the Chair.
• A quorum is defined as having participation from at least 50% of the voting members.

80.38.006: Voting Privileges and Procedures

• Votes may take place in-person, virtually, or electronically, during a meeting or as a stand-alone event;
• A positive vote of more than half of present voting members is required to pass a measure;
• Voting via proxy is not permitted;

80.38.007: PhD Curriculum Committee

The Committee consists of 13 voting members.

1. Standing Members (10 total):  The Associate Dean of the PhD program and the course leaders.  Shall have no length of term nor term limits but must be current course leaders and will rotate as necessary.  The Standing Members are voting members.
2. Rotating Members (3 total):  Graduate Faculty selected by the Dean and Associate Dean that teach in the PhD courses.
    i.   The maximum term of membership shall be three (3) years. Terms will be staggered so that a new Rotating Member is appointed each year.
   ii.  Consecutive terms are not allowed, but former Rotating Members can serve again after a two (2) year break.

80.38.008: MSc GCH Curriculum Committee

The Committee consists of seven (7) voting members.

1. Standing Members (3 total):  The Associate Dean of the program, the Dean of the Graduate School, and the Chair of Global Pediatric Medicine shall have no length of term nor term limits.  The Standing Members are voting members.
2. Rotating Members (4 total):  Selected  by vote from the Graduate Faculty.
   i.  The maximum term of membership shall be three (3) years. Terms will be staggered so that two new Rotating Members will be elected or appointed each year.
   ii. Unless otherwise approved by the Dean of the Graduate School or the Associate Dean, consecutive terms are not allowed, but former Rotating Members can serve again after a two (2) year break.

80.38.009: MSc CI Curriculum Committee

The Committee consists of eight (8) voting members.

1. Standing Members (5 total):  The Associate Dean of the MSc CI program, course leaders representing the disciplines of Statistics, Epidemiology, and Clinical Trials, and one additional course leader appointed by the Associate Dean.  Shall have no length of term nor term limits but must be current course leaders and will rotate as necessary.  The Standing Members are voting members.
2. Rotating Members (3 total):  Graduate Faculty selected by the Dean and Associate Dean that teach in the MSc CI courses.
   i.   The maximum term of membership shall be three (3) years. Terms will be staggered so that a new Rotating Member is appointed each year.
   ii.  Unless otherwise approved by the Dean of the Graduate School or the Associate Dean, consecutive terms are not allowed, but former Rotating Members can serve again after a two (2) year break.
   

80.39.001: Mission

The Admissions Committee for each degree granting program shall have the responsibility of identifying the best candidates for entry into the program.  A key goal of each Admissions Committee is to align the missions and strategic plans of the Graduate School, St. Jude Children’s Research Hospital, and the participating basic research, clinical and Global Pediatric Medicine departments.

80.39.002: Guiding Principles

• Governance procedures are consistent with the requirements of the Graduate School, St. Jude Children’s Research Hospital, the Tennessee Higher Education Commission (THEC), the Tennessee Student Assistance Corporation, and the Southern Association of Colleges and Schools Commission on Colleges (SACSCOC);
• Governance procedures incorporate appropriate representation from multiple disciplines at St. Jude Children’s Research Hospital;
• Admissions management allows for an appropriate balance between central Graduate School oversight and individual program’s initiative and innovation;
• The governance process encourages continuous improvement of the admissions process;
• Processes leading to decision-making are based on open discussion, transparency, shared governance, and iterative consensus development;
• The selection of individual students for admission is not influenced by any political, financial, religious, sexual, personal or nepotistic factors.

80.39.003: Roles and Responsibilities

• Review student applications, rank order the applications and summarize the reasons for the rank order for subsequent discussion;
• Report admissions recommendations to the Dean and Associate Dean, and meet with them to finalize the applicant rankings;
• Participate in applicant interviews and subsequent amendments to the applicant rankings;
• Generate the final offer list in consultation with the Dean and Associate Dean;
• Review the selection procedure with the Graduate School staff and identify refinements and improvements to the procedure.

80.39.004: Membership

• Each Admissions Committee has its own membership rules, but with the following caveats;
  • Each committee has a Chair who cannot be the Dean or the Associate Dean;
  • The Chair cannot serve for more than three (3) years;
  • The Assistant Dean will be an ex-officio non-voting member who will coordinate the committee meetings and report to the Associate Dean, and Dean if necessary.

80.39.005: Meetings

• Meetings shall be held at regular intervals as determined by the Chair;
• Meeting agendas (including date, time, and location) and any supporting materials shall be prepared by the Chair and distributed to the Admissions Committee Members by the Assistant Dean at least seven (7) business days in advance of the meeting. Any member of the Admissions Committee may have an item placed on the agenda by submitting a written request to the Chair ten (10) business days in advance of the meeting;
• Special Meetings may be called by the Chair, the Associate Dean, the Dean, or by petition of a majority of the members of the Admissions Committee.  Notices will be sent by the Assistant Dean at least seven (7) business days prior to the event and will state the purpose of the meeting;
• Meetings can only be attended by Admissions Committee Members.  Guest participants will only be included with an invitation from the Chair;
• A quorum is defined as having participation from at least 50% of the voting members.

80.39.006: Voting Privileges and Procedures

These apply to Admissions Committee matters and admissions decisions.

• All Admissions Committee Members are eligible to vote apart from ex officio members;        
• Votes may take place in-person, virtually, or electronically, during a meeting or as a stand-alone event;
• A positive vote of more than half of present voting members is required to pass a measure unless otherwise noted or announced;
• Voting via proxy is not permitted.
  

80.39.007: PhD Admissions Committee

The Admissions Committee consists of fifteen (15) voting members and two (2) ex-officio members.

• The Dean and Associate Dean will select the Chair of the committee from the membership;
• The term of membership, including the Chair, shall be three (3) years. Terms will be staggered so that approximately one-third of the committee membership will be elected or appointed each year;
• A member can serve a total of two (2) consecutive terms, but must take at least a two (2) year break before being considered to serve again;
• The SVP/COO of the Graduate School and the Assistant Dean are ex-officio members and have no term limits.  The ex-officio members are non-voting members.

80.39.008: MSc GCH Admissions Committee

• The Admissions Committee consists of thirteen (13) voting members and two (2) ex-officio members.
• The Associate Dean will select the Chair of the committee from the membership;
• The Chair of Global Pediatric Medicine, Dean of the Graduate School, and Associate Dean of the MSc GCH Program are standing members of the committee and shall have no term limits;
• Select members of the Graduate Faculty and St. Jude senior staff of Global Pediatric Medicine shall be Rotating Members of the Committee. The term of membership of the Rotating Members shall be three (3) years. Terms will be staggered so that approximately one-third of the committee membership will be elected or appointed each year;
• A Rotating Member can serve a total of two (2) consecutive terms, but must take at least a two (2) year break before being considered to serve again;
•  The SVP/COO of the Graduate School and the Assistant Dean are ex-officio members and have no term limits.  The ex-officio members are non-voting members.
  

80.39.009: MSc CI Admissions Committee

• The Admissions Committee consists of eight (8) voting members and two (2) ex-officio members.
• The Associate Dean will select the Chair of the committee from the membership;
• After receiving nominations from the Faculty, the Associate Dean and the Chair of the committee will appoint the remaining seven (7) members of the committee;
• The term of membership, including the Chair, shall be three (3) years. Terms will be staggered so that approximately one-third of the committee membership will be elected or appointed each year;
• A member can serve a total of two (2) consecutive terms but must take at least a two (2) year break before being considered to serve again;
• The SVP/COO of the Graduate School and the Assistant Dean are ex-officio members and have no term limits.  The ex-officio members are non-voting members.

80.40.001: Admissions Policy and Practices

• The Graduate School has developed rigorous admissions and recruiting policies that are governed by (1) integrity and honesty, (2) consistency with the school’s mission, (3) identifying students committed to personal achievement and drive to succeed, (4) academic excellence, and (5) promoting diversity across all degree programs. The school’s staff, faculty and students are solely responsible for the recruiting of new students, and admissions are processed by the staff. The school does not employ independent contractors or agents at any stage in the process. 
• All recruiting materials including flyers, pamphlets, videos and electronic mailings have been developed by the Graduate School staff with assistance from St. Jude experts in communications, content development and artistic/video design. The content is thoroughly reviewed for accuracy and updated as necessary.
• The recruiting process follows standard procedures and includes in-person and virtual recruiting fairs, attendance at relevant meetings that accommodate student recruitment, visits to undergraduate and medical institutions, advertising and communication to targeted prospects, and networking with faculty advisors.
• All potential applicants are referred to the Graduate School website for information and instructions on how to apply and the detailed information of required admissions material (‘Admissions’ pages for each program). 
• Financial incentives are strictly prohibited although applicants are fully supported during recruitment visits to the Graduate School, and Graduate School staff and students host potential applicants at group events during meetings and other recruiting events.
• Student selection into each program is overseen by an Admissions Committee that is comprised of Graduate School faculty members (See Section 80.39 under Faculty Policies). Although the policies governing each program’s Admissions Committee are largely uniform and are consistent with SACSCOC governance procedures, there are some program specific policies that are fully described on the website. Importantly, the Dean and each program’s Associate Dean cannot serve on the committees to maintain independence and avoid conflict of interest.
• The Chair of each Admissions Committee is a faculty member who has served on the committee. As such, the chair has the requisite experience to lead the effort. An admissions committee member shall serve for three (3) years. Each program’s Assistant Dean is an ex officio non-voting member of the committee.
• The entire admissions process is coordinated by dedicated software that is widely used in the US and abroad by prospective graduate students. 
• Very broadly, each program follows the same admissions process comprising (1) advertising and encouraging applications, (2) acceptance of applications until the deadline (typically the end of the day on December 1st PST), (3) review of applicants by the Admissions Committees, (4) a ranked list of all applicants, (5) selection of those for further consideration, (6) visits to the Graduate School for interviews with faculty (or web-based interviews if necessary, for example for overseas applicants) and (7) final selection of applicants who will be offered admission. Depending on how the yield proceeds, the Admissions Committee Chair, Dean and Associate Dean may consider further offers and interviews based on the ranking list.
• When the admissions process is completed for each program, the respective Admissions Committee Chair, Associate Dean, Assistant Dean submit their ranked lists to the Dean and SVP/COO for final review and approval.
• Applicants are required to accept/reject offers by April 15th, which is the national acceptance date in the US. However, further offers can be made and accepted after this date.
• All offers of admission in any degree program are valid and in effect up to the deadline noted in the admit letter and their acceptance prior to the admit deadline will be honored irrespective of the number of offers that are accepted.
• After the incoming cohort is confirmed for each degree program, a debrief meeting of the process is held with the respective Admissions Committee Chair, Associate Dean, and Assistant Dean, along with the Dean and SVP/COO review the process and identify opportunities for improvement.

80.40.002: Graduate Student Health Screening

Purpose

All students in the St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences whose program requires on-campus presence or are considered full-time must fulfill health screening requirements to improve overall wellbeing of the St Jude community. This policy outlines the scope of those health screening requirements. This policy is in addition to the St Jude Children’s Research Hospital Policy 15.10.030 (Employment Health Screening) and 15.10.111 (Mandatory COVID Vaccine for Employees and for Students Enrolled in the St. Jude Graduate School for Biomedical Sciences) which for campus health and safety purposes applies to students in the St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences.

Scope

The policy applies to all students whose program requires an on-campus presence or are considered full-time.

Students who will be physically present on the St. Jude campus or are considered full-time must have documentation of vaccination to measles, mumps, rubella, and varicella. If proof of prior vaccination cannot be established at time of orientation, blood titers will be performed to test immunity. Those physically present on the St. Jude campus must participate in St. Jude’s Mandatory COVID-19 Vaccination Program (full vaccination against SARS-CoV-2 by September 9, 2021 is a condition of enrollment/program continuation, unless a medical or religious accommodation request is approved). Students who will work with highly pathogenic influenza viruses must receive the annual influenza vaccine unless a medical or religious accommodation is approved. All other students physically present on the St. Jude campus must receive the annual influenza vaccine or sign a declination form.

Students may also be required to comply with St. Jude health and safety protocols designed in accordance with local and federal requirements or guidelines. These protocols may include daily SARS-CoV-2 or other pathogen symptom screening, masking and/or physical distancing as applicable.

The St. Jude Children’s Research Hospital Graduate School, through its own staff or through designees, may engage in an interactive process with students who have a qualifying medical condition or who object to a health requirement based on sincerely held religious beliefs, to determine if a reasonable accommodation can be provided. This process will require a determination of whether an accommodation would create an undue hardship for the St. Jude Children’s Research Hospital Graduate School and/or would pose a direct threat to the health or safety of others on campus.

Policy

1. All newly admitted students, as part of the onboarding process, are required to complete an online health screening. In addition, newly admitted students whose program requires an on-campus presence or are considered full-time are required to meet with an occupational health nurse no later than the first day of employment.
2. Due to the immunocompromised state of St. Jude patients, immunization compliance is of utmost importance. All students whose program requires an on-campus presence or are considered full-time must complete all components of the health screening process, to include vaccination(s); blood analysis Mycobacterium Tuberculosis (BAMT) and laboratory test(s) within ten (10) working days of orientation and/or notification from Occupational Health, or complete St. Jude’s declination form.
3. Participation in St. Jude’s Mandatory COVID-19 Vaccination Program is a condition of admittance/program continuation for students whose program requires an on-campus presence or are considered full-time, in accordance with St. Jude Policy 15.10.111 Mandatory COVID-19 Vaccine.
4. Noncompliance with this policy may result in recension of an offer.
5. All student medical records are confidential and only shared on a business need-to-know basis. Student medical records are maintained separately from other student files in accordance with state and federal law.

Procedure

1. All newly admitted students are required to complete the pre-employment online onboarding process, which includes completion of a form regarding a personal medical history prior to the first day of orientation.
2. All newly admitted students whose program requires an on-campus presence or are considered full-time are required to meet with an occupational health nurse during orientation or their first day on campus to ensure completion of the health screening process.
3. All newly admitted students should upload any medical records showing proof of required vaccination or immunization into the online onboarding portal or bring the documentation with them to their appointment with an occupational health nurse.
4. The student health screening will include a personal medical history and may require screening tests (laboratory tests, BAMT test, immunizations) as applicable to the job responsibilities.
5. Students whose work and projects will place them at risk of occupational exposure to hepatitis B virus will be required to receive hepatitis B vaccine or show proof of previous vaccination as a condition of admittance unless medical or religious accommodation is requested, in which case the student shall be referred to the ADA Coordinator. The ADA Coordinator may request or offer for the student to begin the interactive accommodation process by completion of the Accommodation Request form, the Medical Accommodation Request form, and other forms as appropriate.
6. All newly admitted students whose program requires an on-campus presence or are considered full-time must have immunity to measles, mumps, rubella, varicella and must participate in St. Jude’s Mandatory COVID-19 Vaccination Program. Students receiving offers on or after June 1, 2021, and existing students after September 9, 2021 must also be fully vaccinated against SARS-CoV-2. Students without positive immunity to measles, mumps, rubella, varicella or without proof of vaccination against SARS-CoV-2 will be required to receive vaccination(s) as a condition of acceptance/continuation in the program unless medical or religious accommodations are requested, in which case the student shall be referred to the ADA Coordinator. The ADA Coordinator may request or offer for the student to begin the interactive accommodation process by completion of the Accommodation Request form, the Medical Accommodation Request form, and other forms as appropriate.
7. Participation in the annual influenza program is required for all students as outlined below.
   • All students who work with highly pathogenic influenza viruses (HPI) and any student with direct patient contact must receive the annual influenza vaccine unless a medical or religious accommodation is provided, in which case the student shall be referred to the ADA Coordinator.
   • All other students (non-HPI and non-direct patient contact) must receive the annual influenza vaccine or sign a declination form.
   • Students who report certain infectious illnesses and/or health needs may require additional screening if determined to constitute a “direct threat” to the St. Jude campus or anyone on the St. Jude campus and will be referred to the ADA Coordinator. The screening process will be considered on a case-by-case basis under the 80.98.003: Accommodation Policy.
8. If a potentially infected student may pose a direct threat to the health of others, screening or testing requirements including, but not limited to, temperature screens or nasal swab testing for an infectious disease may be required as students enter the St. Jude campus. Under such circumstances, St. Jude may also inquire as to whether students are experiencing symptoms of the infectious illness before permitting them to enter the St. Jude campus. Such “direct threat” circumstances typically arise during a pandemic or other situation in which public health authorities have acknowledged significant community spread.
9. Students may be required to have a fitness for duty assessment completed by medical personnel of St. Jude’s choosing if deemed appropriate. See Policy 80.98.003, Accommodation Policy.

80.40.020: Student Complaints and Grievances Process

The Graduate School will use reasonable methods to respond to all Complaints and Grievances in a timely manner.  Retaliation against graduate students for raising Complaints or filing Grievances in good faith shall not be tolerated.

Procedure

Step One:  A graduate student should speak directly to the source of his/her/their concern. When possible and appropriate, students should attempt to resolve the problem with the other person or persons who are the alleged cause of the Complaint. The parties involved should make every effort to resolve the issue fairly and promptly.  If a graduate student is uncomfortable with or unable to speak directly with the source of the concern, they should attempt to resolve the issue in collaboration with the Associate Dean for Student Affairs, Dr. Stacey Schultz-Cherry, E8053 Donald P. Pinkel MD Research Tower, 901-595-6629 or cell 901-216-2627. If a graduate student is not satisfied with the outcome of Step One, he/she/they should proceed to Step Two.

Step Two:  If a graduate student is not able to reach a satisfactory resolution at Step One, the student should promptly (no more than 30 [thirty] days from the date of the event or incident leading to the Complaint) file a formal written Complaint in the student portal within the student information system at: https://thaddeus.stjude.org/secure/student/loginstu.aspx or through EthicsPoint - St. Jude Children's Research Hospital. The portal is an electronic submission system in which Complaints are stored. The form prepopulates the graduate student’s information. The submitted complaint routes to the Student Affairs Committee for review. The Student Affairs Committee consists of the Associate Dean for Student Affairs who will act as chair, the three Assistant Deans, and an additional ad hoc member appointed by the Dean.  A representative from the St. Jude Office of Legal Services shall act as legal support to the Student Affairs Committee. If one or more of the members of the Student Affairs Committee is temporarily unavailable to serve, the Dean may appoint designees for this purpose. If the formal written Complaint is about one of the members of the Student Affairs Committee, that member will be recused and the Dean will appoint a designee in their place. 

Within one month of having received notification, the Student Affairs Committee shall:

• Meet to discuss the complaint 
• Meet with the Reporter to discuss the complaint
• Meet with the Respondent(s) to discuss the complaint
• Determine if a Code of Conduct violation occurred
• Render a decision and possible sanction and/or corrective actions
• Issue a decision and recommendation for any sanction and/or corrective actions in writing to the Dean
• If, under extraordinary circumstances, this deadline cannot be met, the chair of the Student Affairs Committee shall inform the Reporter and Respondent(s) of the delay.
• The Complaint will be maintained in a confidential file in the Graduate School.

Once the decision has been made by the Student Affairs Committee, the following notifications will be sent:

• The Reporter and the Respondent(s) will be notified of the decision and any required follow up actions in writing from the Dean.
• The Reporter and the Respondent(s) will be notified of the appeal process.

If follow up corrective actions or sanctions are required, the Associate Dean of Student Affairs will ensure these requirements are met and documented. A copy of the complaint, any investigatory documents, and a statement of the matter’s disposition will be kept in the appropriate student file in the graduate school office for a minimum of three years.

The range of possible sanctions includes, but is not limited to, those listed at the end of this policy.

As possible, the confidentiality of all students will be maintained.

It is prohibited to interfere with or obstruct the Graduate Student Complaint or Grievance Process, by any means and through any medium, including but not limited to the following:

• Knowingly filing a false report that a violation was committed.
• Falsification, distortion, or misrepresentation of information relevant to the Graduate School Complaint or Grievance Process.
• Disruption or interference with the orderly conduct of any meeting as outlined in this policy.
• Attempting to influence the impartiality of a Student Affairs Committee member prior to, or during, a Graduate Student Complaint or Grievance Process.
• Harassment or intimidation of a Student Affairs Committee member, and/or participant, prior to, during or after any meeting as outlined in this policy.
• Influencing or attempting to influence another person to commit an obstruction of the Graduate Student Complaint or Grievance Process.

Step Three. If a graduate student believes that he/she/they has not received appropriate redress through the Complaint procedure, the graduate student may file a Grievance on one or more of the following three grounds:

Procedural irregularities sufficient to affect the outcome;

New information that was not reasonably available at an earlier stage of review that could reasonably be expected to affect the outcome; or

An error of judgment in the conclusion reached by a decision-maker at an earlier stage of review.

A Grievance must be no more than five (5) double-spaced pages with one (1) inch margins and twelve (12) point font and may include attachments, including the original complaint and documentation from each prior step in the process. The Dean will confirm that the student has exhausted the Complaint process (Steps One and Two) and should make every effort to resolve the Grievance promptly (usually within thirty (30) days) through a written decision issued to the student. The Dean will make a decision based on the written record.  The decision of the Dean is final.

Any questions about the Student Complaint Process should be directed to the Associate Dean of Student Affairs.

Students are urged to exhaust all possible internal avenues for resolution before filing complaints with external agencies. In the event that an issue cannot be resolved by the Graduate School, the student has the right to contact the state of Tennessee and its appropriate agencies to determine the course of action. Any person claiming damage or loss as a result of any act or practice by this institution that may be a violation of Title 49, Chapter 7, Part 20 or Rule Chapter 1540-01-02 may file a complaint with the Tennessee Higher Education Commission, Division of Postsecondary State Authorization (DPSA). The THEC DPSA is located at 312 Rosa L. Parks Ave., 9^th Floor, Nashville, TN 37243. The phone number is (615) 741-5293

Sanctions and Corrective Actions

A sanction is an educational, restorative, corrective, or deterrent measure assigned to a student because he/she/they has been found responsible for a violation. If the respondent is a St Jude faculty or staff member, sanctions fall under the purview of St Jude. Possible sanctions/corrective actions against students, in increasing order of severity include without limitation one or more of the following:

• Formal Warning: Respondent is notified that the respondent’s actions constituted a violation and that further violations will result in further disciplinary action.
• Educational Activity: Respondent is required to complete corrective measures designed to be educational, developmental, or restorative in nature that promote enhanced ethical decision-making.
• Restitution: Respondent is required to make restitution for misuse, damage or destruction of or to Graduate School public or private property or services. Examples include without limitation costs of repair, replacement, recovery, cleaning, or otherwise restoring the property or services affected.
• Denial of Privileges or Associations: Respondent is notified that, for a specified period, certain privileges or associations within or related to the Graduate School are withdrawn. This sanction may include without limitation the termination of housing contracts and revocation of the privileges of using certain campus facilities.
• Probation: Respondent is notified that his/her/their status with the Graduate School, for a specified period, is such that further violations of any applicable Graduate School policies will result in his/her/their being considered for a “higher level” sanction, including deferred suspension, suspension, or dismissal from the Graduate School. If at the end of the specified period no further violations have occurred, the respondent is removed from active probationary status.
• Deferred Suspension: In some cases, a sanction may be held in abeyance for a specified period. This means that if the respondent is found responsible for any violation of Graduate School policy during that period, the respondent will be subject to the deferred sanction without further review in addition to the disciplinary action appropriate to the new violation. For serious misconduct, the conferring of an academic degree will be deferred for the duration of the sanction.
• Suspension: Respondent is notified that he/she/they is separated from the Graduate School for a specified period. The respondent must leave campus and vacate student housing, if applicable, within the time prescribed and is prohibited from St. Jude property and events. A suspension may be effective immediately or at a later date under the discretion of the Dean or Dean’s designee based on consideration of relevant factors, including without limitation the nature of the misconduct and the health and safety of the respondent and others in the Graduate School community. The respondent’s academic transcript will contain a notation of the suspension stating that the respondent was suspended by Graduate School action. The conferring of an academic degree may be deferred for the duration of the suspension. The respondent must receive written permission from the Graduate School Dean prior to re-enrollment.
• Dismissal: Dismissal means the permanent removal of the respondent from the Graduate School, which. includes a forfeiture of all rights and degrees not actually conferred at the time of dismissal, notification of dismissal to the Graduate School community (as necessary), permanent notation of the dismissal on the respondent’s Graduate School records, and withdrawal from all courses. Any respondent dismissed from the Graduate School is prohibited from St. Jude property and events and will not be readmitted to the Graduate School.

80.40.021: Student Portal and Formal Complaint Submission Policy

The Graduate School utilizes the student information system portal as the entry point for a student to submit a complaint, comment, suggestion, or question. All students are able to access the student complaint portal using their username and password at: https://thaddeus.stjude.org/secure/student/loginstu.aspx.

The Graduate School is committed to continuous improvement and, to that end, we have developed the student complaint portal which allows an enrolled student to lodge a formal complaint, make a comment about something, provide a suggestion to improve anything academic and non-academic, and to ask a question. The portal form feeds to the SVP/COO and the Assistant Dean/Director of Institutional Research. A student gains access to the student portal in the following manner:

1. https://thaddeus.stjude.org/secure/student/loginstu.aspx;
2. Enter St. Jude username;
3. Enter St. Jude password;
4. In the left side margin, choose Student Complaints (or you may choose the Feedback Form link in the bottom right menu); and
5. Then click Student Complaints.

The Feedback Form will appear with the student’s first name, last name, and email pre-populated. The student will then select the type of feedback from the subject box – complaint or comment or suggestion or question. The comments box is an open text field where the student would fill in the details relating to the subject selected.

Once the student clicks Send, the feedback message will route to both the SVP/COO and the Assistant Dean/Director of Institutional Research. Depending on the nature of the feedback, the SVP/COO and/or the Assistant Dean/Director of Institutional Research will coordinate a response to the feedback with a target completion of 30 days from the submission date.

The dedicated email box – gradschoolfeedback – will store all submitted feedback forms. The access to this dedicated email box is limited in the Graduate School to the SVP/COO and the Assistant Dean/Director of Institutional Research.

Logging into the Student Portal

1. Go to https://thaddeus.stjude.org/secure/student/loginstu.aspx
2. Enter your St. Jude username and password.

80.40.022: Code of Conduct

The Graduate School Code of Conduct applies to students within all programs in the Graduate School. Following this Code ensures that we pursue the Graduate School mission with the highest standards of integrity and that we continually earn and maintain the trust of those who look to us as a world leader in the academic community.

Ethical behavior is essential to the Graduate School mission. We are only as strong as our reputations as individuals and as an institution, which includes a commitment to ensure a culture of excellence, innovation, mutual respect, inclusion, and creativity in research, scholarship, and everything we do. It also includes a commitment to respect ethnic, cultural, religious, and lifestyle differences of patients, their families, colleagues, students, and supporters.  Specifically, the Graduate School expects and seeks to foster:

• A drive and sense of urgency to succeed;
• Honesty, integrity, and accountability in actions and decisions;
• A culture of trust and teamwork; 
• Respect for employees and students under our supervision;
• A commitment to the continuous development of our employees and students;
• A commitment to diversity and inclusion;
• A commitment to local, state, national, and global social responsibility and institutional citizenship.

Violations of the Code of Conduct

A.  Alcoholic Beverages, Illegal Drugs, and Gambling Violations

• Possession or consumption of alcoholic beverages by a person under 21 years old in violation of Tennessee law on campus or in connection with an activity sponsored by the Graduate School.
• Unless authorized for a Graduate School-related event, possession, distribution, or use of alcoholic beverages on campus is prohibited per St Jude policy 15.20.035
• Facilitating, arranging, or participating in any activity that constitutes, facilitates, or encourages competitive, rapid, or excessive consumption of alcohol when such activity occurs on campus or in connection with a Graduate School activity.
• Unauthorized possession or use of drugs or alcohol on St. Jude time or premises, or reporting for work under the influence of alcohol, narcotics, or illegal drugs.
• Smoking in unauthorized areas.
• Gambling on premises.
• Conviction of a felony or misdemeanor, or failure to disclose a felony or misdemeanor, or any charge that involves minor children, prescription drugs, narcotics, or illegal drugs.
• Operation of a motor vehicle while impaired by drugs, alcohol, or other mind-altering substance or while having an unlawful blood or breath alcohol level, in violation of Tennessee law.
• Operating a motor vehicle on behalf of the Graduate School while under the influence of drugs, alcohol, or other mind-altering substance, regardless of whether a violation of Tennessee law.
• Illegally using, possessing, manufacturing, distributing, or intending to distribute a controlled substance. 
• Knowingly inhaling and/or ingesting substances or causing another to knowingly or unknowingly inhale and/or ingest substances, that will alter one’s mental state. 
• Prescription or non-prescription drug abuse.
• Illegal possession or use of prescription medications not prescribed to the user.
• Possession of illegal drug paraphernalia.

B. Complicity in Violating the Code of Conduct

• Attempting, aiding, encouraging, facilitating, abetting, conspiring to commit, hiring someone else to commit, giving or receiving bribes to secure, or being an accessory to any act prohibited by this Code.

C. Disruptive Conduct

• Disruption of Graduate School officials, students, and other individuals working or volunteering at or on the behalf of the Graduate School or St. Jude Children’s Research Hospital in the performance of their work, which includes conduct that interferes with the individual’s ability to perform their duties safely and effectively, as determined by the Graduate School.
• Disruption of a Graduate School activity or event, including but not limited to public intoxication, excessive noise, or public nuisance.
• Disruption of a class or curricular activity, which includes classroom or another academic workplace behavior that interferes with either:
  1. the instructor’s authority or ability to conduct the class, or
  2. another students’ ability to conduct and/or benefit from the class. 
• Conduct that is disorderly or a breach of the peace under law.
• Disruptive conduct does not include any conduct protected by Graduate School or St. Jude Children’s Research Hospital policies regarding expressive conduct and academic freedom.

D. Endangering Behavior

• Unwanted, sexually suggestive physical contact, or physical contact with another individual in a way that is known to be unwelcome or was reasonably foreseeable as unwelcome.
• Fighting, verbal or physical threats or threatening statements, gestures or physical contact.
• Other conduct which does or could unreasonably endanger the health, safety, or welfare of any person or people, including oneself.
• Interference with the freedom of movement of any member or guest of the Graduate School or St. Jude Children’s Research Hospital community.
• Stalking/cyberstalking, which is a course of conduct committed with the intent to kill, injure, harass, or intimidate another person that either places the person in reasonable fear of the death of, or serious bodily injury to, that person, an immediate family member, a spouse, or an intimate partner of that person; or causes, attempts to cause, or would be reasonably expected to cause substantial emotional distress to a person listed above.
• The Graduate School prohibits carrying or transporting a firearm or weapon of any kind on St. Jude property. This prohibition does not apply to on-duty law enforcement officers or other individuals whose presence on campus is related to emergency operations and are authorized to carry a weapon based upon the nature of their job.
• See also (within the Code) Harassment; Hazing; and Sexual Harassment. Endangering Behavior may be prohibited by both the Code and Policy 80.93.002: Sexual Harassment in Educational Programs or Activities (e.g., sexual assault, stalking).

E. Failure to Comply with Security Directive

• Failure to comply with security directives.

F. Fire Safety Violations

• Conduct that causes or attempts to cause a fire or explosion on campus or at Graduate-School sponsored events.
• Possession or use of fireworks on campus or at Graduate-School sponsored events unless authorized by the Graduate School in advance in writing.
• Misuse, tampering with or vandalism of fire or emergency alarm systems, fire extinguishers, electrical breakers, or other safety/security equipment on the campus or at any Graduate School activity.
• Failure to evacuate or follow instructions during a fire or emergency alarm or interfering with fire or emergency evacuations on the campus or at any Graduate School activity.

G. Furnishing False Information

Knowingly furnishing false or misleading information to the Graduate School or to any Graduate School official. This includes written, verbal or other forms of falsification of records, forging of documents, or omitting facts that are material to the purpose for which the information is submitted.

H. Harassment

Threats, intimidation, coercion, or any other conduct (including on social media) that places a reasonable person in fear of physical, emotional or mental harm, through words or actions, or objectively disrupts a person’s daily activities, including education and employment. Discriminatory harassment includes conduct (oral, written, graphic or physical) directed against any person or, group of persons because of their race, color, national origin, religion, sex, sexual orientation, gender identity, age, disability, or veteran's status and that has the purpose or reasonably foreseeable effect of creating a hostile environment for that person or group of persons. Harassment does not include conduct protected by the Graduate School policy regarding academic freedom. Harassment that is sexual or gender-based in nature is prohibited by both the Code and Policy 80.93.002: Sexual Harassment in Educational Programs or Activities.

I. Hazing

Any action or series of actions that recklessly or intentionally endangers the mental health, physical health, or safety of a person for any purpose. Hazing includes but is not limited to any physical brutality, such as whipping; beating; branding; exposure to the elements; forced consumption of any food, alcohol, drug, or other substance; or other forced physical activity that could adversely affect the physical health, mental health or safety of any person and any activity that would subject the person to extreme mental stress, such as sleep deprivation, forced sexual conduct, or forced exclusion from social contact.  Hazing also includes

• Conduct that by design, intent or recklessness causes a person to be reasonably unable to pursue, interferes with, or attempts to interfere with a person’s schedule or performance.
• Causes, induces, pressures, coerces, or requires a person to violate the law.

In response to allegations of hazing under this policy, it is not a defense that:

1. The person harmed gave consent to the conduct.
2. The conduct was not part of an official organizational event or sanctioned or approved by the organization.
3. The conduct was not done as a condition of membership in the organization.

Hazing that is sexual or gender-based in nature is prohibited by both the Code and 80.93.002: Sexual Harassment in Educational Programs or Activities.

J. Invasion of Privacy and Unauthorized Recording

• To facilitate open discussion and exchange of ideas, protect privacy, and maintain integrity of operations, the Graduate School prohibits the secret recording (audio or video) of classes, meetings or other conversations, including telephone calls. In order to promote an environment of trust and collegiality, recordings may be made only with the prior consent of the parties involved. Covert/secret recording of conversation or meeting occurring at the Graduate School, including any classroom or other educational setting. It is also a violation of this policy to download recorded conversations to a computer, upload them to the internet, or otherwise share, transmit or publish such recordings without the prior written consent of all participants.
• Classes may be audio-recorded by the faculty member, or by a student in the class for personal use with the prior consent of only the professor. Class participants should generally be informed when a class may be recorded. However, faculty should not disclose the identity of students recording classes under an accommodation. Class recordings by students may not be downloaded to any computer, uploaded to the internet, or otherwise shared, transmitted or published without the further, prior written consent of the faculty member.
• Video recordings present additional privacy concerns, and potential concerns with copyright and intellectual property issues. Therefore, video recordings should only be allowed under conditions completely understood and approved in advance in writing by the faculty member. All students and other participants in a class or educational activity which will be video recorded must be informed of the recording. Video recordings shall not be publicly shared, such as on the internet or in public viewings, without the written consent of those being being recorded. 
• Surveillance cameras/equipment and software may be placed on campus by authorized campus personnel to prevent or deter crimes and protect public safety and to facilitate official investigations into criminal activities or violations of policy.
• Acts of voyeurism, peeping, spying, or recording another in any location where a reasonable expectation of privacy exists are strictly prohibited
• Any violation of Graduate School or St. Jude Children’s Research Hospital privacy policies (such as those related to student, employee, or patient privacy) will be reviewed as possible violations of this Code of Conduct.

K. Misuse or Unauthorized Possession or Use of Campus Property

• Theft, misuse, taking or unauthorized use or possession of campus property or unauthorized use or acquisition of campus services.
• Destroying, damaging or littering of campus property.
• Misuse of the identification number or card issued to a student through alteration, forgery or duplication, or through use of an identification card that has not been issued to the user. 
• Use or possession of fake identification materials.

L. Misuse or Unauthorized Use of Graduate School Computer Resources

• Any action without authorization from the Graduate School that does, or causes a person to, access, use, modify, destroy, disclose or take data, programs or supporting documentation residing in or relating in any way to a Graduate School computer, computer system or computer network or causes the denial of computer system services to an authorized user of such system.
• Downloading or facilitating others to download copyrighted music and films without authorization on Graduate School computers.
• Any other violation of the Information eSecurity Policy.  (Policy 80.60.002)
• The use of the Graduate School’s computer resources to violate any laws.

M. Obstruction of the Graduate School Complaint and Grievance Process

It is prohibited to interfere with or obstruct the Student Complaint and Grievance or Code of Conduct Process, by any means and through any medium, including but not limited to the following:

• Knowingly filing a false report that a violation was committed.
• Falsification, distortion or misrepresentation (including the knowing omission of material facts) of information relevant to the Student Complaint and Grievance Process.
• Disruption or interference with the orderly conduct of any meeting as outlined in this policy.
• Attempting to influence the impartiality of a Student Affairs Committee member prior to, or during, a Student Complaint and Grievance Process.
• Harassment or intimidation of a Student Affairs Committee member, and/or participant, prior to, during or after any meeting as outlined in this policy.
• Influencing or attempting to influence another person to commit an obstruction of the Student Complaint and Grievance Process.
• Any form of retaliation in accordance with St. Jude Policy 70.01.006.

N. Public Indecency

• Examples include, but are not limited to, public urination and exposure of sexual organs. 
• Breastfeeding a child is not public indecency and does not violate this policy.

O. Sexual Misconduct

Sexual misconduct is prohibited by both the Code and Policy 80.93.002: Sexual Harassment in Educational Programs or Activities.

P. Unauthorized Entry to Facilities

Unauthorized access or entry to campus property, buildings, structures or facilities. Unauthorized possession, duplication or use of keys or access cards for any such campus property.

Q. Unprofessional Conduct

Failure to abide by the Graduate School Honor Code may be a violation of the Code of Conduct. Academic violations, conflicts between students, and other unprofessional conduct that does not otherwise constitute a violation of the Code are addressed through the Student Honor Code System

Reporting Alleged Misconduct

Reports of alleged Code violations should be filed with or reported to the Associate Dean of Student Affairs, Dr. Stacey Schultz-Cherry, E8053 Donald P Pinkel MD Research Tower, 901-595-6629 or cell 901-216-2627, through EthicsPoint (which allows submission of information anonymously), the Graduate Student Association, or using the student portal within the student information system at: https://thaddeus.stjude.org/secure/student/loginstu.aspx. When reporting a student conduct complaint, the reporting individual should provide the following: reporter’s name and contact information (unless the reporter wishes to remain anonymous), a clear description of the problem or complaint, appropriate supporting documentation that is directly related to the complaint, a description of any subsequent actions taken by the reporter or the institution, and a description of the desired outcome.  Anonymous complaints will be investigated to the extent that the Graduate School has enough information to proceed with the investigation.

Any student, faculty, staff, administrator, or a concerned party may initiate a complaint under this Code and is referred to as a “Reporter”. The student or student group/organization who is alleged to have violated the Code is referred to as the “Respondent.” Persons are encouraged to bring complaints under this Code as soon after the alleged misconduct as is reasonably possible.

See also Policies 80.40.020 Student Complaints and Grievances Policy and 80.40.021 Student Portal and Complaint Submission regarding processes for filing student complaints.

Student Conduct Process

Purpose

The Graduate School’s conduct process is an educational tool with three major objectives: to ensure a safe working and learning environment for all, to hold a person(s) and/or groups/organizations accountable for unacceptable behavior, and to modify those behaviors deemed unacceptable by the Graduate School. The conduct process strives to address unacceptable behavior and to guide a person(s) toward a greater sense of both individual and shared responsibility and toward more ethical decision making.

Participation

While the Graduate School encourages the parties to participate fully in the conduct process, the Reporter and/or Respondent(s) may decline to participate in the conduct process. The Graduate School may, however, continue the process without the Reporter and/or Respondent’s participation, including, without limitation, cases in which a party has withdrawn, transferred or graduated from the Graduate School. A Respondent must comply with any disciplinary measures or sanctions/corrective actions issued pursuant to the conduct process, even if the Respondent has declined to participate in the process.

Student Rights and Responsibilities

Any student or student group/organization who participates in the student conduct process, whether as a Reporter, Respondent, witness or otherwise, has the following rights in the process, as may be applicable to the party:

• Treated with dignity and respect throughout the conduct process.
• A prompt, fair, and impartial investigation and resolution of the alleged misconduct.
• Allegations investigated and resolved by individuals who are appropriately trained and impartial.
• Confidential information protected as provided in Graduate School policies.
• Maintain privacy in the proceedings.
• Report any potential conflict of any Graduate School personnel or student participating in the conduct process. The Student Affairs Committee will determine if a conflict exists.
• Accompanied by an advisor (other than an attorney or witness) to meetings and hearings, if any, in the conduct process (see below).
• No retaliation for participation in the conduct process.
• Receive notice of the outcome of the conduct process in writing.
• Advised of the appeals process.

Respondents in the student conduct process have the following additional rights:

• Notified by the Graduate School of the allegations at least five (5) business days prior to any conduct proceeding.
• Opportunity to respond to information considered.

The student conduct process will primarily communicate with students through their official Graduate School email address. Students are expected to check their official Graduate School email on a regular basis.

Students and others involved in the conduct process are encouraged to be as forthright and as specific as possible but may choose if and the extent to which they share information. Any person who knowingly makes a false statement and/or fabricates and/or withholds evidence in connection with student conduct matters may be subject to disciplinary action under this Code.

Advisors

Both reporters and respondents may be accompanied by one advisor (limited to St Jude faculty) of their choosing throughout the student conduct process, except that attorneys and witnesses may not serve as advisors. Personnel whose participation could create a conflict of interest and/or reasonably call into question the impartiality of the process are also not eligible to serve as advisors. This determination is made at the discretion of the Associate Dean for Student Affairs or the conduct administrator appointed by the Associate Dean for Student Affairs.

The advisor may accompany the party to any meeting or hearing held pursuant to this Code. During any such meeting or proceeding, an advisor may advise and provide support to the party but may not speak on the party’s behalf or otherwise participate, or address or question the Associate Dean of Student Affairs/conduct administrator or Student Affairs Committee, or other parties or witnesses. The advisor may make written submission on the party’s behalf.

Advisors who do not comply with the structure of their role may be asked to leave the meeting or hearing and/or may be restricted from further participation in the process at the discretion of the Associate Dean of Student Affairs/conduct administrator or Student Affairs Committee, and the investigation or disciplinary proceeding will continue without the advisor’s presence. Should the respondent choose to bring an advisor, the respondent should inform the Associate Dean of Student Affairs/conduct administrator of the name of the advisor in writing at least twenty-four (24) hours in advance of the meeting or hearing.

Initial Inquiry

Upon the receipt of a complaint of misconduct under this Code, the Associate Dean of Student Affairs, or an appointed conduct administrator, will gather information regarding the alleged misconduct in order to determine the appropriate means of resolution. This gathering of information may include, without limitation, meetings with or requests for statements from the parties and witnesses, and review of any related and available documents and other information. Following review of the information available, and based on the severity of the alleged conduct, the respondent’s status at the Graduate School (e.g., whether the respondent is currently enrolled), the willingness of the reporter to participate, and whether the alleged conduct – if substantiated – constitutes a violation of the Code or other Graduate School policy, the Associate Dean of Student Affairs/conduct administrator will determine the appropriate next steps. Options include either dismissal of the complaint, informal resolution, or a conduct proceeding. Where the alleged misconduct may be a violation of Policy 80.93.002: Sexual Harassment in Educational Programs or Activities, the complaint will be addressed through the procedures of Policy 80.93.002: Sexual Harassment in Educational Programs or Activities and, in its discretion, the Graduate School may hold concurrent proceedings under this Code. 

Dismissal of Complaint

The Associate Dean of Student Affairs/conduct administrator may dismiss a complaint due to insufficient information or if the alleged conduct does not fall within conduct prohibited by this Code. The Associate Dean of Student Affairs/conduct administrator may, in their discretion, reopen a closed case in the future if additional information becomes available. All information will be reported to the Registrar for student status update. An official, living document that includes the student’s name, effective date, means of separation (i.e. dismissal, withdrawal), and the type (i.e. Academic, Misconduct) will be kept on file by the Associate Dean of Student Affairs and reports provided to the Dean, Associate Dean of relevant program, Registrar, and Office Coordinator, as needed.

Informal Resolution

The Associate Dean of Student Affairs/conduct administrator may also, in their discretion, refer the report for informal resolution where appropriate under the circumstances, including without limitation where the reporter does not wish to participate, there is insufficient information, or the alleged conduct does not fall within conduct prohibited by this Code. Options for informal resolution include, but are not limited to:

• A no-contact directive placed between students or students and employees;
• Changes in academic, schedule or work arrangements;
• An educational meeting;
• Participation in educational training or programming; or
• A written request that a student cease current behaviors.

Conduct Proceedings

After the initial inquiry, the Associate Dean of Student Affairs/conduct administrator will decide whether a case will be dismissed, resolved informally, or resolved through a conduct proceeding.

Notification

When a complaint will be resolved through a conduct proceeding, the Associate Dean of Student Affairs/conduct administrator will send notification of the alleged violation(s) of the Code to the respondent and to the reporter, if applicable. The notification will typically include a brief description of the alleged misconduct, including the time, date, and place the incident(s) allegedly occurred, and the process by which the complaint will be resolved. 

Standard of Evidence

The standard of evidence required for a determination of responsibility for misconduct under this Code is a “preponderance of the evidence,” which means that it is more likely than not that the alleged misconduct occurred.

Student Affairs Committee Hearing

The Student Affairs Committee consists of the Associate Dean for Student Affairs who will act as chair, the SVP/COO and the three Assistant Deans.  A representative from the St. Jude Office of Legal Services shall act as legal support to the Student Affairs Committee. If one or more of the members of the Student Affairs Committee is temporarily unavailable to serve, the Dean may appoint designees for this purpose. The Dean may also appoint an ad hoc member if needed for specific substantive expertise. If the formal written Complaint is about one of the members of the Student Affairs Committee, that member will be recused and the Dean will appoint a designee in their place.  The committee is charged with determining, based on a preponderance of the evidence, whether a respondent’s actions constitute a violation of this Code and, if so, determining appropriate sanction(s). The committee will review materials from the Associate Dean of Student Affairs/conduct administrator prior to the Student Affairs Committee hearing.

The hearing is a closed proceeding, meaning that no one other than the respondent, respondent’s advisor, committee members, and necessary Graduate School personnel, may be present. The reporter (if not anonymous), reporter’s advisor, and witnesses called to the hearing will be present in the hearing room only when making a statement or being questioned by the committee. In general, hearings will proceed as follows, although the committee has discretion to alter the order or way it hears or receives evidence, and to impose time limits on any stage of the process.

• Within one month of having received notification, the Student Affairs Committee shall:
  • Meet to discuss the complaint; 
  • Meet with the Reporter to discuss the complaint;
  • Meet with the Respondent(s) to discuss the complaint;
  • Meet with any witnesses;
  • Determine if a Code of Conduct violation occurred;
  • Render a decision by majority vote and possible sanction and/or corrective actions;
  • Issue a decision and recommendation for any sanction and/or corrective actions in writing to the Dean; and
  • If, under extraordinary circumstances, this deadline cannot be met, the chair of the Student Affairs Committee shall inform the reporter and respondent of the delay.
• Once the decision has been made by the Student Affairs Committee, the following notifications will be sent:
  • The Reporter and the Respondent(s) will be notified of the decision and any required follow up on actions in writing from the Dean.
  • The Reporter and the Respondent(s) will be notified of the appeal process. 
• If follow up corrective actions or sanctions are required, the Associate Dean of Student Affairs will ensure these requirements are met and documented. These records will be kept in the appropriate student file with the SVP/COO and/or Registrar.  
  • The range of possible sanctions includes, but is not limited to, those listed at the end of this policy.
• As possible, the confidentiality of all students will be maintained.
• It is prohibited to interfere with or obstruct of the Code of Conduct Process, by any means and through any medium, including but not limited to the following:
  • Knowingly filing a false report that a violation was committed.
  • Falsification, distortion, or misrepresentation of information relevant to the Graduate School Code of Conduct process.
  • Disruption or interference with the orderly conduct of any meeting as outlined in this policy.
  • Attempting to influence the impartiality of a Student Affairs Committee member prior to, or during, a Graduate School Code of Conduct process.
  • Harassment or intimidation of a Student Affairs Committee member, and/or participant, prior to, during or after any meeting as outlined in this policy.
  • Influencing or attempting to influence another person to commit an obstruction of the Graduate School Code of Conduct process.

Final Decision by the Dean

The Dean will review the report and recommendation from the Associate Dean for Student Affairs/conduct administrator or from the Student Affairs Committee if a formal hearing occurred. The Dean may instruct the Associate Dean of Student Affairs/conduct administrator to follow-up and/or clarify evidence obtained, or, as determined necessary in the Dean’s discretion, request that the parties provide written responses to the report and recommendation of either the Associate Dean of Student Affairs/conduct administrator or Student Affairs Committee.

The Dean is responsible for making a decision as to whether to accept a finding that a policy violation occurred and on the appropriateness of sanction(s). The Dean, in the Dean’s discretion, may accept the Associate Dean of Student Affairs/conduct administrator or committee’s recommendation, reach a different determination of whether a policy violation occurred, issue a different sanction (except that the Student Affairs Committee must have considered any matter resulting in separation from the Graduate School), or determine that no sanction will be issued. Written notice of the final decision will be provided to the respondent, and the reporter, if applicable. 

Appeal

A reporter or respondent may appeal the outcome of a hearing in writing to the Dean within five (5) business days of the date of the notice of outcome on the grounds of:

• A procedural error that could have affected the determination or sanction(s); and/or
• New information that was not available at the time of the investigation or hearing and that could reasonably have affected the determination or sanction(s); and/or
• Excessiveness or insufficiency of the sanction(s).

The appeal is not a re-hearing of the case, but an opportunity to provide a written statement specifically stating the grounds for the appeal and any supporting information. The burden is on the reporter or the respondent bringing the appeal to demonstrate why the finding or sanction should be altered. Appeal requests will be denied if there are insufficient grounds for the appeal.

The Dean or his/her/their designee (“appellate officer”) is responsible for deciding on the appeal. The appellate officer may, in his/her/their discretion, request to meet with either party to discuss the appealing party’s basis for the appeal, review evidence and/or consult with other individuals as deemed appropriate. The appellate officer will then make a decision on the appeal and notify both parties of the decision in writing. The appellate officer may decide to dismiss the appeal and uphold the initial decision and sanction; impose a greater or lesser sanction; or refer the matter back to the Associate Dean of Student Affairs/conduct administrator or Student Affairs Committee for further consideration with instruction.

Sanctions and Corrective Actions

Possible sanctions/corrective actions against students, in increasing order of severity include without limitation one or more of the following:

A sanction is an educational, restorative, corrective, or deterrent measure assigned to a student because he/she/they has been found responsible for a violation of the Code of Conduct. Possible sanctions/corrective actions against students, in increasing order of severity include without limitation one or more of the following:

• Formal Warning: Respondent is notified that the respondent’s actions constituted a violation of the Code of Conduct and that further violations will result in further disciplinary action.
• Educational Activity: Respondent is required to complete corrective measures designed to be educational, developmental, or restorative in nature that promote enhanced ethical decision-making.
• Restitution: Respondent is required to make restitution for misuse, damage or destruction of or to Graduate School, public or private property or services. Examples include without limitation costs of repair, replacement, recovery, cleaning, or otherwise restoring the property or services affected.
• Denial of Privileges or Associations: Respondent is notified that, for a specified period, certain privileges or associations within or related to the Graduate School are withdrawn. This sanction may include without limitation the termination of housing contracts and revocation of the privileges of using certain campus facilities.
• Probation: Respondent is notified that his/her/their status with the Graduate School for a specified periodis such that further violations of any applicable Graduate School policies will result in his/her/their being considered for a “higher level” sanction, including deferred suspension, suspension, or dismissal from the Graduate School. If at the end of the specified period no further violations have occurred, the respondent is removed from active probationary status.
• Deferred Suspension: In some cases, a sanction may be held in abeyance for a specified period. This means that if the respondent is found responsible for any violation of Graduate School policy during that period, the respondent will be subject to the deferred sanction without further review in addition to the disciplinary action appropriate to the new violation. For serious misconduct, the conferring of an academic degree will be deferred for the duration of the sanction.
• Suspension: Respondent is notified that he/she/they is separated from the Graduate School for a specified period. The respondent must leave campus and vacate student housing, if applicable, within the time prescribed and is prohibited from St. Jude property and events. A suspension may be effective immediately or at a later date under the discretion of the SVP/COO based on consideration of relevant factors, including without limitation the nature of the misconduct and the health and safety of the respondent and others in the Graduate School community. The respondent’s academic transcript will contain a notation of the suspension stating that the respondent was suspended by Graduate School action. The conferring of an academic degree may be deferred for the duration of the suspension. The respondent must receive written permission from the Graduate School Dean prior to re-enrollment. 
• Dismissal: Dismissal means the permanent removal of the respondent from the Graduate School, which includes a forfeiture of all rights and degrees not actually conferred at the time of the dismissal, notification of the dismissal to the Graduate School community (as necessary), permanent notation of the dismissal on the respondent’s Graduate School records, and withdrawal from all courses. Any respondent dismissed from the Graduate School is prohibited from St. Jude property and events and will not be readmitted to the Graduate School. Note: This definition refers to the student.  In a separate context in this policy, ‘dismissal’ can also refer to a complaint, case or appeal. 

Violations of Multiple Policies

Where conduct constituting a violation of the Code of Conduct also constitutes a violation of another Graduate School policy, the Graduate School may, in its discretion, elect to address the violation under the other policy and related procedure instead of the Code of Conduct, under both policies, or only under the Code of Conduct where appropriate in light of the other policy’s provisions.

Record Keeping

All information will be reported to the Registrar for student status update. An official, living document that includes the student’s name, effective date, means of separation (i.e. dismissal, withdrawal), and the type (i.e.  Academic, Misconduct) will be kept on file by the Associate Dean of Student Affairs and reports provided to the Dean, Associate Dean of relevant program, Registrar, and Office Coordinator, as needed.

80.40.023: The Student Honor Code System

Article 1: Preamble and Purpose

Section 1: Preamble
The St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences (“Graduate School”) is dedicated to graduate education that exemplifies academic integrity, responsibility, and excellence. As such, the Graduate School expects that all students uphold these qualities in their academic interactions with each other, faculty, staff, and other research personnel. These expectations form the basis of the Graduate School Honor System, by which all students are required to abide.

Section 2: Purpose
The purpose of the Honor System is to uphold the Honor Code, defined in Article 2 Section 2, through clear and consistent channels outlined within this document.

Article 2: Student Honor Code

Section 1: Scope
Honor System proceedings shall pertain to academic violations, as outlined in Article 3. Other circumstances that may warrant Honor System involvement are:

(a) Research misconduct that occurs during a laboratory rotation or student dissertation/thesis research is subject to investigation by the St. Jude Research Integrity Officer. If the research misconduct also affects the academic progress of the student (i.e. Candidacy Qualifying Exams, Dissertation Defense, etc.), the Honor Board may conduct an independent Honor System proceeding.

(b) Conflicts arising between students that are not related to academic activities are subject to investigation by the Graduate School Deans, who may elect to consult with the Honor Board during their investigation.

Section 2: Honor Code
Graduate School students must conduct all academic activities with personal integrity and responsibility. This includes conducting themselves professionally and ethically with regard to:

(a) The classroom, in person or online, including without limitation:

(i) Tests, examinations, and all other graded assignments, oral, written, or practical;

(ii) Non-graded assignments, oral, written, or practical;

(iii) The use of electronic technology; and

(iv) Any classroom requirements set forth by faculty, staff, students, or teaching assistants.

(b) Laboratory work pursuant to the student’s academic progress, including without limitation:

(i) PhD and/or MSc Laboratory Rotations;

(ii) PhD Candidacy Qualifying Examinations;

(iii) PhD Dissertation Defense Examinations; and

(iv) Master’s Thesis Defense Examinations.

Section 3: Student Honor Code Pledge
All students must sign the following pledge during the first two weeks of the start of classes:

I have carefully read the Student Honor System of the St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences and understand its meaning and significance. I agree to abide by the standards set forth in the Student Honor Code while enrolled in the Graduate School and agree to accept its implications in full.

A student’s signature under this pledge signifies the student’s commitment to personal academic integrity and responsibility and obligates the student to comply with the Graduate School Honor Code.

Section 4: Graduate School Compliance with the Honor Code
All Graduate School faculty and staff are expected to comply with the guidelines set forth in the Student Honor System, including without limitation:

(a) Reporting perceived Honor Code violations;

(b) Participation in Honor System proceedings; and

(c) Enforcement of Honor Code violation penalties as recommended by the Honor Board.

Graduate School Policies and Procedures include complementary language that reflects these expectations.

Article 3: Violations of the Student Honor Code

Section 1: Honor Code Violations
A violation of the Student Honor Code is defined as any activity that interferes with the academic progress of a student through an unfair advantage, that may also disenfranchise another student(s). Violations of the Honor Code include without limitation:

(a) Plagiarism by presenting another person’s ideas, contributions, words, projects, creations, or other work as their own;

(b) Submission of the same assignment for credit in more than one course without prior authorization;

(c) Using, providing, or receiving unauthorized assistance or materials for any assignment or examination (especially in the instance of online assessments):

(i) Collaborating with others on independent assignments and activities;

(ii) Sharing materials with individuals not enrolled in the Graduate School;

(iii) Posting lectures or resource materials to external sites;

(iv) Recording audio or video of lectures without authorization;

(d) Falsifying, fabricating, or misrepresenting data and results as they relate to academic progress;

(e) Substituting for another student or having another student substitute for oneself to complete exams or assignments;

(f) Forging a signature or allowing forgery of any academic-related document;

(g) Engaging in any activity that places another student at an unfair disadvantage, such as taking, altering, or withholding resource materials;

(h) Failing to follow faculty instructions on exams or assignments that may compromise the integrity of the assignment;

(i) Maliciously accusing another student of violating the Honor Code;

(j) Retaliation or other malicious acts against the Reporting Person;

(k) Discussing or revealing confidential information pertaining to the Honor System;

(l) Complicity in Honor Code violations;

(m) Failure or refusal to sign the Honor Code Pledge; and

(n) Engaging in any acts of academic dishonesty.

Article 4: Student Rights

Section 1: Accused Student Rights
Any Accused Student(s) will be afforded the following rights and be given the opportunity to waive any of these rights to expedite the Honor System proceedings; such a waiver must be submitted to the Honor Board Chair in writing as a letter or email. The Honor Board Chair will make a final determination as to the appropriateness of a waiver and whether or not to accept the waiver.

(a) Individually participate in a pre-Hearing meeting, at least ten (10) business days prior to the scheduled Hearing, with the Honor Board Chair and Vice Chair to review the allegations, possible penalties, and Accused Persons rights;

(b) Access and review of all Graduate School Honor System policies and procedures;

(c) Written notification of any potential outcomes that will be levied from an alleged Honor Code violation;

(d) Contest the allegation(s) and request a Hearing;

(e) Privacy of the student’s educational records to the extent permitted or required by law;

(f) Presence of an Advisor or other support person during the Honor Board Hearing:

(i) The Advisor or support person may only be present at the Hearing and may not participate in the proceedings;

(g) A Hearing to determine culpability of the alleged Honor Code violation(s) if the Investigative Committee has found evidence to support such a Hearing;

(h) Decline to answer questions or provide self-incriminating evidence during Honor System proceedings:
(i) The Accused Student may elect not to be present at the Hearing with the understanding that any decision and subsequent penalties will be based on the information available at the Hearing in their absence;

(i) The ability to ask the Honor Board Chair questions pertaining to the Honor System and receive answers to the extent the Chair is permitted and able to respond;

(j) Provide and review appropriate information, including witness(es) written statements, that could be used in the Honor Board decision-making process:

(i) A written submission of all information, including potential witnesses, must be given to the Honor Board Chair at least eight (8) business days prior to the scheduled Hearing. No new information will be accepted for consideration after this time, unless express written permission is granted by the Chair.

(ii) The accused student and their Advisor or support person, if applicable, shall receive the case file five (5) business days prior to the scheduled Hearing for inspection.

(k) Request that information regarding the case, including witness(es) statements, be reviewed for relevance:

(i) The Honor Board Chair shall perform this review and submit a decision, with justification, in writing to the Accused Student and to the Reporting Person, five (5) business days prior to the scheduled Hearing. The Accused Student may appeal to the Dean of the Graduate School for reversal or modification of the Chair’s decision;

(l) Participate in the Hearing, including provide information or testimony, listen to witness testimony, and question the witness(es) through the Honor Board Chair;

(m) Have a decision and any resulting penalty, if applicable, be based on the Preponderance of Evidence standard;

(n) Request reasonable accommodations if disabled, in accordance with any applicable law:

(i) Student(s) in need of accommodations at any point during the Honor System proceedings should contact the Honor Board Chair as soon as possible;

(o) Submit an appeal of the Hearing Board decision, in writing, in accordance with Article 9;

(p) Request permission to participate in the Hearing via audio or video call-in from another location, and/or participate in such a manner that the Accused Student avoids direct contact with the Reporting Person, as long as the request does not infringe on the Accused Student’s right to question the Reporting Person or other witnesses through the Honor Board Chair, and does not impede the Honor Board’s ability to conduct the Hearing; and

(q) Receive written notification of the final outcome of the case.

Section 2: Reporting Person Rights
Any Reporting Persons will have the following rights afforded to them throughout the Honor System proceedings:

(a) Individually participate in a pre-Hearing meeting, at least ten (10) business days prior to the scheduled Hearing, with the Honor Board Chair and Vice Chair to review the allegations, possible penalties, and Reporting Persons rights;

(b) Access and review of all Graduate School Honor System policies and procedures;

(c) The ability to ask the Honor Board Chair questions pertaining to the Honor System and receive answers to the extent the Chair is permitted and able to respond;

(d) Provide appropriate information, including witnesses, that could be used in the Honor Board decision-making process:

(i) A written submission of all information, including potential witnesses, must be submitted to the Honor Board Chair at least eight (8) business days prior to the scheduled Hearing. No new information will be accepted for consideration after this time, unless express written permission is granted by the Chair;

(ii) The Reporting Person, and their Advisor or support person, if applicable, shall deliver the Reporting Person’s statement and any submitted information five (5) business days prior to the scheduled Hearing for review. The Reporting Person shall not be granted access to the entire case file;

(iii) The Reporting Person may submit any questions for the Accused Student to the Vice Chair at least eight (8) business days before the Hearing to be asked by the Chair during the Hearing;

(e) Ability to request that information or witnesses directly related to themselves be reviewed for relevance

(i) The Honor Board Chair shall perform this review and submit a decision, with justification, in writing to the Accused Student and to the Reporting Person, five (5) business days prior to the scheduled Hearing. The Reporting Person may appeal to the Dean of the Graduate School for reversal or modification of the Chair’s decision;

(f) Presence of their Advisor or other support person during the Honor Board Hearing:

(i) The Advisor or support person may only be present at the Hearing and may not participate in the proceedings;

(g) Participate in the Hearing, including providing information or testimony, listening to witness testimony, and answering questions raised by the Accused Student through the Honor Board Chair;

(h) Receive written notification of the final outcome of the case;

(i) Request permission to participate in the Hearing via audio or video call-in from another location, and/or participate in such a manner that the Reporting Person avoids direct contact with the Accused Student, as long as the request does not infringe on the Accused Student’s right to question the Reporting Person or other witnesses through the Honor Board Chair, and does not impede the Honor Board’s ability to conduct the Hearing; and

(j) Decline to answer questions or provide self-incriminating evidence during Honor System proceedings.

Article 5: Honor Board

Section 1: Honor Board Definition
The Graduate School Honor Board is made up of a panel of Graduate School students tasked with carrying out academic misconduct investigations, Hearings, and verdicts.

Section 2: Honor Board Members
Appointment to the Honor Board shall coincide with election as a Graduate Student Association Officer. Roles of each GSA Officer are defined in this Article 5 Section 2 subsection (a).

(a) Graduate Student Association Officer Position and Honor Board Appointment:

(i) GSA President: The President of the GSA will serve as the Chair of the Honor Board and be a non-voting Member.

(ii) GSA Vice President: The GSA Vice President shall serve as the head of the Investigative Committee and Vice Chair during Honor Board Hearings and be a non-voting Member.

(iii) GSA Chair of Diversity and Inclusion: The GSA Chair of Diversity and Inclusion shall serve as a voting member of the Honor Board during Hearings. The Chair of Diversity and Inclusion may be called upon to consult during an investigation.

(iv) GSA Cohort Representatives (PhD and Master’s): The GSA Cohort Representatives shall serve as voting members of the Honor Board during Hearings.

Section 3: Alternate Honor Board Members
The Honor Board will have a panel of Alternate Members that may be called upon to serve in instances where a conflict of interest exists, or impartiality cannot be maintained by the primary Honor Board Member(s). All students who appear on the ballot for the Graduate Student Association Executive Board will be asked to serve as Alternate Members and will undergo Honor System training along with the Honor Board Members.

Section 4: Advisory Staff and Faculty
Graduate School staff and faculty may be called upon by the Honor Board Chair to assist in Honor Code violation investigations and Hearings. Faculty and staff appointed by the Chair shall serve in an advisory capacity, unless otherwise specified.

Section 5: Impartiality
All Honor Board Members must remain impartial throughout the course of Honor System proceedings. In the event that impartiality cannot be maintained by an Honor Board Member, that Member must recuse himself or herself from the Honor System proceedings. The Honor Board Chair shall appoint an Alternate Member to serve during the Honor System proceedings in place of a recused Member(s). Specific Member appointment contingencies are listed below:

(a) Inability of a Cohort Representative to serve: The Chair shall appoint an Alternate Member to this position;

(b) Inability of Chair of Diversity and Inclusion to serve: The Chair shall appoint an Alternate Member to this position;

(c) Inability of the Vice Chair to serve: The Chair of Diversity and Inclusion shall be appointed to the role of the Vice Chair, and as such head the Investigative Committee. An Alternate Member shall be appointed by the Chair to fill the vacancy left by the Chair of Diversity and Inclusion; or

(d) Inability of the Chair to serve: The Vice Chair shall be appointed to the position of the Chair and the procedure for replacing the Vice Chair enacted.

Should an Honor Board Member not recuse, and a conflict of interest is later discovered, that Member shall be subject to an Honor System proceeding. In this instance, the Chair may elect to reopen the initial case as well.

Article 6: Administration of Honor System

Section 1: Responsibilities for Administering the Honor System
All Graduate School students, faculty, and staff shall be made aware of the Honor System through the following channels:

(a) The Honor System shall be posted to the Graduate School website, and students, staff, and faculty will be given instructions on how to access it;

(b) Incoming first-year students shall receive an introduction to the Honor System during their orientation and will sign the Honor Code Pledge at that time. These signatures will be submitted to the Registrar to become part of each student’s official file;

(c) Students may inquire about Honor System policies and procedures to the Honor Board Chair at any time;

(d) Honor Board Members and Alternate Members shall receive annual Honor System training during Graduate Student Association Officer turnover.

Section 2: Responsibility and Procedure for Reporting Violations
All Graduate School students, staff, and faculty must report a reasonable belief of student academic misconduct in a timely fashion through the process outlined below:

(a) Reporting process: A Graduate School student, staff, or faculty member shall report perceived violations of the Honor Code to any primary Member of the Honor Board within five (5) business days of witnessing the alleged violation. Honor Board Members must then report the allegation to the Honor Board Chair within two (2) business days of receiving the report.

(b) Written documentation of the date(s) and all personnel involved will be documented in a formal report to maintain a timeline of Honor System proceedings.

Section 3: Investigations of Alleged Honor Code Violations
Upon receipt of an Honor Code violation report, the Honor Board Chair shall notify the Vice Chair to initiate an investigation of the alleged violation. The Chair shall also assign two Alternate Members to the Investigative Committee who will serve under the Vice Chair, as the Head of the Investigative Committee. The Investigative Committee will investigate and determine the facts of the alleged violation. The Vice Chair will then submit a written report summarizing the findings of the Investigative Committee to the Chair and a determination on the merits of the allegation.

(a) If the Vice Chair does not find a Preponderance of Evidence to support a formal charge, the Chair shall review this recommendation and justification and determine if the finding is appropriate. If the Chair agrees the Preponderance of Evidence has not been met, they shall dismiss the formal charge.

(b) If the Vice Chair determines that there is sufficient evidence to support that the alleged violation has occurred, they will recommend the Chair issue a Notice of Charge. The Chair shall review the recommendation and evidence to determine if the Notice of Charge is appropriate; if so, a written Notice will be sent to the Accused Student, Reporting Person, and the Graduate School Dean.

(i) The identity of the Reporting Person will remain confidential throughout the investigation. If a Notice of Charge is issued, the Accused Student will then be notified of the name(s) of the Reporting Person(s) by request to the Honor Board Chair.

Section 4: Notice to the Accused Student and Response from the Accused Student
Upon determining there is sufficient evidence to support a charge of Honor Code violation, the Chair shall issue a Notice of Charge to the Accused Student, to which the Accused Student must respond.

(a) Notice of Charge must be a written document delivered to the Accused Student within three (3) business days of determining such a charge should be issued. The Notice of Charge shall include:

(i) Factual basis of the charge(s);

(ii) The student’s right to a Hearing if the charge(s) is contested;

(iii) Penalties that may be incurred if the Accused Student is found to be culpable during a Hearing;

(iv) The proposed penalties if the student waives their right to a Hearing;

(v) The contact information of the Chair so the Accused Student may request a Hearing;

(vi) A statement indicating that the request must be received no more than seven (7) business days from the Notice of Charge issue date; and

(vii) A statement indicating the Accused Student’s right to a faculty advisor or support person.

(b) Upon receipt of the Notice of Charge, the Accused Student must submit a written response to the Honor Board Chair no more than seven (7) business days from the issue date of the Notice of Charge and include:

(i) Acknowledgement of the charge and that they agree to accept the proposed penalties; or

(ii) Denial of the alleged violation and a request for a Hearing to contest the charge(s).

(c) Notice of Charge and the Accused Student response must be delivered either electronically or through the mail.

(i) Electronic documents will be sent using students’ St. Jude email addresses.

(ii) Documents sent through USPS will be addressed to the student’s address on file with the Registrar.

Section 5: Honor Board Hearing Procedure
If a Hearing is requested by the Accused Student, the Chair shall schedule an Honor Board Hearing. All Honor Board Members (primary and any selected alternate) must be present, excusing students enrolled in distance-learning programs when off-campus. Once scheduled, the Chair will issue a notice of Hearing date, time, and location to the Accused Student and Reporting Person. Honor Board Hearings must meet the following standards:

(a) All Final Determinations will be decided by majority vote of the Honor Board voting Members according to the Preponderance of Evidence Standard;

(b) Honor Board voting Members shall determine the weight of presented evidence and credibility of witnesses;

(c) The facts of the case will be determined by the Honor Board in a closed session following the Hearing. Only evidence presented during the Hearing will be considered;

(d) Hearings will be audio recorded only and will be the sole property of the Graduate School;

(e) Only material evidence will be considered during the Hearing, in accordance with Article 4 Section 1 Subsection (j) and Article 4 Section 2 Subsection (e);

(f) The Accused Student and Reporting Person will have the opportunity to present relevant information;

(g) Witnesses:

(i) May be arranged by the Accused Student and Reporting Person to voluntarily present;

(ii) Witness questions will be facilitated through the Chair:

(1) Questions will be preliminarily reviewed by the Chair, and any deemed inappropriate may not be asked;

(iii) Witnesses will not be sworn in but will be told they are required to tell the truth:

(1) Witnesses found to be untruthful in their testimony may face a separate Honor Code violation charge;

(iv) Witnesses may submit a written testimony in lieu of appearing in person at the Hearing:

(1) This testimony shall be read aloud, and the Accused Student and Reporting Person given the opportunity to respond or rebut the testimony;

(v) Inability or unwillingness of a witness to appear at the Hearing shall not invalidate the Hearing;

(h) A student or witness may choose not to answer any or all of the questions posed to them during the Hearing;

(i) The Accused Student or Reporting Person may identify Honor Board Member(s) that they feel have a conflict of interest or will be unable to remain impartial throughout the Honor System proceedings and request the recusal of that Member(s). The Honor Board Chair shall review the request and make a Final Determination; this decision may be appealed to the Dean of the Graduate School for reversal or modification.

(j) All Hearings shall be conducted in private;

(k) In cases involving multiple related allegations, information provided in relation to one allegation may be used in consideration of another allegation if relevant;

(l) In general, Hearings should proceed as follows:

(i) Review of Hearing protocol

(ii) Review of allegation(s)

(iii) Introductory statements from the Accused Student and Reporting Person

(iv) Presentation of evidence by the Vice Chair

(v) Questioning of witnesses by the Chair

(vi) Presentation of evidence by the Reporting Person and questioning of the Reporting Person by the Honor Board Hearing Panel

(vii) Presentation of evidence by the Accused Student and questioning of the Accused Student by the Honor Board Hearing Panel

(viii) Closing statements from the Accused Student and Reporting Person

(ix) Deliberation of the Honor Board (closed to everyone but Honor Board Members, and not recorded)

(x) The Honor Board may elect to verbally share their Final Determination with the Accused Student.

Section 6: Notice of Final Honor Board Determination
Upon Final Determination of the Honor Board, the Chair shall submit in writing the Final Determination to the Accused Student, Reporting Person, and Graduate School Dean within 2 business days after the conclusion is reached.

(a) The Honor Board shall find the Accused Student “Responsible” or “Not Responsible”;

(b) The rationale or evidence leading to this finding;

(c) If the Accused Student is found to be Responsible, the Final Determination notification shall include recommended penalties; and

(d) The final notice shall include applicable information on the appeal process.

(e) Record of Honor Board proceedings will be maintained in the Registrar’s file, even in instances when the Accused Person withdraws from the program before the penalties are levied.

Article 7: Honor Code Violation Penalties

Section 1: Upon finding the Accused Student Responsible, the Honor Board shall recommend one of the following penalties be incurred by the accused student:

(a) Formal reprimand: The Accused Student shall receive a formal reprimand, and this reprimand will be sent to the Registrar to be included in the student’s official file;

(b) Failure of the assignment: If the Honor Board finds cause that the Accused Student should fail the assignment (including Laboratory work milestones), this recommendation will be submitted in writing to the Graduate School Dean, who is tasked with communicating this penalty to the faculty member that gave the assignment;

(c) Failure of the course: If the Honor Board finds cause that the Accused Student should fail the course in which the violation occurred, this recommendation will be submitted to the Graduate School Dean, who is tasked with communicating this penalty to the appropriate Course Leader(s);

(d) Suspension: If the Honor Board finds cause that the Accused Student’s violation warrants suspension, this finding will be submitted to the Graduate School Dean in writing. The Graduate School Dean shall review the recommended penalty and its rationale and make the Final Determination of whether or not to suspend the Accused Student; or

(e) Expulsion: If the Honor Board finds cause that the Accused Student’s violation warrants expulsion, this finding will be submitted to the Graduate School Dean in writing. The Graduate School Dean shall review the recommended penalty and its rationale and make the Final Determination of whether or not to expel the Accused Student from the program.

Section 2: Requirements of the Graduate School to Comply with the Honor Board’s Recommendations
Upon submission of a ‘Responsible’ Final Determination by the Honor Board to the Graduate School Dean, the Graduate School shall be responsible for fulfilling the proposed penalties.

(a) If an appeal is not filed by the Accused Student, as outlined in Article 8, the Graduate School Dean must review the penalty put forth within the Final Determination and communicate with the necessary parties (i.e. Faculty, Graduate School Staff, etc.) to ensure the penalty is carried out within 10 business days.

(b) If an appeal if filed by the Accused Student, as outlined in Article 8, the Graduate School Dean must review the appeal and Final Determination to determine if the appeal is justified or if the penalty proposed in the Final Determination has merit. The Dean shall come to a decision and impose either the Honor Board’s recommended penalty or a modified penalty and communicate his decision to the appropriate parties (i.e. Accused Student, Faculty, Graduate School Staff, Honor Board, etc.). The Dean must also ensure that whatever penalty he or she deems appropriate is carried out; this decision and enforcement must occur within 10 business days of receipt of the appeal.

Article 8: Appeals

Section 1: Appeals process
All Accused Students found “Responsible” for an Honor Code violation by the Honor Board may appeal the Honor Board’s penalty recommendation to the Graduate School Dean. A written request and justification must be submitted, as a letter or an email, within 10 business days of receipt of the Honor Board’s Final Determination.

(a) The appeal may only address the recommended penalty, not the Honor Board’s finding that an Honor Code violation was committed;

(b) The Accused Student has the burden of proving the recommended penalty is unreasonable;

(c) The Dean of the Graduate School shall send a written decision to the Accused Student within 10 business days of receipt of the appeal. This decision will also be sent to the Registrar to be maintained in the Accused Student’s records.

Article 9: Adoption and Amendments

Section 1: Amendments to the Honor System may be proposed by any Honor Board Member at any point during the academic year. A special meeting of the primary Honor Board Members to discuss the proposal shall be scheduled and proposed amendments must be circulated in writing to the Honor Board at least two weeks prior to this meeting. Amendments must be seconded and considered only after a 2/3 anonymous ballot vote of the Honor Board.

Section 2: Amendments that pass Honor Board consideration shall then be circulated to all Graduate School students two weeks prior to holding a general election for acceptance and adoption. Amendments will require a 2/3 affirmative vote from the Graduate School students to be adopted.

Section 3: The newly adopted Honor System or Honor System Amendments shall supersede any previous Honor System and shall be the sole Honor System of the St. Jude Graduate School of Biomedical Sciences.

The SVP/COO retains all records permanently.

The Graduate School defines academic integrity as the pursuit of scholarly activity in an open, honest, and responsible manner. All students shall act with personal integrity; respect other students’ dignity, rights, and property; and help create and maintain an environment in which all can succeed through the fruits of their efforts. Dishonesty of any kind will not be tolerated. Dishonesty includes, but is not limited to, cheating, plagiarism, and fabricating or falsifying information or citations; facilitating acts of academic dishonesty by others; having unauthorized possession of examinations; submitting work of another person or work previously used without informing the instructor; and tampering with the academic work of other students. Students who are found to be dishonest will receive academic sanctions and will be reported to the Graduate School Administration for possible further disciplinary sanctions, up to and including expulsion.

The St. Jude Graduate School Code of Conduct outlines the principles for how we conduct ourselves and perform our duties. This Code applies to all researchers, physicians, students, employees, volunteers, board members, and anyone who is conducting work on behalf of the Graduate School. Following this Code ensures that we pursue the Graduate School mission with the highest standards of integrity and that we continually earn and maintain the trust of those who look to us as a world leader in the academic community.

Ethical behavior is essential to the Graduate School mission. We are only as strong as our reputations as individuals and as an institution, which includes a commitment to respect ethnic, cultural, religious, and lifestyle differences of patients, their families, colleagues, students, and supporters. It also includes a commitment to ensure a culture of excellence, innovation, and creativity in research, scholarship, and everything we do.

A drive and sense of urgency to succeed

• Honesty, integrity, and accountability in actions and decisions
• A culture of trust and teamwork
• Respect for employees and students under our supervision
• A commitment to the continuous development of our employees and students
• A commitment to diversity
• A commitment to local, state, national, and global social responsibility and institutional citizenship

This Code supplements policies and procedures that provide more detailed guidance and documents and fosters our commitment to ethical conduct and compliance throughout the institution.

In 2018, the Honor Code was established as an agreement between student and faculty to uphold a high standard of academic integrity at the Graduate School.  The underlying spirit of the Honor Code is trust and commitment to original academic work which pervades the St. Jude community.

All examinations, quizzes, homework assignments, and research are subject to the Honor Code.  After a thorough review of the Honor Code, students pledge their honor that they will abide by its terms.  In exchange, faculty proctors need not be present in examination rooms.  Additionally, students pledge a duty to report all suspected violations of the Honor Code to the Honor Committee or one of the deans of the Graduate School.  The foundation of the Honor Code emphasizes the student-to-student accountability.

The Honor Committee is a group of five appointed members of the graduate student body and they are responsible for upholding the Honor Code.  The members follow the constitutionally mandated procedures to ensure a fair and unbiased result of the investigation and adjudication of an alleged Honor Code violation.

The Honor Code is available in the office of the Graduate School.

Students are required to attend St. Jude’s Responsible Conduct of Research (RCR) Training Program. This training is based on a formal, comprehensive series of didactic lectures and discussion groups led by senior faculty and administrators. RCR training opportunities are currently provided monthly, with each session lasting one hour. Each student is required to obtain an annual minimum of eight hours of RCR training at face-to-face lectures and discussions.

The St. Jude RCR curriculum is complemented by the Collaborative Institutional Training Initiative (CITI) online courses on the protection of human participants and RCR; all students will complete this course as part of orientation. In addition, the CITI RCR Training Program in Biomedical or Social & Behavioral Research provides a detailed overview of 10 core areas involved in RCR, which students are expected to complete within the first four months of the program.

80.60.002: Information eSecurity Acceptable Use Agreement

Purpose

To document the desired behaviors and practices regarding the acceptable use of the Hospital’s and the Graduate School’s information systems.

In following the acceptable use agreement, you agree to:

1. General Use

A. Exercise good judgment regarding the protection and security of the Hospital and the Graduate School information assets. Failure to follow security policies and standards could place the Hospital and the Graduate School in violation of laws and regulations such as the Health Insurance Portability and Accountability Act (HIPAA) and Protection of Student Data.

B. Exercise good judgment when communicating as a member of the Graduate School over email, social media or other technology. Members of the Graduate School should not use language that may be offensive, obscene, sexually explicit, threatening, intimidating, discriminatory, retaliatory, or harassing.

C. Promptly report the theft, loss, or unauthorized disclosure of the Graduate School Confidential or Protected information (e.g., grades, student information, proprietary information) to the Graduate School and Information Security Office.

D. Use of Hospital or Graduate School technologies (network, Internet, email, computers, files shares and applications) is done so with the understanding that they are monitored for security purposes and there is no right to or expectation of privacy when using Hospital or Graduate School owned technology. The Hospital or the Graduate School reserves the right to access, monitor and disclose contents of the Internet, email, and voice mail messages or other communications made through the Hospital or Graduate School owned systems.

E. Use of Hospital or Graduate School information systems with the understanding that occasional personal use is allowed provided it is not associated with a personal business, does not interfere with productivity, and does not preempt legitimate Hospital or Graduate School business activity.

F. Refrain from attempting to test, circumvent, or defeat any security system or monitoring capability.

G. Refrain from using Hospital or the Graduate School information systems to engage in any unlawful or obscene activities that could put Hospital and/or the Graduate School at risk. Examples include, but are not limited to, the following:

1. Gaining unauthorized access to any information system or network.
2. Damaging, altering, or disrupting the operations of any information system or network.
3. Making any inappropriate or discriminatory statements based on race, religion, national origin, sex, sexual orientation, transgender status, gender identity or expression, disability or veteran status.
4. Accessing, reading, copying, storing or forwarding inappropriate or sexually explicit messages or materials.
5. Engaging in illegal, fraudulent, or malicious conduct.

2. Asset Usage

A. Physically secure all Hospital and the Graduate School assets taken off-site at all times. Mobile devices should not be left in unattended bags, luggage, or vehicles.

B. Return all Hospital and the Graduate School issued assets upon termination of employment, contract, or agreement. Access to Hospital and Graduate School systems, networks, and facilities will be disabled upon termination.

C. Use personal devices to store or access Hospital and Graduate School information only when authorized to do so and in accordance with defined policies and standards for personal devices.

3. Clear Desk/Clear Screen

A. Log off from applications or network services when they are no longer needed and lock workstations when leaving your workspace unattended.

B. Control physical access to Confidential or Protected information at all times to prevent unauthorized access, e.g. lock doors to offices and file cabinets, do not leave Confidential or Protected documents in view, stay with visitors in areas with Confidential or Protected information, and do not leave Confidential or Protected information on and immediately remove from fax machines and printers.

4. Data Protection

A. Refrain from transferring or storing electronic protected health information (ePHI) or student protected data to a cloud-based service that has not been approved by Information Services and the Office of Legal Services. Using an unauthorized cloud-based service for ePHI and student data may be a violation of HIPAA and the Hospital’s requirement to perform due diligence on all third-parties that process or store ePHI and the Graduate School’s requirement to safeguard student records.

B. Use only authorized technologies, applications, and/or services verified to meet Hospital and Graduate School security requirements. If an alternative application or cloud-based service must be used, you agree not to transfer or store sensitive or confidential information on such applications or services.

C. Do not forward Hospital or Graduate School business related emails containing Confidential or Protected information to a personal account.

5. Information System Access

A. Maintain the confidentiality of authentication credentials you have been entrusted with (e.g. passwords, PINS, badges, etc.). Your authentication credentials must not be shared.

B. Create and change your passwords in accordance with Hospital Information Services password requirements (e.g. password length, password composition).

C. Be responsible for all activities that use your credentials.

6. Physical Security

A. Dispose of any electronic media containing Confidential or Protected information in accordance with Hospital and Graduate School disposal policies and standards.

B. Dispose of any paper containing Confidential or Protected Information securely using a locked disposal container or cross-cut paper shredder.

C. Refrain from using photographic, video, audio or other recording equipment, such as cameras in mobile devices, unless authorized.

7. Removable Media

A. Encrypt all removable media used to store Confidential or Protected information.

B. Refrain from connecting a removable media device from an unknown origin to a Hospital or Graduate School computer or information system as it may contain malware.

80.90.001: Procedures Governing Legal Affairs

Derived from St. Jude policy 10.04.001 (Owner, Katherine B. Steuer)

Purpose and Scope

• This policy is established to ensure the effective coordination of the legal affairs of the Graduate School, including engagement and supervision of outside counsel, when necessary.
• This policy applies to all Graduate School faculty, employees and students.

Definitions

• Process server - a person authorized to serve process (any non-party aged 18 years or older). 
• Subpoena - a court order commanding a person to appear in person or to produce documents or other evidence. 
• Subpoenas duces tecum - court order requiring the recipient to produce documents or other tangible evidence.

Policy

• The St. Jude Chief Legal Officer (CLO) or his/her chosen designee, who must be a licensed attorney in the state of Tennessee, shall be responsible for advising and consulting with the Graduate School Dean regarding legal aspects of the Graduate School operations.
• The CLO or designee shall advise the deans of the Graduate School with regard to local, state (TN), and federal regulatory and legal obligations. Assist with accreditation compliance, internal academic disciplinary, research integrity, and student conduct investigations.
• Scientific misconduct by a St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences student is investigated under St. Jude’s Research Integrity policy 70.05.001. See policy ? for more details.
• The CLO or designee must initiate the engagement of any outside counsel. The CLO or designee shall serve as liaison with outside law firms, oversee Graduate School legal obligations, manage litigation, and coordinate legal negotiations to achieve the most economical use of outside representation.

Procedure

• All correspondence, communications and contact regarding the legal affairs of the Graduate School shall be coordinated with the CLO or designee. Whenever a problem in the Graduate School is identified as requiring legal advice or legal representation, the appropriate employee shall contact the CLO or designee immediately. Without regard to which cost center will ultimately be responsible for payment of an invoice, all invoices for Graduate School legal services must initially be submitted by outside counsel to the St. Jude Office of Legal Services. The CLO or designee is responsible for reviewing all invoices to ensure economical and appropriate handling of the matter.
• If the CLO or designee determines that engaging outside counsel is necessary for effective representation of the Graduate School in a particular matter, and that the engagement reasonably could be expected to exceed $100,000, the CLO or designee, in accordance with allowable disclosure, shall advise the Graduate School Dean and the St. Jude CEO of the nature of the matter.
• As Registered Agent for St. Jude and the Graduate School, the CLO or designee accepts and signs for:
  • Properly served process (including civil summonses and subpoenas) for the Graduate School. Properly served includes service by process server, unless the CLO or designee agrees to waive service, and confirming that all out-of-state subpoenas are properly domesticated in Shelby County;
  • Appropriate requests, administrative orders including but not limited to garnishment orders and subpoenas, and subpoenas duces tecum, to the Graduate School for employee records, payroll, and benefits. The CLO or designee forwards the request to St. Jude Human Resources (HR) and immediately notifies the employee. In addition, HR notifies the CLO or designee of any requests for Graduate School employee records, payroll, and benefits records that it receives from an attorney or law firm, court, or other entity;
  • Any request from an attorney or other person for expert or other similar information and all appropriate summonses and subpoenas for depositions of the Graduate School faculty or employees in their professional capacities as set forth in policy 10.04.007 and relevant provisions of the St. Jude Faculty Handbook. The St. Jude Office of Legal Services is available to assist Graduate School faculty and employees with responding to such requests.
  • Subpoenas related to any type of administrative employment action (i.e., Equal Employment Opportunity Commission, Employment Security Office Complaint) involving a Graduate School employee or former employee.

References

• Tenn. R. Civ. P. 4.01, 4.04, 45TCA § 39-16-602
• TCA §§ 24-9-201- 24-9-205

80.90.002: Contact with Federal, State and Local Officials

Derived from St. Jude policy 10.04.004 (Owner, Robert R. Clark)

Purpose and Scope

• It is often appropriate for the Graduate School employees and students to communicate with elected officials for public policies to be crafted to advance the mission of St. Jude or the Graduate School. It is critical that this communication be coordinated with other institutional efforts.  This policy outlines the position on official visits to St. Jude or the Graduate School by candidates seeking election for a political office and their representatives.
• An official visit is defined as one that is documented and shared publicly for the purpose of publicity via press, social media, email, or any other communications method by a politician and/or his or her representative(s) or by the press in attendance. The policy includes candidates seeking a political party’s nomination and those actively campaigning as candidates and their representatives as determined by St. Jude.
• This policy applies to all Graduate School students and employees.

Policy

• The St. Jude Office of Government Affairs (OGA) serves as the primary point of contact with elected officials, candidates, and their representatives on all public policy issues and communications on behalf of the Graduate School . This includes, but is not limited to, written communication, public testimony, in-person meetings, visits to campus, and any other form of policy endorsement, opposition, or negotiation. The OGA, reports to the St. Jude SVP/Chief Legal Officer and works closely with the St. Jude VP/Communications and St. Jude Liaison Office. The OGA is responsible for considering and responding to all requests in light of the Graduate School interests and official positions on public policy matters.
• As a Tennessee nonprofit LLC, the Graduate School is permitted by federal law to participate in non-partisan activities; however, it is not allowed to engage in partisan political activities.

It is important for politicians and candidates for elective office to better understand the issues of biomedical education and research and St. Jude and the Graduate School wish to promote better understanding among public officials of these critical medical, educational, and scientific issues.

• This policy sets forth procedures to be followed by the Graduate School in responding to requests by politicians and candidates for public office at local, state, federal and international levels to visit or tour the Graduate School. The purpose is to ensure compliance with applicable regulations relating to the Graduate School status as a not-for-profit organization that is not allowed to engage in partisan political activities.

Communication with Federal, State or Local Elected Officials or their Representatives

• The Graduate School employees shall coordinate communication with elected officials and/or their representatives through the SVP/COO and the St. Jude OGA; if the SVP/COO reasonably determines that advance coordination with the OGA is not possible, the OGA will be notified immediately after contact is made with an elected official and/or their staff.
• If a Graduate School employee is contacted directly by an elected official and/or their representatives, the employee will notify the SVP/COO who will notify the OGA as soon as possible.
• The OGA is responsible for coordinating with the SVP/COO, St. Jude Communications, and the St. Jude Liaison Office, which works with ALSAC as necessary to respond to any requests.
• Responses to requests and final plans are reviewed and approved by the Dean.

Responses to Politicians and Candidates Seeking a Tour of the Graduate School

• Requests by politicians or candidates for elected public office and/or their staff for visits to or tours of the Graduate School should be coordinated with the OGA.  Any person who meets the established visit criteria for public and private tours, including health and age, is welcome to schedule a visit via established booking methods. Individuals actively campaigning for political office or seeking nomination from a political party and their representatives are welcome to visit the Graduate School in a non-partisan, information-seeking capacity only.
• As a Tennessee nonprofit LLC the Graduate School may not endorse or oppose any politician or candidate, allow campaign literature to be distributed on its or hospital premises, or be involved in any campaign fundraising. Graduate School employees should not use their St. Jude email, St. Jude social media, or other St. Jude or Graduate School channels to engage in political activities or to endorse or support a specific candidate. This policy does not restrict a citizen’s right to support or oppose any politician or candidate in their personal time.
• The Graduate School will not allow individuals seeking elected office or a party nomination or their representatives to use a visit to the Graduate School for partisan or campaign purposes, including capturing photo, video, or testimonials from the visit and sharing those with press, social media, or via email or any other communication channels. The Graduate School welcomes visits from those who currently hold and those who formerly held elected public office, but St. Jude reserves the right to determine whether those visits may be publicized on a case-by-case basis. Any campaign-related activity is strictly prohibited.
• Upon receiving a request from an individual currently holding elected public office, or that individual’s representatives, the OGA will:
  • Explore with the elected official what he or she seeks to do at the Graduate School (tour, give speech about health-related, research, or educational issues, or receive a briefing about the research and education at the Graduate School), and explain the restrictions for each activity;
  • Share this policy with any Graduate School employees working on the event to make sure they understand the restrictions;
  • Ensure that all materials produced in connection with the appearance include a disclaimer stating that the activity is in no way intended to reflect an endorsement for, or opposition to, any politician, candidate or political party;
  • Coordinate with the Graduate School, St. Jude Communications, and the St. Jude Liaison Office with final pre-approval of any visit to be given by the Graduate School Dean; and
  • In the case of a current candidate for elective office who seeks to visit the Graduate School, contact other candidates for the elected office and communicate to them that they are welcome to request a similar visit to the Graduate School.

Patient Confidentiality and Media Coverage

• When an elected public official requests a tour of the Graduate School, he or she may want to be accompanied by media/press. As with all VIP tours, these tours and visits must never interfere with students’ academic pursuit dignity and/or privacy. It is important that sensitivity to these concerns be maintained and tours and visits comply with the Family Educational Rights and Privacy Act (FERPA) and all other applicable student privacy and confidentiality statutes and standards of ethics. No photography or filming of students is allowed unless written consent is obtained from the students and has been approved in advance and in accordance with FERPA and ALSAC.
• The Graduate School will consider requests by elected public officials, but reserves the right to exclude all press/media. Advance notice (generally 48 hours) is required to allow the Graduate School employees time to make arrangements that will accommodate the request consistent with its standards. The Graduate School, if press/media are allowed, may require that press/media coverage and/or cameras be “pooled” to reduce numbers of camera operators and reporters who will be present. If the presence of press/media is authorized by the Graduate School, press/media will only be allowed in area(s) of the Graduate School as designated by the Dean or SVP/COO and the hospital as designated by the OGA and the Vice President of Communications.

80.90.003: Depositions in Legal Proceedings

Derived from St. Jude policy 10.04.007 

Purpose and Scope

• This Policy applies to all Graduate School employees and students.
• The purpose of this policy is to set forth the procedures regarding taking testimony of a professional staff member in a pending court proceeding by deposition.

Definitions

• Deposition - A witness' out-of-court testimony that is reduced to writing, usually by a court reporter, for later use in court or for trial discovery purposes.
• Expert testimony - Testimony about a scientific, technical, or professional issue given by a person qualified to testify because of familiarity with the subject or special training in the field. 
• Expert witness - A witness qualified by knowledge, skill, experience, training, or education to provide a scientific, technical, or other specialized opinion about the evidence. 
  
• Factual testimony - Testimony as to an individual’s personal knowledge of events. 
• Fact witness - A witness who usually has no stake in the outcome of the lawsuit or legal proceeding, yet may possess critical information related to the lawsuit or legal proceeding.
• Subpoena - A Court Order commanding a person to appear and/or bring specified documents or records.

Policy

• The Graduate School employees and students will not act as consultants, advisors, or expert witnesses in legal cases in which the Graduate School or St. Jude is not a party. If the requested deposition or testimony does not involve the Graduate School or St. Jude, the St. Jude OLS will decline the request in accordance with established policy.
• In legal matters where factual testimony, not expert testimony, is required by law and is evidenced by legal documentation such as a subpoena, the Graduate School employees and students, under the guidance and direction of the St. Jude OLS, will comply with that court-ordered request.

Procedures

• When an employee or student is served with a subpoena directing him or her to appear and give testimony by deposition in a pending court proceeding, the employee or student should promptly notify the OLS.
• Employees and students should not speak directly with non-St. Jude attorneys or law firm personnel.
• The OLS will assess the validity of the subpoena or court order and advise the requesting party that all future communications should be routed through the St. Jude Office of Legal Services. 
• When factual testimony is required by law, the OLS will collaborate with the employee or student and outside legal counsel (as needed) to ensure the Graduate School employee or student is adequately prepared to give any testimony that might be required.
  • Graduate School employees and students should refrain from reviewing medical records or engaging in other activities aimed at familiarizing themselves with the matter at issue until being advised to do so by an attorney in the OLS.
  • The OLS will make every effort to work around any scheduling conflicts the Graduate School employee or student may have, including the need to be available to perform Graduate School job duties, and will make every effort to schedule testimony on a date and in a location that is convenient for all parties. 
  • Graduate School employees and students are expected to assist in the scheduling of testimony by being responsive to scheduling requests from the OLS and by making themselves available for appointments with St. Jude’s outside legal counsel and/or related legal proceedings. 
• During the deposition the deposing attorney or anyone else present at the deposition should not have access to, make copies of, or remove a medical record, unless expressly authorized by a St. Jude attorney or St. Jude’s outside legal counsel.
• If a Graduate School employee or student is subpoenaed to give testimony in a court proceeding, the Graduate School is entitled to reimbursement for the employee time required to prepare for and participate in the deposition according to the fee schedule below:
  • Minimum first hour $300 
  • Every 1/2 hour thereafter $125
    
• The employee or student participating in the deposition shall advise the OLS, in writing, of the time spent in preparation for and during the deposition.
   

80.90.004: Expert Witness Legal Testimony

Derived from St. Jude policy 10.04.008 

Purpose and Scope

• The purpose of this policy is to set forth the limited circumstances in which the Graduate School employees and students may provide testimony related to their role at the Graduate School. This policy applies to all Graduate School employees and students.
• On occasions when a Graduate School student or employee is called upon to serve as a behind-the-scenes consultant, case preparation consultant, or consulting expert witness, give interviews, or render expert opinions in a legal matter when the Graduate School or St. Jude is not a named party in the legal matter. In such cases, the Graduate School employee and student will not act as consultant, advisor, or expert witness.
• In legal matters where factual testimony, not expert testimony, is required by law and is evidenced by legal documentation such as a subpoena, the Graduate School employee and student will comply with that court-ordered request.

Definitions

• Expert testimony - Testimony about a scientific, technical, or professional issue given by a person qualified to testify because of familiarity with the subject or special training in the field.
• Expert witness - A witness qualified by knowledge, skill, experience, training, or education to provide a scientific, technical, or other specialized opinion about the evidence.
• Factual testimony – Testimony as to an individuals’ personal knowledge of events.
• Subpoena - An order commanding a person to appear and/or bring specified documents or records.

Procedure

• If a non-St. Jude attorney contacts a Graduate School employee or student about serving as a behind-the-scenes consultant, assisting with case preparation, or serving as a consulting expert witness, giving interviews, or rendering expert opinions in a legal matter, the Graduate School employee or student should immediately refer the requestor to the OLS.
• Any subpoenas or court orders received by an employee or student for legal testimony (of any type) related to that individual’s role at the Graduate School must be referred immediately to the OLS. Employees and students should not speak directly with non-St. Jude attorneys or law firm personnel. The OLS will assess the validity of the subpoena or court order and advise the requesting party that all future communications should be routed through the OLS. 
• When factual testimony is required by law, the OLS will collaborate with the employee or student and outside legal counsel (as needed) to ensure the Graduate School employee or student is adequately prepared to give testimony. 
• Graduate School employees and students should refrain from reviewing medical records or engaging in other activities aimed at familiarizing themselves with the matter at issue until being advised to do so by an attorney in the OLS. 
• The OLS will make every effort to work around scheduling conflicts the Graduate School employee or student may have, including the need to be available to perform Graduate School job duties, and will make every effort to schedule testimony on a date and in a location that is convenient for all parties. 
• Graduate School employees are expected to assist in the scheduling of testimony by being responsive to scheduling requests from the OLS and by making themselves available for appointments with St. Jude’s outside legal counsel and/or related legal proceedings.

80.90.005: Litigation Hold

Derived from St. Jude policy 10.04.010 (Owner, LaResa Young)

Purpose and Scope

• This policy applies to all Graduate School employees and students.
• Outline the steps that must be taken to initiate, implement, preserve, monitor, and release litigation holds for paper and electronic records and related Electronically Stored Information (ESI) in response to a triggering event. 
• Documents, records, data, and health information include both paper and electronic form.

Definitions

• Documents, Records, Data and Electronically Stored Information (ESI) (collectively, "records")’ - any paper or electronic record, correspondence, or file that was created, received, or maintained in the course of business. This includes the original and all drafts, copies, and versions, including duplicate documents or near-duplicate documents. The terms also include all metadata attached to or embedded within a document. They further include any attachments or links connected to a document. A non-exhaustive list of documents, data, and ESI includes:
  • Email (including archived, sent, and deleted)
  • Word Processing documents
  • Calendars
  • Medical records
  • Research data
  • Spreadsheets
  • Voice messages
  • Instant messages
  • Text messages
  • Videos
  • Photographs
• Documents, records, data, or ESI may be created, received or maintained in a variety of formats including, but not limited to:
  • Servers
  • Memory sticks
  • Internet (e.g. blogs or websites)
  • Desktop or laptop hard drives (both work and personal)
  • CD-ROMs
  • Social networking sites or social media (e.g. Facebook, Twitter)
  • Tapes
  • Other removable storage media
  • Cloud environment
  • Zip disks
  • Smartphones
  • Flash drives
  • Mobile devices
• ‘Personnel’ - every person in the Graduate School, including but not limited to Graduate School employees, students, individuals not on payroll, volunteers, and any other individual responsible for maintaining records.
• ‘Litigation Hold’ - a suspension of a company’s document retention/destruction policies for those documents that may be relevant to:
  • a lawsuit that has been actually filed, or one that is reasonably anticipated;
  • a governmental regulatory inquiry that has been actually initiated, or that is reasonably anticipated; or 
  • preservation obligations imposed by law. 
  • A Litigation Hold ensures that relevant data are not destroyed and that personnel who may have relevant records are notified of document preservation requirements. Informal procedures for managing print or electronic documents, such as recycling e-mail backup tapes or scrubbing laptops and re-issuing them to new employees must change when under a Litigation Hold.
• The ‘Litigation Response Team’ oversees the Litigation Hold Process. It comprises one attorney and the Legal and Risk Analyst, plus assigned Information Services staff. 
• ‘Office of Legal Services ("OLS")’ - the St Jude department responsible for managing Litigation Holds. 
• ‘Triggering Event’ - any event that by its nature provides OLS with credible information indicating either:
  • that Graduate School is on notice of a credible threat that it will become a defendant in litigation;
  • that Graduate School reasonably anticipates being a target of a governmental regulatory inquiry; 
  • that Graduate School reasonably anticipates becoming subject to preservation obligations imposed by law; or
  • that Graduate School seriously considers initiating litigation against another party or is taking steps to commence litigation.

Policy

The Graduate School’s policy is to identify, collect, produce, and disclose available and relevant documents, records, data, and other ESI in compliance with applicable laws, court procedures, and agreements made during the litigation process. Graduate School policy #? outlines its record and data retention policy, which is suspended in a litigation hold.

Procedure

• Any employee who becomes aware of a potential triggering event must immediately notify the OLS of the event. Upon receipt of notice of a potential triggering event, in a reasonable period of time, OLS shall make a determination as to whether or not to initiate a Litigation Hold. This may include activation of the Litigation Response Team??.
• Factors that OLS may consider include, but are not limited to, the following:
  • The nature and specificity of the claim, complaint, or threat;
  • The party and position of the party making the potential claim, complaint, or threat;
  • The business or other relationship between the Graduate School and the party;
  • Whether the threat of litigation or government regulatory inquiry is direct, implied, or inferred;
  • Whether the party making the potential legal claim is known to be aggressive or litigious;
  • The strength, scope, or value of the potential legal claim being asserted;
  • The likelihood that records or data relating to the potential legal claim or governmental regulatory inquiry will be lost or destroyed;
  • Whether the Graduate School has previously of similar legal claims or governmental regulatory inquiries;
  • Whether the records and data that would be relevant to the potential legal claim or governmental regulatory inquiry are being retained for some separate reason; and 
  • Press or industry coverage of the issues raised by the potential legal claim or governmental regulatory inquiry.
• If OLS determines that issuance of a Litigation Hold is warranted, the Litigation Response Team shall:
  • Take reasonable steps to identify all sources of records potentially covered by the scope of the Litigation Hold.
    o Notify the affected Graduate School students and employees in writing through the Litigation Hold Notification email system that a Litigation Hold has been initiated. The notice will inform affected Graduate School students and employees of their obligation to identify and preserve all records that may be relevant to the Litigation Hold.
  • Make a reasonable effort to interview Graduate School students and employees identified as having records potentially identified by the scope of the Litigation Hold to ascertain how they generate, distribute, receive, and maintain records relating to the subject of the Litigation Hold.
  • Make a reasonable effort to identify the location of records subject to the Litigation Hold, including paper files, local hard drives, servers, shared drives, home computers, mobile devices, and removable storage media.
  • Take reasonable steps to preserve data such as but not limited to imaging relevant sources.
  • Specifically direct all affected Graduate School students and employees that records potentially covered by the scope of the Litigation Hold may not be altered, destroyed, or otherwise disposed of without the express consent and approval of OLS.
  • If medical records are involved, notify Health Information Management Services (“HIMS”) of the Litigation Hold.
• Upon notice of a Litigation Hold, Graduate School students and employees shall do the following:
  • Acknowledge receipt, understanding, and compliance with the Litigation Hold by clicking the Litigation Hold Notification email system acknowledgement.
  • Immediately suspend deletion, alteration, overwriting or any other destruction, changing or modifying of any records relevant to the Litigation Hold that are under their control; this includes not deleting emails and text messages.
  • Secure paper records relevant to the Litigation Hold and notify the Litigation Response Team once completed. Preserve ESI so that it can be retrieved at a later time. The information must be preserved by IT Security in its original electronic form. It is not sufficient to make a hard copy.
  • Coordinate with the Litigation Response Team to ensure the ESI subject to the Litigation Hold are properly secured.
  • Preserve any new information or records generated after receipt of the Litigation Hold notice that is relevant to the Litigation Hold. Direct all inquiries regarding any records subject to the Litigation Hold to OLS or the Litigation Response Team. Affected personnel shall not forward the Litigation Hold notice, and shall not discuss the Litigation Hold with anyone other than legal counsel in OLS.
  • Affected Graduate School students or employees may be periodically queried to ensure compliance. Affected Graduate School students or employees shall cooperate and respond to any inquiries regarding the Litigation Hold by OLS or the Litigation Response Team.
  • Once the Litigation Hold has been released, the affected Graduate School students or employees will be notified, and normal retention and destruction processes may be resumed.
  • Violations of this policy are subject to disciplinary action up to and including dismissal.
• Legal Hold Notification
  • The Litigation Hold Notification will come by e-mail and will include custodian acknowledgement instructions.
  • Custodians will receive periodic e-mail reminders as long as a Litigation Hold is active.

References

1. Institutional Policy 50.011 Email Policy, https://home.stjude.org/policies/Policies/50-011.pdf
   
2. Institutional Policy 50.065 Record/Data Retention, https://home.stjude.org/policies/Policies/50-065.pdf
3. Institutional Policy 50.072 Information Security Data Classification, https://home.stjude.org/policies/Policies/50-072.pdf
4. Rules 26, 16, 33, 34, 37, and 45, and Form 35 of the Federal and Tennessee Rules of Civil Procedure.

80.90.006: Government Investigations

Derived from St. Jude policy 70.01.005 (Owner, Tamara M. Walk)

Purpose and Scope

• The Graduate School is committed to cooperating with government officials during government inquiries and investigations.
• This policy applies to Graduate School staff members.

Definitions

• Government Agency - Agencies can be established by legislation or by executive powers. A government agency may be established by either the Federal government or a state government. 
  • Examples of federal government agencies include, but are not limited to:
    1. Federal Food and Drug Administration (“FDA”)
    2. Office of Laboratory Animal Welfare (“OLAW”)
    3. Internal Revenue Service (“IRS”)
    4. Department of Health and Human Services (“HHS”)
    5. Office of the Inspector General (“OIG”)
    6. Office for Civil Rights (“OCR”)
    7. Centers for Medicare and Medicaid Services (“CMS”)
    8. Department of Justice (“DOJ”)
    9. United States Attorneys’ Office
    10. Federal Bureau of Investigation (“FBI”)
    11. Drug Enforcement Administration (“DEA”) 
    12. Office for Human Subjects Protection (“OHRP)
  • Examples of state government agencies include, but are not limited to:
    1. Tennessee Higher Education Commission
    2. Tennessee Department of Health
    3. Office of Attorney General and Reporter
    4. Bureau of TennCare
    5. Tennessee Bureau of Investigation (TBI)
• Government Contractor – A private company that produces goods or services under contract for the government. Examples of government contractors include, but are not limited to, Recovery Audit Contractors (RAC), Zone Program Integrity Contractors (ZPIC), and Medicare Administrative Contractors (MAC).
• Search Warrant – A document issued by a court allowing a government agent to search a specific location identified in the warrant for specified things or persons listed in the warrant and take specific materials identified by the search warrant (see #4 above).
• Staff member - All graduate faculty, postdoctoral scientists, employees, volunteers, agents, vendors, and contractors of the Graduate School.
• Student – an enrolled person in a graduate, degree-granting program. 
• Subpoena – A document from a court or grand jury requiring that a person testify, that specified documents be produced at a particular time and place, or both.

Policy

The Graduate School will cooperate appropriately with government inquires and investigations, and also is committed to protecting the legal rights of Graduate School staff members.

Procedure

• If a Graduate School staff member becomes aware of an upcoming or ongoing government investigation or audit, but government agents are not on-site, he or she will notify either the Office of Legal Services or the Compliance Office immediately. The Office of Legal Services and the Compliance Office will designate a point of contact for coordinating a response to the government investigation or audit. 
• If a government agent(s) arrives unannounced, the Graduate School will notify Security and the Office of Legal Services immediately. Security will initiate an appropriate Send Word Now alert to designated staff members and escort government agents to the Patient Care Center lobby to await the arrival of the designated contact. 
• Subpoenas: 
  • Notify the Office of Legal Services immediately if a subpoena, inquiry, or other document other than a search warrant is received at the Graduate School from any government agency or contractor regarding the Graduate School’s business, students, or employees,.
  • No Graduate School document shall be released unless approved by the point of contact designated by the Office of Legal Services and the Compliance Office to coordinate the response.
• Search Warrants: If a government agent arrives at the Graduate School with a search warrant, contact the Office of Legal Services and ask the government agent to wait for legal counsel to arrive. If the government official declines to wait:
  • Verify each agent’s identification and agency affiliation; 
  • Note agent(s) badge number;
  • Ask the reason for the agent’s visit;
  • Review and photocopy the search warrant;
  • Record each agent’s contact information, including any phone numbers, physical addresses, and email addresses;
  • If designated attorney-client privileged files and documents are on the premises, the agents need to be notified. These files may be marked privileged and confidential, privileged and/or attorney client privileged or may be in a file cabinet or workspace designated as such;
  • Take written notes of events as they unfold;
  • Remain courteous and do not interfere with the search;
  • Do not consent to any request to search an area not covered by the warrant. Agents can search any area within the warrant, including locked file cabinets and personal desks;
  • Do not consent to a search without a search warrant. Politely object if agents go outside of the locations identified in the search warrant; and
  • Photocopy all documents that are removed and ask for copies of seized electronic media. If you are not allowed to photocopy the documents being removed, make a list of the documents that are taken.
  • Ask to be present when agents make an inventory of property to be seized. 
  • Request a receipt or detailed inventory for any property seized. 
• Government official visits to a Graduate School staff member’s home: staff members may speak with government officials but are not required to do so. St. Jude legal counsel will not advise staff members on whether or not to speak to an official. If a Graduate School staff member chooses to speak with a government official, all of the official’s questions should be answered truthfully without making assumptions and/or guessing at answers. If the official asks a question to which the answer is unknown, the person being interviewed should state that he or she does not know the answer. If a staff member receives a phone call, email, text message, or other communication from a government official, he or she is free to direct the official to the Office of Legal Services.
  • Graduate School staff members have the right to refuse to be interviewed, the right to have legal counsel present, the right to terminate an interview at any time, and to conduct the interview at the staff member’s convenience.
  • All questions regarding government inquiries or investigations should be addressed to the Office of Legal Services.
  • Upon notice of a government investigation or inquiry at the Graduate School , document destruction is on hold. Do not destroy, alter, or remove any documents. 
  • All third-party inquiries (including media inquiries) about government investigations should be referred to the Communications Department or the Office of Legal Services.'Government investigations and inquiries are confidential. The investigation/inquiry and related issues should only be discussed with St. Jude legal counsel or members of the Compliance Department, unless otherwise authorized and should never be discussed with individuals outside of the institution, other than the investigators themselves.

References

• Tennessee Code Annotated §68-11-401 et seq
• Rule 45 of the Federal Rules of Civil Procedure

80.91.001: Corporate Compliance

Derived from St. Jude policy 70.01.001 (Owner, Tamara M. Walk)

Purpose and Scope

• Through its Compliance Program, Code of Conduct, and related policies and procedures the Graduate School has implemented standards and procedures to promote the highest ethical culture and to detect, prevent, and resolve inappropriate conduct.
  This policy applies to all faculty, postdoctoral scientists, full- and part-time Graduate School employees, students, volunteers, agents, vendors, and contractors, and any other persons or entities acting or providing services on behalf of the Graduate School.

Policy

• The policy of the Graduate School is to conduct business in compliance with applicable laws, regulations, accrediting organization guidelines, and internal policies and procedures. 

Procedure

• The Graduate School Compliance Program promotes prevention, detection, and resolution of actions that do not conform to regulatory requirements, health care program requirements, or the Graduate School’s business and ethical policies. The Compliance Program includes the seven fundamental elements of an effective compliance program included in the U.S. Federal Sentencing Guidelines and the Office of Inspector General’s compliance program guidance documents.
• The Compliance Program is directed by a Compliance Steering Committee (“CSC”)?? consisting Graduate School and St. Jude employees and the Chief Compliance Officer (“CCO”). The CSC and CCO coordinate to ensure the Program encompasses the requirements of relevant Federal, state, and local laws and regulations, and best practices established by professional organizations and peer institutions. 
• Individuals listed in the scope of this policy are expected to comply with applicable laws, regulations, accrediting organization guidelines, and internal policies and procedures.
• The Compliance Office is responsible for investigating any matter within the scope of its duties and responsibilities or as otherwise delegated by the Graduate School Dean, St. Jude Chief Executive Officer, Board of Trustees, or Board of Governors, with unrestricted access to appropriate books, records, systems, facilities, and personnel of St. Jude.

References

• United States Sentencing Guidelines
• Office of Inspector General Compliance Guidance

80.91.002: Non-Retaliation

Derived from St. Jude policy 70.01.006 (Owner, Tamara M. Walk)

Purpose and Scope

• The Graduate School is committed to complying with applicable statutes and regulations and protecting staff members from retaliation for good faith reporting of suspected or actual wrongdoing. This policy provides notice to the Graduate School's staff members and students of their whistleblower rights and remedies.
• This policy applies to all Graduate School staff members and students.

Definitions

• Good Faith – Honest intent to act without taking an unfair advantage over another; disclosing perceived wrongdoing without deception. 
• Harassment - Verbal or physical conduct that denigrates or shows hostility or aversion toward a person when such conduct has the purpose or effect of creating an intimidating, hostile, or offensive working environment.
• Staff Member - All faculty, postdoctoral scientists, full- and part-time employees, volunteers, agents, vendors, and contractors and any other persons or entities acting or providing services on behalf of the Graduate School.
• Wrongdoing – Examples of wrongdoing include, but are not limited to non-compliance, illegal or fraudulent activity, financial misstatements or accounting/auditing irregularities, undisclosed conflicts of interests or dishonest or unethical conduct, research misconduct, violation of the Graduate School’s policies or Code of Conduct or other laws, rules, regulations and/or policies. For purpose of this policy, wrongdoing related to a federal contract or grant (as set forth at 41 U.S.C. § 4712) may include the following: gross mismanagement of a federal contract or grant; a gross waste or fraudulent use of state, federal, or foundation funds; an abuse of authority relating to a federal contract or grant; a substantial and specific danger to public health or safety; and/or a violation of law, rule, regulation related to a federal contract (including bidding for or negotiating of a contract) or grant (including applications for and progress reports about) awarded by local, state, federal government, or private foundation.

Policy

• The Graduate School requires all staff members and students to report known or suspected wrongdoing. The Graduate School does not permit or condone any form of retaliation for good faith reporting of a wrongdoing or for participating in an internal investigation. No adverse action(s) will be taken against a Graduate School staff member or student for making reports in good faith. A Graduate School staff member or student may not be terminated, demoted, or otherwise discriminated against for disclosing information that the staff member or student reasonably believes is evidence of wrongdoing related to a local, state, federal, or foundation contract or grant to any of the following persons or entities: the staff member’s supervisor or student’s advisor, a Graduate School manager, Chief Compliance Officer (or his/her designee), the Office of Legal Services, or the Research Integrity Officer; a member of Congress or representative of a committee of Congress; an Inspector General; the Government Accountability Office; a federal employee responsible for contract or grant oversight or management at the agency related to the federal contract or grant; an authorized official of the Department of Justice or other law enforcement agency; or a court or grand jury. 
• All managers have a responsibility to create a work environment in which ethical and legal concerns may be raised and openly discussed without fear of retaliation or retribution and to protect the identity of the reporter to the extent possible. Actions that might constitute retaliation, retribution or harassment include, but are not limited to, negative grade assignment, intimidation, threats, demotion, suspension, denial of promotion or raises, or loss of employment or professional opportunities. 
• This policy may not be used as a defense against a disciplinary action if that action has been taken for legitimate reasons and in a manner that is consistent with the Graduate School’s policies and procedures. Additionally, Graduate School staff members and students who knowingly and intentionally make false allegations of non-compliance will be subject to disciplinary measures, up to and including termination, in accordance with these policies and procedures.

Procedure

• Managers should maintain an open work environment that encourages Graduate School staff members and students to report irregularities and concerns. All managers are expected to educate Graduate School staff members and students on this policy, provide periodic reminders of this policy, and maintain appropriate documentation of the training.
• Anyone who receives a report of possible wrongdoing must immediately notify the SVP/COO, Chief Compliance Officer (CCO), Chief Legal Officer (CLO), or Research Integrity Officer (RIO) upon any report of retaliation.
• Graduate School staff members and students may report real or suspected retaliation related to compliance to the SVP/COO, CCO, CLO, RIO, any member of the Compliance Steering Committee (CSC), or EthicsPoint by calling 1-800-433-1847.
• The person taking the report must document the conversation in writing and should include specific information to document and support the retaliation complaint. A copy of the written report will be provided to the CCO.
• Confidentiality will be maintained to the extent possible, informing only those individuals who have a need to know. Investigations of real or suspected retaliation are confidential and should not be shared with anyone outside the investigation team.
• The CCO, CLO or designee will investigate and respond to the complainant promptly. This initial review will only assess the nature and seriousness of the retaliatory action.
• The final determination as to whether or not retaliation has occurred in violation of this policy will be made by the CCO in consultation with the CSC and the Dean. 
• The CCO will provide a report to the Dean who, in turn, will make a report to the Board of Trustees regarding any allegations of retaliation and the resolution of any allegations.
• Graduate School staff members or students cannot exempt themselves from the consequences of wrongdoing by reporting their own wrongdoing, although self-reporting may be taken into account in determining the appropriate course of action.
• If a Graduate School staff member or student believes that he/she has been discharged, demoted, or otherwise discriminated against for disclosing wrongdoing related to a federal contract or grant to a person or entity listed above, the Graduate School staff member or student may submit a complaint to the Inspector General of the federal agency responsible for the contract or grant within three (3) years of the date on which the alleged retaliatory conduct took place. 
  • The federal agency will receive a report from the Inspector General following its investigation of the alleged retaliatory conduct. 
  • No later than thirty (30) days after receiving the Inspector General's investigation report, the head of the federal agency may deny the Graduate School staff member or student relief or may take one or more of the following actions: 
    1. order Graduate School to take corrective action; 
    2. order Graduate School to reinstate the Graduate School staff member or student with compensatory damages (including back pay and health benefits), employment benefits, and other terms and conditions that would apply to the Graduate School staff member or student if the retaliation had not occurred; and/or 
    3. order Graduate School to pay the Graduate School staff member or student an amount up to or equal to his/her costs and expenses to bring the retaliation complaint.
  • If the head of the federal agency denies the Graduate School staff member or student relief or fails to issue an order to the Graduate School within 210 days after the Graduate School staff member or student filed his/her retaliation complaint (provided there was not an extension or bad faith delay), the Graduate School staff member or student may file an action against Graduate School. Generally, the Graduate School staff member or student must file with the court within two (2) years of (i) the federal agency order denying the Graduate School staff member or student relief or (ii) the failure to issue an order within 210 days after the Graduate School staff member or student filed his/her retaliation complaint. 
  • Additional information on whistleblower protection related to federal contracts and grants may be found at the relevant federal agency's Inspector General website or at 41 U.S.C. § 4712.

References

• Administrative Remedies 31 U.S.C. §§ 3801, et seq
• Deficit Reduction Act of 2005 (S. 1932) §§ 6031 – 6034 (DRA) 
• Federal False Claims Act, 31 U.S.C. §§ 3729-3733
• T.C.A. §§ 4-18
• Pilot Program for Enhancement of Employee Whistleblower Protection 41 U.S.C. § 4712

80.91.003: Reporting Compliance Concerns

Derived from St. Jude policy 70.01.007 (Owner, Tamara M. Walk)

Purpose and Scope

• To outline a variety of ways for Graduate School staff members and students to report known or suspected violation of federal, state, or local laws and regulations, accreditation standards, Graduate School policies and procedures or Code of Conduct. 
• This policy applies to all Graduate School staff members and students.

Definitions

• Staff member -  All faculty, postdoctoral scientists, employees, volunteers, agents, vendors, contractors and any other persons or entities acting on behalf of or providing services to the Graduate School.
• Student - a person enrolled in a graduate degree program of the St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences.
• EthicsPoint - A confidential telephone and online reporting system provided by a third-party vendor. Reports made using EthicsPoint are anonymous when the reporter chooses not to self-identify.

Policy

• The Graduate School encourages proper conduct and facilitates open communication of any compliance concern and/or question. 
• Staff members and students are expected to report known or suspected violations of federal, state, or local laws and regulations, accreditation standards, policies and procedures or Code of Conduct. Failure to report an actual or potential violation may result in disciplinary action.
• There are multiple ways to report compliance concerns, but staff members and students are encouraged to initially share their concerns with the SVP/COO and/or supervisor. However, if this does not result in appropriate action, or if a staff member or student is uncomfortable discussing these issues with the SVP/COO and/or his or her supervisor, concerns should be reported directly to the Compliance Office (ext. 5563), through EthicsPoint or the Employee Hotline (1-800-433-1847). 
• Retaliation will not be tolerated against a staff member or student who reports issues and concerns in good faith. 
• All reports will be responded to in a timely manner. Confidentiality will be maintained to the greatest extent possible, involving only those parties with a need-to-know.

Procedure

• When an issue or concern is identified, a staff member or student may report the issue or concern to a supervisor and/or:
  • The SVP/COO;
  • the Compliance Office at ext. 5563;
  • EthicsPoint by phone at 1-800-433-1847 or the internet at www.ethicspoint.com. EthicsPoint may also be accessed from the Compliance Office intranet. The staff member or student should call back or access the EthicsPoint website after making a report to answer questions and/or check the status of the report; and
• If the staff member or student offers identification, his or her confidentiality will be protected to the limit of the law. If a staff member or student wishes to remain anonymous, compliance concerns should be reported using EthicsPoint.
• The SVP/COO and supervisors are encouraged to consult with the Compliance Office or Human Resources to ensure response(s) to reported concerns are appropriate and aligned with policy. If the complaint raises a substantive compliance issue, it must be reported to the Compliance Office.'
• If a staff member or student feels he or she has been retaliated against for reporting a concern, the staff member or student should immediately contact the Compliance Office or Human Resources.

References

• Graduate School Code of Conduct

80.91.004: Institutional Conflicts of Interest in Research

Derived from St. Jude policy 70.03.002 (Owner, Laura Pruett)

Purpose and Scope

• The Graduate School has relationships with outside entities such as for-profit or corporate entities that may lead to financial benefit for the institution in many forms, including but not limited to donations, grants, royalty payments or sponsored research agreements. However, these financial and other incentives could compromise the integrity of the Graduate School's primary mission, leading to institutional conflicts of interest (Institutional Conflicts) that need to be reduced, managed, or eliminated. 
• This policy outlines the process for Institutional Conflict disclosure, review, and management. Its purpose is to preserve the credibility of the Graduate School by preventing Institutional Conflicts from interfering with or influencing decisions that affect the Graduate School’s primary mission, including the safety and/or integrity of research.
• This policy applies to the Graduate School and does not apply to individual or board member conflicts of interests. 
• This policy does not apply to financial interests in or received from government agencies, institutions of higher education, non-profits, or professional societies.

Definitions

• Conflict of Interest Committee - An institutional committee appointed by the St. Jude President and Chief Executive Officer (Director/CEO) to provide oversight and direction to the Compliance Office regarding this policy and related procedures. 
• Disclosure - Submission or notification of the Graduate School's significant financial interests.
• Institutional Conflict of Interest - A situation in which the Graduate School 's financial interests or its senior officials' financial interests appear to a reasonable observer to create a risk of undue influence over decisions involving research or appear to directly and significantly affect research design, conduct, or reporting.
• Investigator - Any person, regardless of title or position, who designs, conducts or reports St. Jude-directed research (e.g. principal investigator, project director, clinical research associates, collaborators/consultants).
• Financial Interest - Anything of monetary value held by the Graduate School, including but not limited to intellectual property rights (e.g., patents and patent applications, copyrights, trademarks, trade secrets) and royalties from those rights; an interest with a value that cannot be readily determined (e.g., a future royalty interest); and any other similar monetary interest in or received from an outside entity (e.g. corporate sponsored research agreements, scholarships, fellowships, and endowments).
• Management Plan - Formal plan for managing, reducing, or eliminating a conflict as agreed by the Compliance Office or the COI Committee. 
• Significant Financial Interest - A Financial Interest held by the Graduate School or its senior officials that meets the threshold for disclosure, as detailed in Procedure Section 1 of this policy.
• Senior Officials - The Dean and SVP/COO who hold specific executive powers conferred by the authority of the Graduate School Board of Trustees and who have responsibilities of managing the Graduate School daily operations.

Policy

• Any direct vendor support for research activities shall comply with policy, “Relationships with Vendors." (80.91.005)
• The Office of Technology Licensing (OTL) notifies the Compliance Office of institutional patents and licensing agreements related to research.
• The Grants and Sponsored Programs Office (GSPO) notifies the Compliance Office of institutional Significant Financial Interests related to research.

Procedure

• Note: The procedures and conditions of this policy are more fully described in the Corporate Compliance Conflict of Interest and Commitment standard operating procedure found on the Compliance Office intranet site.
• Disclosure
  • OTL notifies the Compliance Office within 30 days if the Graduate School acquires an equity interest or compensation arrangement related to licensing, technology transfer, or patents that directly and significantly affect research (e.g., receipt of royalty payments from the sales of investigational products that are the subject of research).
  • GSPO notifies the Compliance Office within 30 days if the Graduate School receives or acquires significant financial interests that directly and significantly affect research (e.g., substantial grants from a sponsor of research).
  • Graduate School officials are held to the same disclosure requirements as St. Jude Children’s Research Hospital officials, and shall make disclosures to the Compliance Office.
• Review, Conflict Determination, and Management 
  • Review
    1. Research investigators will assist Compliance and OTL in determining if intellectual property covered in patent applications or license agreements is related to the Graduate School research.
  • Conflict Determination
    1. Compliance will determine if an Institutional Conflict in research exists and develop a Management Plan(s) as needed.
    2.  If a significant financial interest is of a particularly unique or significant nature, the Compliance Office will refer the matter to the COI Committee for conflict determination.
  • Management Plan Development, Dissemination, Reconsideration, and Monitoring
    1. Institutional Conflicts in research require Management Plans that must be approved by the COI Committee. As appropriate, the COI Committee may develop a Management Plan(s), or amend, approve, or veto any proposed Management Plan, and communicate its decision in writing to Compliance.
    2. A Management Plan will be structured to address the complexities of the Institutional Conflict, but some possible strategies include:
       
       i. Recusal from relevant decision making (if an individual conflict);
       ii. Reduction, modification, or elimination of institutional or individual significant financial interest;
       iii. If conflict relates to a major corporate donation or grant, a separation of those involved in soliciting/managing the donation or grant from those involved in research;
       iv. Disclosure of the significant financial interest in publications, presentations, and future grant applications; and
       v. Establishment of a research oversight board that includes non-St. Jude Graduate School individuals; 
       
       
    3. Compliance with Management Plans will be monitored by the Compliance Office.

•  Record Retention
  • Compliance will maintain all disclosure records for three years from the date that the Institutional Conflict ceases to exist.

References

• Compliance Office Intranet Site
• Accreditation Council for Continuing Medical Education (ACCME) Standards for Commercial Support http://www.accme.org/requirements/accreditation-requirements-cme-providers/standards-for-commercial-support
• American Medical Association Ethical Opinion E‐8.061 http://www.ama-assn.org/ama/pub/physician¬resources/medical-ethics/code-medical-ethics/opinion8061.page
• Patient Protection and Affordable Care Act, Pub. L. No. 111-148, § 6002 (the “Sunshine Law”) 
• Pharmaceutical Research and Manufacturers of America (PhRMA) Code https://journalofethics.ama-assn.org/sites/journalofethics.ama-assn.org/files/2018-07/pfor2-0307.pdf
• Advance Medical Technology Association (AdvaMed) Code https://www.advamed.org/sites/default/files/resource/advamed-code-of-ethics_2020_july20.pdf

80.91.005: Relationship with Vendors

Derived from St. Jude policy 70.03.003 (Owner, Scott Long)

Purpose and Scope

• Graduate School faculty and staff may have interactions with Vendors. These interactions will be conducted in accordance with applicable laws, and in a manner that minimizes conflicts of interest and the real or perceived potential to improperly influence research or clinical decision-making, compromise student rights, or create patient safety or quality care concerns.
• This policy establishes standards for appropriate interactions with Vendors. This policy supplements the Conflict of Interest and Commitment in Research policy (St. Jude Policy 70.03.001). In the event of a conflict between this policy and the Conflict of Interest and Commitment in Research policy, the terms of this policy govern and control. Nothing in this policy is intended to limit the responsibility of those who have a direct role in institutional decisions to avoid conflicts of interest and to interact with non-Vendor entities on an impartial basis. Graduate School faculty and staff shall not solicit gifts, meals, travel, or entertainment from Vendor entities wishing to do business with the Graduate School. If offered by entities that do not meet this policy’s definition of “Vendor,” acceptance of gifts, meals, travel, and reasonable business entertainment (e.g., attendance at sporting and cultural events) is acceptable as long as the items or events are reasonable in terms of expense and will not influence any part of a decision making process.

This policy applies to all Graduate School faculty and staff and governs their interactions with Vendors.

Definitions

• Vendor – Any pharmaceutical, medical device, medical equipment, medical supply, medical service, bioscience, software or higher education related company, whether or not it is currently doing business with the Graduate School.

Policy

• Faculty and staff who engage in relationships with Vendors must minimize the possibility of the relationships creating conflict of interest concerns or improperly influencing research and clinical decision-making, or creating patient safety or quality care concerns.
• Faculty and staff may submit a Vendor Request for Exception Form to receive compensation or other items of value that the policy indicates should not be accepted. The Vendor Request for Exception Form is described in greater detail in the Procedures section below. 
• Gifts, such as textbooks, electronic devices, entertainment, may not be accepted from Vendors, with the following exceptions:
  • Educational materials that directly benefit students or are intended to be used by or with students, such as models and journal article reprints, may be accepted.
  • Gifts of less than $10 value (pens, notebooks) provided by Vendors may be accepted.
  • Unsolicited food, such as desserts and snacks delivered to the Graduate School campus and not provided in conjunction with an on-campus event (e.g., food delivered through the mail to show appreciation) may be accepted if the food is made available to all faculty and staff in the Graduate School.
  • Faculty and staff shall not enter raffles or other drawings in which Vendors give away items of value, including, but not limited to, gift certificates, software, and mobile or electronic devices.
  • Discounts and rebates are not gifts, but are subject to requirements in the Fraud and Abuse Compliance in Contracting policy (St. Jude policy 70.02.003). 
• Meals may not be accepted from Vendors, with the following exceptions:
  • Faculty and staff must purchase their own meals (or partake in a meal funded by the hosting Graduate School, if applicable) when attending a Vendor education session held on the Graduate School campus. 
  • Meals paid for directly by Vendors off campus are permitted when there is a legitimate purpose justifying acceptance of the meal. Examples of meals provided for legitimate purposes are meals offered in the course of providing approved consulting or advisory services, meals at meetings directly related to ongoing research projects, and meals provided in conjunction with educational conferences or programs (e.g., covered by a registration fee, offered to all event attendees).
  • Faculty and staff should decline one-on-one or small group meals with Vendor representatives engaged in sales or marketing activities but may accept an invitation to discuss on-going business.
• Compensation
  • Faculty and staff may not accept personal compensation, such as honoraria and consulting or advisory board service fees from Vendors.
  • Faculty and staff may not accept sponsored or reimbursed travel expenses, such as airfare, lodging, and transportation from Vendors unless faculty or staff are engaged to present at administrative or educational venues. 
  • Approved Consulting Arrangements include:
    1. Consulting arrangements with Vendors, which include compensation, are permitted if the arrangements include professional seminars or panel discussions in an administrative or educational engagement. Before signing a consulting agreement, faculty and staff must consider whether the request for services originated from the appropriate division within a Vendor organization. For example, Vendor marketing representatives are generally not the appropriate unit to engage services that are solely scientific but may be appropriate for an educational engagement.
    2. All consulting arrangements must comply with the St. Jude Faculty Handbook (if applicable) and St. Jude policies 70.03.001 and 70.02.003. In addition, all consulting arrangements for faculty and staff must:

i. Be in writing;
ii. Describe in reasonable detail the services provided;
iii. Provide no more than fair-market value compensation;
iv. Require necessary and legitimate services that are actually rendered;
v. Not involve the use of Graduate School facilities, services, or resources;
vi. Not prohibit publication of research results generated as a result of employment at the Graduate School;
vii. Not be motivated (or appear to be motivated) by an improper purpose, such as to incentivize the faculty or staff to change his or her purchasing or prescribing habits;
viii. Not be with a for-profit company sponsoring the faculty’s research-related work, unless the Conflict of Interest Committee has reviewed and approved the arrangement; and
ix. Be disclosed to and reviewed by the Office of Technology Licensing before research-related consulting services are rendered. 

• Donations. Vendor donations (including donations of funds, services, equipment, devices, and supplies) should be directed to ALSAC.
• Site Access by Sales and Marketing Representatives
  • Vendor sales and marketing representatives are not permitted in any direct patient care areas except to provide in-service training and then by appointment only. This is not intended to prevent a Vendor sales or marketing representative with an appointment to see an employee from incidentally walking through a direct patient care area.
  • Vendor sales and marketing representatives are permitted in non-patient care areas by appointment only. Appointments will normally be made for purposes such as: 
    1. In-service training of faculty, employees, and students;
    2. Evaluation of new purchases; and
    3. Presentation of seminars that share new technical, scientific, or educational information, applications, or technologies.
  • Vendor representative appointment and credentialing requirements are contained in the Vendor Credentialing policy 10.06.023.
  • Vendor representatives who will be given access to student information must sign a Graduate School Confidentiality Form.
• Support for Educational and Other Professional Activities
  • Support for accredited continuing medical education (CME) may be accepted from Vendors as long as:
    1. The support subsidizes attendees’ tuition fees only;
    2. The program meets the accreditation or certification standards and requirements of the Accreditation Council for Continuing Medical Education (ACCME), the American Osteopathic Association, the American Medical Association, the American Academy of Family Physicians, or the American Dental Association (ADA) Continuing Education Recognition Program;
    3. Vendors have not selected the presenter(s); and
    4. Vendors will not directly pay the presenters(s).
  • Direct support (including grants) from Vendors for unaccredited or noncertified CME must not be accepted. Vendors may not influence the curriculum of a Graduate School-sponsored educational event in any way, including, without limitation, the planning, content, and/or execution of the event. Any presenter at a Graduate School-sponsored educational event must disclose any financial interest that poses a conflict of interest to learners prior to the educational activity and in post-meeting publications. 
• Vendor-Sponsored Research Projects
  • All Vendor support (funds, devices, drugs) received via sponsored research projects must be reviewed and approved by the SVP/COO, Clinical Trials Administration or the Grants and Sponsored Programs Office, and any other appropriate department or office, and all sponsored research agreements are subject to all applicable Graduate School policies.
  • Disclosures of potential or actual conflicts of interest with a sponsored research project must be made to the Compliance Office per St. Jude policy 70.03.001 and the Institutional Review Board, if applicable.
• Vendor-Sponsored Conference Attendance and Speaking Engagements 
  • Faculty and staff may attend Vendor-sponsored programs (e.g., educational meetings, lectures, and conferences). Such events must contain objective scientific and educational information that promotes graduate education or evidence-based medicine and scientific research.
    1. Programs must be structured so as not to improperly influence purchasing or prescribing decisions.
    2. Faculty and staff’s main objective in attending the Vendor-sponsored programs must be to promulgate their knowledge on the subject(s) presented.
  • Faculty and staff may participate as bona fide lecturers at Vendor-sponsored programs if the programs: 
    1. Comply with the ACCME Standards for Commercial Support or the standards of the Accreditation Council for Pharmacy Education (ACPE) or the ADA, as appropriate, whether or not CE credit will be awarded; and 
    2. Disclose to attendees orally and/or in writing their financial relationship with the Vendor, if applicable.
  • Items, such as meals, transportation, lodging, or incidentals that are included with a registration fee may be accepted
  • Faculty and staff may not accept any remuneration from Vendors to pay expenses incurred by a spouse or other guest.
  • Participation in the following activities is not permitted: 
    1. Vendor-sponsored "speakers bureaus” (i.e., contractual relationships to give talks in which the topic(s) and/or content are provided by the Vendor). 
    2. Allowing professional publications and presentations to be “ghost written” (i.e., material that is officially credited to someone other than the writer(s) of the material).
    3. Dedicated marketing and training programs designed solely or predominantly for sales or marketing purposes. 

Procedure

• Faculty and staff may submit a Vendor Request for Exception Form to receive compensation or other items of value this policy indicates should not be accepted. The process employees must follow to have their request reviewed and approved is indicated on the Form. The Vendor Request for Exception Form may be used to submit a request to receive:
  • Gifts, meals, and compensation; and
  • Support for educational events and conferences, including travel expenses.
• Monitoring and Enforcement
  • The Dean, SVP/COO, Associate Deans, Department Chairs, and the Compliance Office are responsible for monitoring compliance with this policy and are expected to enforce this policy with the support of the Conflict of Interest Committee. Alleged violations of this policy must be communicated to the Dean or SVP/COO and respective Department Chair or to the Compliance Office. The Graduate School reserves the right to impose appropriate discipline when warranted. Appropriate corrective action will be determined by the Dean, SVP/COO, and Department Chair.

References

• St. Jude Conflict of Interest and Commitment in Research Policy 70.03.001
• Fraud and Abuse Compliance in Contracting Policy 70.02.003
• Pharmaceutical Services Department Policy 3.09
• Vendor Credentialing Policy 10.06.023

Forms and Documents

• Vendor Request for Exception Form, available on the Compliance Office intranet site.
• Vendor Request for Exception Form: Evaluation Period Greater Than 90 Days, available on the Compliance Office intranet site.
• Graduate School Confidentiality Form

80.91.006: Export Controls and Restricted Parties

Derived from St. Jude policy 70.04.001 (Owner, Laura Pruett)

Purpose and Scope

• To facilitate the Graduate School compliance with United States export control laws and regulations. 
• This policy applies to all Graduate School faculty, employees, visiting scientists, graduate students, postdoctoral fellows, consultants, and all other persons retained by the Graduate School who may engage in exporting activities. Activities subject to export controls include the transfer of controlled items or assets and select services to foreign countries or to foreign nationals wherever located.
• The Departments of Commerce, State, and Treasury are responsible for oversight and enforcement of export controls as follows:
  • The Department of Commerce, through the Bureau of Industry and Security (BIS), administers and enforces the Export Administration Regulations (EAR);
  • The Department of State, through the Directorate of Defense Trade Controls (DDTC), administers and enforces the International Traffic in Arms Regulations (ITAR); and
  • The Department of Treasury, through the Office of Foreign Assets Control (OFAC) administers and enforces country-specific economic and trade sanctions and restrictive controls against specific entities and individuals.

Definitions

• Controlled information - Information required for design, development, production, manufacture, assembly, operation, repair, testing, maintenance, or modification of controlled items. Release of information may occur through activities including, but not limited to, visual inspection, oral exchanges, and emails. Information may also take the form of blueprints, drawings, photographs, plans, instructions, and documentation.
• Controlled items - Items listed in the Commerce Control List within the Export Administration Regulations and the United States Munitions List within the International Traffic in Arms Regulations. “Items” can include material goods, software, information, services, and technology.
• Export Controls - U.S. federal laws and regulations that control the export and reexport of items (e.g., material goods, software, information, services and technology) and funds to foreign countries and persons outside the U.S., and in some cases to foreign nationals within the U.S.
• Foreign National - Anyone who is not a US citizen or a lawful permanent resident of the US, or who does not have refugee or asylum status in the US. Foreign corporations, business associations, partnerships, trusts, societies, and other foreign entities and governments are considered “foreign nationals.”
• Re-export - Shipment or transmission of items subject to export controls, received by one foreign country and transmitted to another foreign country.
• Refer to the Export Control Compliance Guide for definitions of other key terms: http://home.web.stjude.org/compliance/documents/export-control-guide.pdf.

Policy

• The Graduate School will comply with applicable U.S. export control laws and regulations when conducting activities at or on behalf of the Graduate School. 
• Consistent with the Graduate School’s policies promoting academic freedom, it is the Graduate School policy to conduct research openly and without prohibitions or restrictions on publication, dissemination of, or access to research results. 
• The Graduate School is responsible for being aware of and complying with applicable U.S. export control laws and regulations.

Procedure

• The Graduate School activities may intersect with export controls in multiple, and sometimes unobvious, ways. The Compliance Office should be notified of projects and other activities that contain indicators of export control concern. Examples include:
  • References to U.S. export control regulations beyond a statement to comply with the law;
  • Restrictions on publication or dissemination of research results that cause more than a temporary delay in the publication or dissemination of those results;
  • Pre-publication approval requirements by a sponsor;
  • Proprietary claims on research resulting from projects involving export controlled information or technology;
  • Restriction of access of results to U.S. persons only;'
  • Restriction of participation in research projects to U.S. persons only;
  • Travel to or from, shipping to or from, or working with U.S.-sanctioned countries, entities or individuals. The list of sanction programs changes frequently and is available at http://www.treasury.gov/resource-center/sanctions/Programs/Pages/Programs.aspx.
  • US or other military-funded research projects; and
  • Requests to participate in boycotts not sanctioned by the U.S (e.g. Israel).
• The Compliance Office will assist the Graduate School in assessing its export control obligations and facilitating acquisition of export licenses where appropriate. 
• Refer to the St. Jude Export Control Compliance Guide available at http://home.web.stjude.org/compliance/doc/export-control-guide.pdf for further elaboration on procedures.

References

• Export Administration Regulations, 15 C.F.R. Parts 730-744
• Foreign Assets Control Regulations, 31 C.F.R. Parts 500-597
• International Traffic in Arms Regulations, 22 C.F.R. Parts 120-130

Forms and Documents

• Export Control Compliance Guide (http://home.web.stjude.org/compliance/documents/export-control-guide.pdf)

80.91.007: Foreign Anti-Corruption

Derived from St. Jude policy 70.04.002 (Owner, Laura Pruett)

Purpose and Scope

• The Graduate School is committed to conducting business ethically and in compliance with all applicable laws and regulations. This includes the U.S. Foreign Corrupt Practices Act (FCPA), which prohibits U.S. companies and individuals from bribing foreign government officials and other domestic and international laws that prohibit improper payments to obtain a business advantage.
• In pursuit of its mission to provide graduate education in the biomedical sciences and pediatric health both within the U.S. and abroad, the Graduate School may pursue and establish relationships or arrangements with foreign hospitals, clinics, laboratories, health care providers, universities, researchers, foreign officials, and ministries that are state-owned or state-controlled. The Graduate School is committed to conducting its activities fairly, honorably, with integrity, and in compliance with all applicable laws and regulations.
• Graduate School administrators, faculty, students, and employees (collectively personnel) will adhere to the requirements of this policy.

Definitions

• Bribery - offering, promising, giving, demanding, or accepting anything of value to induce an action that is illegal, corrupt, unethical, or a breach of trust. Bribes can consist of anything of value, including, but not limited to:
  • Cash, cash equivalents (checks), or loans;
  • Payments for travel, dinners, or entertainment;
  • Favors, including offers of employment or internships;
  • Gifts of more than nominal value (perfume, jewelry, use of memberships); or
  • Donations to a charity affiliated with or sponsored by a government official. 
  • Commercial bribery involves corrupt dealing with agents or employees of prospective commercial partners to secure an advantage over business competitors, such as providing anything of value to an individual or entity to cause a potential business partner to conduct business with the Graduate School. 
• Corruption - misusing public office or power for private gain, and criminal activity undertaken by a person or organization entrusted with a position of authority, often to acquire illicit benefit. Corruption may include many activities including bribery.
• A government official - 
  • Officer or employee of a local, provincial, or national government (Members of Parliament, physicians, nurses, laboratory personnel, police officers, firefighters, members of the military, tax authorities, customs inspectors);
  • Directors, officers, representatives, agents, or employees of government-owned or controlled businesses (physicians, nurses, laboratory personnel, principal investigators, and researchers of any government-owned or controlled business, hospital, clinic, laboratory or company);
  • Officers or employees of a public international organization (United Nations, World Health Organization, International Red Cross, World Bank);
  • Individuals acting in official capacity or on behalf of a government or public international organization (official advisor to a government, official consultant or advisor serving as a government interface to establish and conduct an international clinical trial);
  • Officers or employees of a political party;
  • Candidates for political office; or
  • Close relatives (parent, sibling, spouse, or child) of any of the above.
  • Examples of improperly influencing a government official may include:
    1. The government official would not act if the Graduate School did not make the gift, and the Graduate School gives a gift to increase the chances that the government official will take action;
    2. The government official has a choice to act or not and makes a decision based on the gift.
  • Examples of an improper business advantage include when a government official:
    1. Overlooks a violation or tolerates non-compliance with applicable laws;
    2. Does not perform a task that should otherwise be performed (does not conduct a required inspection prior to issuing a permit);
    3. Reduces customs duties; or
    4. Grants a favorable financial treatment.
• Third-party representatives - could include visiting professors, Non-Government Organizations (NGOs), grantees, agents, consultants, joint-venture partners, and physicians. Third parties who act on the Graduate School’s behalf must operate at all times in accord with this policy and laws prohibiting payments of bribes directly by the Graduate School or through third parties. Accordingly, retaining NGOs, grantees, consultants, agents, and other third-party representatives to assist the Graduate School must be done with special care and due diligence. It is imperative that the Graduate School knows and keeps track of the third parties with whom it does business and through whom it offers its services.

Policy

• No Graduate School personnel will improperly authorize, pay, promise, or offer to give anything of value to an international business contact to influence an individual or entity to act favorably towards the Graduate School.
• Graduate School personnel engaged in international activities should determine whether a proposed activity or payment could involve a Foreign government official, or an entity owned or controlled by a foreign government, and should consult the Compliance Office when information is difficult to identify. 
• Bona fide hospitality (meals and entertainment), promotional expenses (discounts on products and services), and other business courtesies (personal favors and token gifts) that are reasonable, proportionate, and provided as a means of developing a relationship with integrity are not prohibited. 
• Reimbursing reasonable and proportionate travel, food, lodging, and other comparable expenses for government officials may be permissible if:
  • The payment is not contrary to US, local, or other applicable laws;
  • The payment is for bona fide expenses that relate directly to the demonstration or explanation of the Graduate School services, or to performance of a contract with the foreign government or agency; 
  • Expenses are for a legitimate academic, research, or business purpose; and 
  • Expenses are appropriate and consistent with St. Jude’s Travel Policy.
• Facilitation or other payments to Foreign Officials should be reported to St. Jude Financial Services promptly and properly recorded, with respect to purpose, amount, and other relevant factors.
• Requests for false invoices, reimbursement or payment of expenses that are unusual, excessive, or inadequately described must be rejected and reported to St. Jude Compliance Office promptly. Misleading, incomplete, or false entries in the St. Jude Graduate School’s financial system are prohibited. Unrecorded transactions are prohibited.
• The Graduate School must keep accurate financial records that reflect transactions and asset dispositions in reasonable detail, supported by a proper system of internal accounting controls.
• To ensure compliance with applicable laws, the Office of Legal Services must approve in advance use of funds or assets of the Graduate School or an affiliate to pay travel expenses.

Procedure

• Obligations of the Graduate School personnel:
  • Learn, understand, and comply with the requirements of this policy;
  • Apply the requirements of this policy to performance of all job-related responsibilities and activities;
  • Maintain and retain specific, required evidence of compliance, such as original receipts;
  • Report violations of this policy to the Graduate School management, the Office of Legal Services, Financial Services, or EthicsPoint hotline; and,
  • Cooperate fully in an audit or investigation related to possible policy violations.
• The Dean has an additional responsibility to:
  • Confirm that subordinates know and understand this policy;
  • Take affirmative steps to prevent policy violations;
  • Establish proactive methods to determine if violations have occurred; and
  • Protect an employee or student who reports a suspected policy violation from retaliation.
• Personnel who violate this policy, conceal or destroy evidence of anyone else's violation, or withhold information from or refuse to cooperate with an investigation of a possible policy violation will be subject to appropriate discipline, up to and including termination. 
• International Contracts & Due Diligence
  • Third-party representatives must be selected solely on the basis of merit and after being evaluated according to the Compliance Office’s due diligence procedure; 
  • Third-party representatives may not be retained to provide services that are prohibited by any Graduate School policy;
  • Contracts with third-party representatives must contain language requiring compliance with applicable laws, including the FCPA; 
  • Compensation, reimbursement, and other payments to third-party representatives must be reasonable in relation to the services provided and reflected properly in the Graduate School’s records, books of account, and financial statements;
  • Payments to third-party representatives may not be made in cash, to third persons, or to bank accounts that are not in the third-party representative’s name and resident country or where services are rendered; and 
  • Contracts with third-party representatives must be reviewed by the Office of Legal Services to ensure that they are in strict compliance with this policy.

References

• All referenced policies contain provisions that impact the giving of gifts, gratuities, and business courtesies and should be consulted for additional guidance.

80.92.010: Protection of Student Data

Purpose

• This policy describes the St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences’ (Graduate School) responsibility for the safeguarding of confidential graduate student personal information and educational academic records. 
• Graduate student personal records are confidential in nature and will be kept confidential by Graduate School Officials. Confidential personal information will not be released to persons other than the graduate student and staff of the Graduate School without the written authorization of the graduate student whose records are requested.
• Graduate student academic records are confidential in nature and will be kept confidential by Graduate School Officials. Confidential academic information will not be released to persons other than the graduate student and staff of the Graduate School without the written authorization of the graduate student whose records are requested.
• The Graduate School must use reasonable methods to ensure that (i) School Officials obtain access to only those education records (personal and academic) in which they have legitimate educational interests; (ii) custodians of records have established control procedures to ensure that limitations are observed; and, (iii) if the custodian does not use physical or technological access controls, the custodian will ensure that its administrative policy for controlling access to education records is effective.

Definitions

• “School officials” means employees of the Graduate School, including faculty and staff, and certain individuals such as vendors or contractors, performing work for the Graduate School under proper authorization;
• A vendor, contractor, consultant, volunteer, or other party to whom the Graduate School has outsourced services may be considered a School Official provided that the outside party:
  • performs a service for which the Graduate School would otherwise use its employees; and
  • is under the direct control of the Graduate School with respect to the use and maintenance of education records.
• “Education records” generally includes records that are directly related to a graduate student and may be originated but are maintained by the Graduate School or a party acting for the Graduate School.
• “Aggregated data” means a grouping of de-identified data that will be disclosed – internally and/or externally – only if a minimum of 10 students are noted in the aggregated data category.
• A school official has “legitimate educational interests” in personally identifiable information in the records of a student if the information in question is required or would be helpful to the official in the performance of his or her duties.

Scope

• This policy pertains to the safeguarding and use of personally identifiable information contained in education records.
  • This policy applies to all graduate students who are enrolled, had been enrolled, and/or completed a degree program of the Graduate School regardless of mode of instruction and physical location of the student.

Outside of Scope

• This policy does not apply to:
  • records kept in the sole possession of the maker and used only as a personal memory aid and not accessible to any other individual except a temporary substitute of the maker of the record;
  • grades on peer-graded papers/assignments before they are collected and recorded by a teacher;
  • records created and maintained by a law enforcement unit, including Security and local police, for law enforcement purposes;
  • employee records that relate exclusively to a Graduate School employee who is a graduate student; 
  • records made or maintained by a healthcare professional that are used only in connection with treatment of the student and disclosed only to individuals providing treatment;
  • records that contain only information about an individual after he or she is no longer a student at the Graduate School (such as outcome data for employment or address for contacting) unless the record relates to the student’s attendance at the Graduate School;
  • records of deceased persons. The person responsible for such records, however, should exercise informed discretion in responding to requests for disclosures and should ensure that the person making the request has a legitimate interest in the information and that the privacy interests of the deceased and third parties are considered; and
  • applicants for admission. However, the admission-related records of applicants who become students at the Graduate School are subject to this policy.

Policy

• Generally, personally identifiable information from education records may not be disclosed to other parties without the student’s prior written or electronic consent. Such consent shall be 1) signed (on paper or using an appropriate electronic signature method) and dated and 2) shall specify records or information to be disclosed, the purpose(s) of the disclosure, and 3) the party or class of parties to whom disclosure may be made.
• The Graduate School may release a graduate student’s education records to Graduate School officials with legitimate interests without the graduate student’s consent to access or review the records to:
  • Perform a task specified in his or her position description or contract;
  • Disseminate academic and/or demographic and/or enrollment and/or financial and/or personal aggregated information internally and externally;Perform a task related to a graduate student’s education or to graduate student discipline;
  • Provide a service or benefit related to the graduate student (financial aid, transfer credit process, grants administration, etc.); 
  • Maintain a safe and secure campus; 
  • Specified officials for audit or evaluation purposes (financial audit including grants funding audits, THEC, SACSCOC, etc.);
  • Carry out the functions of the U.S. Department of Education, the Comptroller General, state and local educational authorities, and accrediting organizations;
  • In response to a lawfully issued subpoena or judicial order, provided that the Graduate School makes a reasonable effort to notify the student whose records is involved in advance of disclosing the information, unless the situation prohibits prior notification. All subpoenas and court orders should be directed to the Office of Legal Services and disclosure in response to them must be approved by that office;
  • To comply with a judicial order or lawfully issued subpoena;
  • Regarding directory information; and
  • In connection with an emergency if knowledge of the information is necessary to protect the health or safety of the graduate student or other individuals.

If such disclosure is made, it should be limited to information necessary for the purpose of the disclosure. Note also that specific requirements and qualifications may apply to these exceptions.

• Upon written request, the Graduate School will disclose education records to officials of another school at which a graduate student seeks or intends to apply.
  The Graduate School will inform a party to whom a disclosure of personally identifiable information from the records of a graduate student is made that disclosure is made only on the condition that the party will not disclose the information to any other party without the student’s prior written consent. Exceptions to this requirement include disclosure of directory information, disclosures to the student, to victims of certain disciplinary matters, and disclosures pursuant to court orders and valid subpoenas.
  Before disclosing personally identifiable information from education records, Graduate School employees must take reasonable steps to verify the identity of the requesting party as well as their authority to have access to the information.
  Individuals who are, or have been, in attendance at the Graduate School are entitled to inspect and review their education records upon a written request. The request to inspect or review records must be honored within 45 days after the Graduate School has received the request. The request should be directed to the office that maintains the record and such office may charge a reasonable fee for copies.
  • A student who believes that information contained in his or her education records is inaccurate or misleading or violates his or her privacy rights may request that the Graduate School amend them, and the Graduate School will decide whether to do so within a reasonable period of time.
  • If the Graduate School decides that the information is inaccurate or misleading or otherwise in violation of the privacy rights of a student, the Graduate School will amend the record and inform the student of the amendment in writing.
  • If the Graduate School declines to amend the student’s records, it will so inform the student and inform him or her of the right to request a hearing to challenge the information believed to be inaccurate, misleading or in violation of his or her privacy rights. A hearing, however, may not be requested by a student to contest the appropriateness of a grade.
  • The hearing will be conducted by a Hearing Officer who does not have a direct interest in the outcome of the hearing and will provide the student an opportunity to present evidence relevant to the request to amend the student’s records. The Hearing Officer will provide to the Graduate School and the student a written decision based on the evidence presented at the hearing within a reasonable time after the hearing. The decision will include a summary of the evidence and the reasons for the decision. Additionally, information regarding hearing procedures will be provided when the student receives notice of his or her rights.
  • If, after a hearing, the Graduate School determines that a student’s challenge is without merit it will notify the student of the right to place in his or her records a statement commenting on the challenged information and/or setting forth reasons for disagreeing with the Graduate School ‘s decision. The Graduate School will maintain such statement with the student’s record and disclose the statement whenever it discloses the portion of the record to which the statement relates.
• A graduate student does not have a right to inspect or review the following:
  • Financial records and statements of the student’s parent(s), except with the written permission of the parent(s).
  • Confidential letters and statements of recommendation related to admission to an educational institution, application for employment, or the receipt of an honor or honorary recognition that were placed in a student’s records and as to which the student has executed a written waiver of his or her right to inspect and review; provided that the Graduate School uses the letters and statements only for the purpose for which they were originally intended and notifies the graduate student upon request of the names of all individuals providing such letters and statements.
  • Other records as to which the graduate student has executed a written waiver of his or her right to inspect and review. 
  • Those portions of records that contain information on other graduate students.

80.92.020: Protected Health Information (PHI) Uses and Disclosures

Derived from St. Jude institutional policy 70.06.004 (Owner, John M. Bailey)

Purpose

• To establish the limits of the Use and Disclosure of Protected Health Information (“PHI”) in the Graduate School.

Policy

Faculty, students, and employees in the Graduate School are permitted to Use or Disclose PHI:

• To the Individual or to his or her Personal Representative; 
• For continuity of care, treatment, or health care operations without an Individual Authorization of a patient or Personal Representative;
• Incident to a Use or Disclosure that is permitted by the Privacy Rule; 
• Pursuant to a valid Authorization;
• Pursuant to an agreement or in emergency circumstances to a family member, relative, or any other person identified by the Individual or Personal Representative if relevant to such person’s involvement with the Individual’s health care;
• As otherwise permitted by the Privacy Rule as outlined by 45 C.F.R. §164.512 (e.g. uses and disclosures for public health activities, victims of abuse, neglect, or domestic violence, uses or disclosures for health oversight activities) as described in Policy 70.06.014 Use and Disclosure of Protected Health Information without an Authorization;
• As required by law;
• For purposes of research as described in Policy 70.06.024, The Use and Disclosure of Protected Health Information for Research;
• For purposes of Disclosing a Limited Data Set once a Data Use Agreement is already in place with a recipient as described in Policy 70.06.025, The Use and Disclosure of Protected Health Information for a Limited Data Set; or
• For the purposes of averting a serious harm or threat as described in Policy 70.06.022, The Use and Disclosure of Protected Health Information to Avert Serious Threat to Health or Safety. 45 C.F.R.§164.512(j)

References

• 45 C.F.R. §164.512
• 45 C.F.R. §164.512(j)

80.92.021: De-Identification of PHI

Derived from St. Jude institutional policy 70.06.006 (Owner, John M. Bailey)

Purpose

• The Graduate School may use De-Identified Protected Health Information (“PHI”) for student research with appropriate patient consents.
• Health information that does not identify an individual and there is no reasonable basis to believe the information can be used to identify an individual is not PHI, and the Privacy Rule and Security Rule are not applicable.

Definitions

See Privacy Policy and Procedures Policy 70.06.001.

Policy

• PHI will be considered De-Identified when the risk is very small that the information could be used alone or in combination with other reasonably available information to identify an individual.
• The following Identifiers of a patient and his or her relatives, employers, or household members are removed to create PHI:
  • Names;
  • All geographic subdivisions smaller than a state, including street, address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:
    1. The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
    2. The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people are changed to 000.
  • All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age (90 or older);
  • Telephone numbers;
  • Fax numbers;
  • Electronic mail addresses;
  • Social security numbers;
  • Medical record numbers;
  • Health plan beneficiary numbers;
  • Account numbers;
  • Certificate / license numbers;
  • Vehicle identifiers and serial numbers, including license plate numbers;
  • Device identifiers and serial numbers;
  • Web Universal Resource Locators (URLs);
  • Internet Protocol (IP) address numbers;
  • Biometric identifiers, including finger and voice prints;
  • Full face photographic images and any comparable images; 
  • Any other unique identifying number, characteristic, or code.
• The Graduate School does not have actual knowledge that the information could be used alone or in combination with other information to identify any individual, patient, or relatives, employers, or household members of the individual who is the subject of the information.

References

• 45 C.F.R. § 164.502(d).
• 45 C.F.R. § 164.514.

80.92.022: Use and Disclosure of PHI Without Authorization

Derived from St. Jude institutional policy 70.06.014 (Owner, John M. Bailey)

Purpose and Scope

• This policy and its accompanying procedures apply to Graduate School faculty and students.
• Permitted Uses and Disclosures of Protected Health Information (“PHI”) without the patient’s or Personal Representative’s Authorization.

Definitions

• Authorization - Document designating permission for the use and disclosure of an individual’s Protected Health Information.
• Business Associate ("BA") - An outside person/entity that performs a service on behalf of a Graduate School student or researcher or during which individually identifiable health information is created, used, or disclosed.
• Individual - the person who is the subject of the Protected Health Information.
• Personal Representative - A person authorized under state or other law to act on behalf of the individual in making health-related decisions.
• PHI – Protected Health Information.
• Public Health Authority - a federal or state agency or authority and its employees or agents that are responsible for public health matters as part of its official mandate.
• Workforce - trainees, students, employees, volunteers, and other persons whose conduct in the performance of work for Graduate School, is under direct control by Graduate School, and whether or not they are paid by the Graduate School.

Policy

• The St. Jude Graduate School faculty and students are permitted by HIPAA to use and disclose PHI for treatment purposes and for health care operations without an Authorization from the patient or Personal Representative. These uses and disclosures must otherwise comply with the Privacy Rule and Security Rule and with other applicable state and Federal statutes and regulations regarding the confidentiality of patient information.
• In addition to uses and disclosures related to treatment and health care, the Graduate School may also use and disclose PHI without an individual patient’s or Personal Representative’s permission, consent or Authorization for the following purposes: 
  • Required By Law. The St. Jude Graduate School faculty and students may disclose PHI as required by federal, state, or other applicable law and the use or disclosure complies with and is limited to the relevant requirements of the law. Any inquiries, questions or concerns should be referred to the Office of Legal Services or Privacy Officer. 
  • Public Health Activities. As required or permitted by law, the Graduate School faculty and students may disclose PHI to a public health authority that is authorized by law for the purpose of, for example, preventing or controlling disease, to report disease injury or disability, or vital events such as death, reports of child abuse or neglect, or communicable diseases; and the conduct of public health surveillance, public health investigations, and public health interventions; or, at the direction of a public health authority, to an official of a foreign government agency that is acting in collaboration with a public health authority. 
  • Food and Drug Administration (FDA). The Graduate School faculty and students may disclose PHI to the FDA, or to an entity regulated by the FDA to report an adverse event or a defect related to an FDA-regulated product or activity such as a drug or medical device. Other reasons include but are not limited to: tracking FDA-regulated products; enabling product recalls, repairs or replacement; conducting post marketing surveillance.
    o Communicable Diseases. To the extent permitted or required by law, the Graduate School faculty and students may disclose PHI to a public health authority concerning a person who may have been exposed to a communicable disease or who is otherwise at risk of spreading a disease or condition.
  • Health Oversight Activities. The Graduate School faculty and students may disclose PHI for oversight activities that are authorized by federal or state law, including audits; civil, administrative, or criminal investigations; inspections; licensure, or disciplinary actions; or other activities related to provision of health care. 
  • Armed Forces and Veterans. The Graduate School faculty and students may use or disclose an individual’s PHI who is Armed Forces personnel for activities deemed necessary by appropriate military command authorities. 
  • Workers’ Compensation. The Graduate School faculty and students may disclose PHI as authorized by and to the extent necessary to comply with laws relating to and for the purpose of workers’ compensation or similar programs that provide benefits for work-related injuries or illness. All requests or inquiries shall be referred to Human Resources.

References

• 45 C.F.R. §164.512
• 45 C.F.R. §164.502 (g)
• 45 C.F.R. §164.50

80.92.023: Use and Disclosure of PHI Requiring Authorization

Derived from St. Jude institutional policy 70.06.15 (Owner, John M. Bailey)

Purpose and Scope

• To describe permitted Uses and Disclosures of Protected Health Information (‘PHI’) for which a patient’s Authorization is required.
• This policy and its accompanying procedures apply to all Workforce members of St. Jude Children's Research Hospital Graduate School of Biomedical Sciences and St. Jude Children's Research Hospital.

Definitions

• Authorization - Document designating permission for the Use and Disclosure of an Individual’s Protected Health Information.
• Personal Representative - A person authorized under state or other law to act on behalf of the individual in making health-related decisions.
• Workforce Members - Workforce means students, employees, volunteers, and other persons whose conduct, in the performance of work for a covered entity or business associate, is under the direct control of such covered entity or business associate, whether or not they are paid by the covered entity or business associate.

Policy

• Except as for Treatment, Health Care Operations, or Payment purposes or required by law or as stated in St. Jude Institutional Policy 70.06.014 - Use and Disclosure of PHI without an Authorization, Graduate School employees and students may only Use or Disclose PHI with a valid Authorization. When a Graduate School employee or student obtains or receives a valid Authorization, the Use or Disclosure of PHI must be consistent with the Authorization.
• Graduate School employees and students must obtain an Authorization for any Use or Disclosure of Psychotherapy notes except to carry out Treatment, Payment, or Health Care Operations regarding only:
  • Use or Disclosure for training programs in which students, trainees, or practitioners in mental health learn under the supervision of mental health professionals; or
  • Use or disclosure by the covered entity to defend itself in a legal action or other proceeding brought by the individual;
• Graduate School employees and students do not need a valid Authorization regarding the Use or Disclosure of Psychotherapy notes if it is:
  • Required by the U.S. Department of Health and Human Services; or Required by law; any inquiries, questions or concerns, should be referred to the St. Jude Office of Legal Services and the St. Jude Privacy Officer; or
  • To a Health Oversight Agency with respect to oversight of the originator of the Psychotherapy notes; or
  • To a coroner or medical examiner; or
  • With regard to an imminent threat to the safety of the Individual students, patient, or to others. 
• Sale of PHI. Graduate School employees and students may not Disclose any PHI that is a sale of PHI. 
• Core Requirements
  • The Graduate School shall forward any signed Authorization to the St. Jude Privacy Officer who will document and retain the Authorization for at least six (6) years. The St. Jude standard Authorization Form contains the following elements:
    1. A description of the information to be Used or Disclosed that identifies the information in a specific and meaningful fashion;
    2. The name or other specific identification of the person(s) or class of persons, authorized to make the requested Use or Disclosure;
    3. The name or other specific identification of the person(s) or class of persons to whom St. Jude may make the requested Use or Disclosure; A description of the requested Use or Disclosure- “at the request of the Individual” is a sufficient description;
    4. An expiration date or an expiration event that relates to the individual- the statement “end of the research study” or “none” or similar language is sufficient if the Authorization is for a Use or Disclosure of PHI for research, including the creation and maintenance of a research database or research repository;
    5. The signature of the individual or Personal Representative and date. If the Authorization is signed by the Personal Representative of the individual, a description of the representative’s authority to act for the Individual must be provided;
    6. A statement that the Individual has to right to revoke the Authorization in writing;
    7. A statement that St. Jude will not condition treatment, payment, enrollment, or eligibility of benefits on whether the individual or Personal Representative signs the Authorization; and
    8. A statement that potential for information disclosed pursuant to the Authorization could be subject to re-disclosure by the recipient and thus no longer be protected.
  • The Authorization must be in plain language.
  • St. Jude will provide a copy of the signed Authorization to the individual or Personal Representative. 
• Compound Authorizations. If any St. Jude Workforce Member has any concerns or questions about combining Authorizations for various purposes, contact the St. Jude Privacy Officer for further guidance.

Procedure

N/A.

References

• 45 C.F.R. §164.508
• St. Jude Policy 70.06.014 and St. Jude Graduate School Policy 80.92.022 - Use and Disclosure of PHI without an Authorization

Forms and Documents

Authorization to Use or Disclose Health Information From St. Jude Children’s Research Hospital Form 4556 Rev. 08/04

80.92.024: Use and Disclosure of PHI for Research

Derived from St. Jude institutional policy 70.06.24 (Owner, John M. Bailey)

Purpose and Scope

• To ensure appropriate and legal Use and Disclosure of patient Protected Health Information (“PHI”) for Research purposes. 
• This policy and its accompanying procedure apply to all staff members and students of the Graduate School.

Policy

• Background
  • The Privacy Rule establishes the conditions under which PHI may be Used or Disclosed by the Graduate School or St. Jude for Research purposes. Research is defined in the Privacy Rule as, “a systematic investigation, including research development, testing, and evaluation, designed to develop or contribute to generalizable knowledge.” St. Jude may always Use or Disclose for Research purposes health information which has been De-identified without regard to the provisions below. 
  • The Privacy Rule also defines the means by which Individuals will be informed of the Uses and Disclosures of their PHI for Research purposes, and their rights to access information about them held by the Graduate School or St. Jude. Where Research is concerned, the Privacy Rule protects the privacy of individually identifiable health information, while at the same time ensuring that researchers continue to have access to health information necessary to conduct vital Research. Currently, most Research involving human subjects operates under the Common Rule (45 CFR Part 46, Subpart A) and/or the Food and Drug Administration’s (FDA) human subject protection regulations (21 CFR Parts 50 and 56), which are similar to, but separate from, the Privacy Rule’s provisions for Research. These human subject protection regulations, which apply to most Federally-funded and to some privately funded Research, include protections to help ensure the privacy of subjects and the confidentiality of information. The Privacy Rule builds upon these existing Federal protections. The Privacy Rule creates standards of privacy protection for Research governed by the existing Federal human subject regulations.
• Applying HIPAA Rules. In the course of conducting Research, researchers may obtain, create, use, and/or disclose individually identifiable health information. Under the Privacy Rule, the Graduate School is permitted to Use and Disclose PHI for Research with an Individual’s Authorization, or without Individual’s Authorization under limited circumstances set forth in the Privacy Rule. 
• Research Use/Disclosure Without an Authorization. To Use or Disclose PHI without an Authorization by the Research participant, the Graduate School must abide by the following rules: 
  • Either, obtain documented Institutional Review Board (IRB) Approval. There are situations where an IRB can approve that documentation of an alteration or waiver of Research participants’ Authorization for Use/Disclosure of PHI for Research purposes The Graduate School may Use or Disclose PHI for Research purposes pursuant to a waiver of an Authorization by an IRB in conjunction with St. Jude IRB, provided it has obtained the following documentation: 
    1. Identification of the IRB and the date on which the alteration or waiver of Authorization was approved; 
    2. A statement that the IRB has determined that the alteration or waiver of Authorization, in whole or in part, satisfies the three (3) criteria in the Privacy Rule (see below); 
    3. A brief description of the PHI for which use of or access to has been determined to be necessary by the IRB; 
    4. A statement that the alteration or waiver of authorization has been reviewed and approved under either normal or expedited review procedures; and 
    5. The signature of the chair or other member, as designated by the chair, of the IRB, as applicable. 
  • Or, obtain documented Institutional Review Board (IRB) Waiver. The following three (3) criteria must be satisfied for an IRB to approve a waiver of Authorization. These criteria ensure that the Use or Disclosure of PHI involves no more than a minimal risk to the privacy of Individuals. 
    1. an adequate plan to protect the identifiers from improper Use and Disclosure; 
    2. an adequate plan to destroy the identifiers at the earliest opportunity consistent with conduct of the research, unless there is a health or research justification for retaining the identifiers or such retention is otherwise required by law; and 
    3. adequate written assurances that the PHI will not be reused or Disclosed to any other person or entity, except as required by law, for authorized oversight of the Research study, or for other Research for which the Use or Disclosure of PHI would be permitted; 
  • Demonstrate that the Research could not practicably be conducted without the waiver or alteration; and 
  • Demonstrate that the Research could not practicably be conducted without access to and Use of the PHI. 
  • Preparatory to Research. Representations from the researcher, in writing (form is available from St. Jude HIMS), that the Use or Disclosure of the PHI is solely to prepare a Research protocol or for similar purposes preparatory to Research, that the Researcher will not remove any PHI from St. Jude in the course of review, and representation that PHI for which Use or access is sought is necessary for the Research purpose. For example, to design a Research study or to assess the feasibility of conducting a study. 
  • Research on PHI of Decedents. A researcher must represent, either in writing or orally, that the Use or Disclosure being sought is solely for research on the PHI of Decedents, that the Decedent’s PHI being requested is necessary for the research, and, at the request of St. Jude, documentation of the death of the Individual Decedent(s).
  • Limited Data Sets with a Data Use Agreement. A Data Use Agreement may be entered into by the Graduate School and the researcher and/or Institution, pursuant to which the Graduate School may Disclose a Limited Data Set to the researcher and/or Institution for research purposes. A Limited Data Set excludes specified direct identifiers of the Individual or of relatives, employers, or household members of the Individual. For example: names; postal address information other than town or city, state and zip code; fax numbers; etc. (See https://home.stjude.org/legal/Pages/hipaa-researchers.wspx for more information). The Data Use Agreement must include the following: 
    1. Establishing the permitted Uses and Disclosures of the Limited Data Set by the recipient, consistent with the purposes of the research, and which may not include any Use or Disclosure that would violate the Privacy Rule if done by the Graduate School; 
    2. Limiting who can Use or receive the data; and 
    3. Requiring the recipient to agree to the following:
       • i. Not to Use or Disclose the information other than as permitted by the Data Use Agreement or as otherwise required by law;
       • ii. Use appropriate safeguards to prevent the Use or Disclosure of the information outside the Uses outlined in the Data Use Agreement;
       • iii. Report to the Graduate School any Use or Disclosure of the information not provided for by the Data Use Agreement of which the recipient becomes aware;
       • iv. Ensure that any agents to whom the recipient provides the Limited Data Set agrees to the same restrictions and conditions that apply to the recipient with respect to the Limited Data Set; and
       • v, Not to identify the information or contact the Individual.
         (a) Note: Refer to Policy 70.06.025 The Use and Disclosure of PHI for a Limited Data Set.
         

• Research Use/Disclosure with an Individual Authorization. The Privacy Rule also permits the Graduate School to Use or Disclose PHI for research purposes when a research participant authorizes the Use or Disclosure of PHI. For example, a research participant’s Authorization will typically be sought for most clinical trials and some records research. In this case, documentation of IRB approval of a waiver of authorization is not required for the Use or Disclosure of this PHI. To Use or Disclose PHI with an authorization by the research participant, the Graduate School must obtain an authorization that satisfies the requirements of St. Jude Policy 70.06.015 Use and Disclosure for Which an Authorization is Required. The Privacy Rule has a general set of authorization requirements that apply to all Uses and Disclosures, including those for Research purposes. However, several special provisions apply to Research Authorizations:
  • Unlike other authorizations, an Authorization for a Research purposes may state that the authorization does not expire, that there is no expiration date or event, or that the authorization continues until the “end of the research study;” and 
  • An authorization for the Use or Disclosure of PHI for research may be combined with a consent to participate in the research, or with any other legal permission related to the research study. 
• Accounting for Research Disclosures
  • In general, the Privacy Rule gives individuals the right to receive an accounting of certain disclosures of PHI made by the Graduate School. This Accounting must include Disclosures of PHI that occurred during the six (6) years prior to the Individual’s request, or since April 14, 2003, (whichever is sooner), and must include specified information regarding each disclosure. A more general accounting is permitted for subsequent multiple disclosures to the same person or entity for a single purpose. Among the types of disclosures that are exempt from this accounting requirement are: 
    1. Research Disclosures made pursuant to an Individual’s Authorization; 
    2. Disclosures of the Limited Data Set to researchers with a Data Use Agreement. 
  • In addition, for Disclosures of PHI for research purposes without the individual’s authorization that involve at least 50 records, the Privacy Rule allows for a simplified accounting of such disclosures. Under this simplified accounting provision, St. Jude may provide Individuals with a list of all protocols for which the patient’s PHI may have been disclosed, as well as the researcher’s name and contact information. 
  • Procedure for Accounting
    1. When an individual requests an Accounting of Disclosures, he or she shall be referred to the St. Jude Privacy Officer in consultation with the Office of Human Subjects’ Protection (OHSP) who shall assist them in the completion of the PHI Disclosure Accounting Request Form, Form 4518.
    2. The St. Jude Privacy Officer, in cooperation with OHRP shall:
       • i. Complete the Privacy Officer portion of the Request for PHI Disclosure Accounting Form, Form 4518.
       • ii. Verify that the initial portion of the Form is fully completed, and the Disclosure Accounting request is clear.
         
       • iii. Verify that the person requesting the Disclosure Accounting is authorized to do so.
         
       • iv. Verify that the time frame for the disclosure accounting requested is not more than six (6) years prior to the PHI disclosure Accounting request date; or
       • v. Verify the time frame for the PHI Disclosure Accounting requested is not prior to the effective date of April 14, 2003.
    3. If the request is in order, the St. Jude Privacy Officer, in cooperation with OHRP will prepare the Disclosure of Accounting and provide it in writing, to the requesting party, maintaining a copy with the St. Jude Privacy Officer. 
    4. The Graduate School will act on the individual's request no later than 60 days after receipt of such a request. If the Graduate School is unable to provide the accounting within 60 days, the Graduate School may extend the time to provide the Accounting by no more than 30 days, provided that: the Graduate School and St. Jude provide the individual with a written statement of the reasons for delay and the date by which the Graduate School will provide the accounting. The Graduate School may have only one such extension of time for action on a request for an accounting. The Graduate School will provide the first accounting to a requesting party in any twelve (12) month period without charge. The Graduate School and St. Jude may impose a reasonable, cost-based fee for each subsequent request for an Accounting of Disclosures made by the same requesting party within a single twelve (12) month period, provided, however, the Graduate School notifies the requesting party in advance of the fee and provide the requesting party with an opportunity to withdraw or modify the request.
• Transition Provisions. Under the Privacy Rule, the Graduate School may Use and Disclose PHI that was created or received for research, either before or after April 14, 2003, if the Graduate School obtained any one of the following prior to April 14, 2003:
  • An Authorization or other express legal permission from an Individual to Use or Disclose PHI for the Research; 
  • The Informed Consent of the Individual to participate in the Research; or 
  • A waiver of Informed Consent by an IRB in accordance with the Common Rule or an exception under FDA’s human subject protection regulations for emergency research purposes; however, if a waiver of Informed Consent was obtained prior to April 14, 2003, but Informed Consent is subsequently sought after April 14, 2003, St. Jude must obtain the Individual’s Authorization. For example, if there was a temporary waiver of Informed Consent for emergency Research under the FDA’s human subject protection regulations, and Informed Consent was later sought subsequent to April 14, 2003, Individual Authorization would be required before the St. Jude Graduate School could Use or Disclose PHI for the Research after the waiver of Informed Consent was no longer valid.

Procedure

• All inquiries or responses regarding Uses and Disclosures of PHI for Research purposes should be referred to the Director of the Human Subjects Protection Office and the HIPAA Privacy Officer.

References

• 45 C.F.R. §164.501
• 45 C.F.R. §164.512(i)(1)(i)
• 45 C.F.R. §164.512(i)(1)(ii)
• 45 C.F.R. §164.512(i)(1)(iii)
• 45 C.F.R. § 164.514(e)
• 45 C.F.R. §164.528
• 45 C.F.R. §164.528(b)(3)
• Institutional Review Board Policy and Procedure Manual for Research Involving Human Subjects

Forms and Documents

• Informed Consent for Research (Therapeutic) IRB Approved Version: February 24, 2009.
• Informed Consent for Research (Non-Therapeutic) IRB Approved Version: February 24, 2009.
• PHI Disclosure Accounting Form, Form 4518.

80.92.025: Communication Policy Related to Non-Electronic PHI

Derived from St. Jude institutional policy 70.06.035 (Owner, John M. Bailey)

Purpose and Scope

• The use of fax, phone, voice mail or Text Messaging (“Communication Tools”) by Graduate School staff members and students is to assist them in the performance of their job responsibilities. These communication tools allow staff and students to communicate with patients and their families and other appropriate personnel which include communicating for treatment purposes. The purpose of this policy is to establish guidelines for the Use and Disclosure of patient data, Protected Health Information ("PHI") and Personally Identifiable Information to ensure this use is appropriate, lawful and consistent with the mission of the institution.
• This policy and its accompanying procedure apply to all staff members and students of the Graduate School.

Definitions

• Breach - An impermissible use or disclosure under the Privacy Rule that compromises the security or privacy of the PHI. 
• Text Messaging - Text messaging means the exchange of brief written messages between mobile phones, over cellular networks and may include messages which may contain image, video, and sound content. Individual messages are referred to as "text messages" or "texts.” The most common application of the service is person-to-person messaging, but text messages may also be used for other institutional notifications with staff or patients that were previously sent by post or left as voicemail.

Policy

• Permitted Uses. The use of Communication Tools for the Use and Disclosure of PHI and Personally Identifiable Information as defined in St. Jude Institutional Policy 50.01.073 – Information Protection Standard shall only be used and disclosed consistent with the Graduate School job or research duties and responsibilities. For Fax transmissions, refer to St. Jude Institutional Policy 20.12.004.
• Communication Tools may not be used to: 
  • Make any discriminatory statements based on race, gender, religion, national origin, sexual preference, disability or veteran status;
  • Harass or intimidate another person;
  • Interfere with a person’s ability to perform their job;
  • Access, read, copy, store or forward inappropriate or sexually explicit messages or materials;
  • Use, copy or distribute documents in violation of U.S. copyright laws;
  • Fabricate and send a Text Message so it appears to be from another person;
  • Obtain access to the files or Text Message of others without proper authorization;
  • Breach any information security systems;
  • Send non-requested communications such as “chain letters,” “prayer wheels” solicitations for goods or services or Text Messages that ask the recipient to forward the message to others;
  • Broadcast/circulate personal information, such as items for sale, giveaways, promotional activities, personal announcements, etc. (exception – St. Jude Bulletin Board);
  • For personal use if such use interferes with the person’s job performance; or
  • For any purpose that constitutes a violation of applicable laws or regulations.
  • Use of the Communication Tools in violation of this policy may result in disciplinary action up to and including termination of employment.
• Privacy
  • All PHI, Personally Identifiable Information, financial, research or other proprietary information should be treated as confidential and its transmission by the Communication Tools should be protected to the same extent as other forms of confidential communication;
  • Confidential information contained in these Communication Tools should only be sent to authorize individuals inside and outside the institution on a “need to know” basis. Extra caution should be taken when addressing texts to ensure they are not inadvertently sent to the wrong person;
  • The HIPAA Privacy Rule permits the Graduate School staff members and students to communicate with patients, whether through the mail or by phone, fax, or in some other manner (e.g. text messaging);
  • To reasonably safeguard the Individual’s privacy, Graduate School students and staff members should limit to the extent possible the amount of personal information disclosed in Communication Tools to ensure that no use of these Communication Tools would be a significant risk to the financial, reputational, or other harm to an Individual patient or family member, or Graduate School staff member or student; and
  • In situations where an individual patient /parent / legal guardian or Personal Representative has requested that a Graduate School staff member or student communicate with him or her in a confidential manner, such as by alternative means or at an alternative location, the Graduate School will accommodate that request, if reasonable. 
• Text messages.
  • While every reasonable measure is taken by the Graduate School to protect the security of its internal information systems, Text Messaging does not provide a totally secure means for communicating privileged, sensitive or confidential information, so caution should be exercised in using Text Messages to communicate confidential or sensitive matters, particularly those involving patients, family members, or employees.
  • An Individual patient, parent, or legal guardian or Personal Representative must agree and consent to receive Text Messages from a Graduate School staff member or student by signing the General Consent For Routine Medical Diagnosis and Treatment and Release of Information, Form 451 in the Patient Registration Department. 
  • The Graduate School will use all reasonable means to protect the privacy and security of Text Message information. Text Messages used in a limited way can be an essential form of communication among and between St. Jude healthcare providers and support personnel and are used to facilitate the healthcare process and assist in the health care treatment of our patients. Employees should be aware that Text Message communications are both difficult to delete and may be subject to discovery in a lawsuit. Additionally, the informality of Text Messages may lead employees or workforce members to be more casual in communications than they would otherwise be when documenting communications. The Graduate School staff members and students should take care to ensure that the tone and content of their communications in a text is appropriate. 
  • These additional steps should be followed:
    1. Text Messages may be forwarded internally as necessary for diagnosis, treatment, or other healthcare operations. Graduate School staff members and students should not however, forward Text Messages to third parties outside the institution without the patient/parent/legal guardian/or Personal Representative’s prior written permission or authorization or except as authorized by the Office of Legal Services.
    2. The Graduate School cannot guarantee that any particular Text Message will be read and responded to within any particular period of time. Individual patients / parents / legal guardians/ or Personal Representative should be instructed not to use Text Messages for medical emergencies or other time sensitive matters.
• Copyrighted Information. Use of Communication Tools to transmit copyrighted information, including software, research data, manuscripts, music, video files and graphics without the consent of the copyright holder is strictly prohibited. 
• Other Access. On occasion, a Graduate School staff member or student may, during the performance of their duties, inadvertently see the contents of a particular message. There may also be circumstances where it will be necessary for appropriate personnel to view a particular Text message. Any intentional, unauthorized viewing or disclosure of the contents of a particular Text message is strictly prohibited and will subject the Graduate School staff member or student to discipline up to and including termination. 
• Breach and Non-compliance. 
  • When a Graduate School staff member or student suspects or knows of a Breach or other impermissible Disclosures or uses of patient data, PHI, or EPI, the Graduate School staff member or student will comply with St. Jude Institutional Policies 50.01.020 – Acceptable Use Agreement and 70.06.034 - Breach Notification and/or may contact the St. Jude Privacy Officer or Information Sciences.
  • Failing to comply with the Graduate School and St. Jude policies and procedures related to offsite use of, or access to PHI or Personally Identifiable Information may subject the Graduate School staff member or student to discipline up to and including termination. 

Procedure

N/A.

References

• HIPAA Privacy Rule, 45 C.F.R. part 160 and part 164.
• American Recovery and Reinvestment Act, The Health Information Technology for Economic and Clinical Health Act (HITECH).

Forms and Documents

Consent for Routine Medical Diagnosis and Treatment and Release of Information, Form 451
 

80.92.026: Human Subjects Protection

Derived from St. Jude policy 30.02.011 (Owner, Theresa Carr)

Purpose and Scope

• The Graduate School will comply with the Office for Human Research Protections (OHRP) expectation that institutions will ensure that students involved in human subjects research will understand and comply with regulations for the protection of human research subjects.
• Graduate students cannot apply for NIH funding to support research that involves human subjects. 
• Applications by students to other funding agencies to support research that involves human subjects must be reviewed and approved by the SVP/COO prior to submission.
• Students who have contact with research subjects, human materials and/or research - related private health information will be required to complete initial training in human subject protections before under-taking any clinical research activity and any additional trainings deemed necessary. Individuals responsible for the oversight of clinical research activities are included in this policy.

Definitions

• CITI - Collaborative Institutional Training Initiative
• DHHS - Department of Health and Human Services
• FDA - Food and Drug Administration
• HSP - Human Subject Protections
• ICH  - International Conference on Harmonization 
• NIH - National Institutes of Health 
• OCRE - Office of Clinical Research Education 
• OHRP - Office for Human Research Protections
• PHI - Protected Health Information
• PI - Principal Investigator

Policy

• The Graduate School requires that all students having contact with St. Jude research subjects or the subjects’ identifiable protected health information (PHI) must complete the Collaborative Institutional Training Initiative (CITI) human subject training course. 
• Students who perform research on human tissue or maintain tissue repositories that include any PHI or other identifiable private information linked to the human tissue/specimen must also complete CITI training. 
• Training must be completed regardless of the funding source or sponsor of the project.
• No student may become involved in any human subjects’ research-related activity without having completed this training.
• Re-certification is accomplished by completing the basic course at required intervals usually every two years.
• The Graduate School Dean and the PI are the responsible leaders of the team conducting a study and responsible for compliance with the ethical and regulatory conduct of the project.

Procedure

• HSP training and education is a shared responsibility of the Principal Investigator (PI) and the institution per FDA and DHHS regulations and ICH guidance. The PI selects qualified sub-investigators based on training and experience for the conduct of all aspects of the clinical trial and ensures they are aware of regulatory requirements and acceptable standards for the conduct of clinical trials and the protection of human subjects.
• The Office of Clinical Research Education (OCRE) provides the guidance and training opportunities to meet the HSP training requirements, and tracks and monitors compliance with the policy. OCRE makes the CITI training information available to the appropriate groups of employees, students, and trainees. In addition, OCRE maintains a record of completed training and updates the institutional electronic HSP training database, ensures that the CITI HSP training program continues to satisfy all mandates, and that individual HSP re-certification is achieved.
• Students may access detailed CITI registration instructions and the CITI hyperlink on the St. Jude intranet on the St. Jude Clinical Research Education webpage under “CITI Links and Information.” 
• Individual HSP re-certification is required every two years for students. This requirement is met by retaking the required basic biomedical or social/behavioral course.
• HSP courses are designated by “Group” and should be selected based on the level and type of involvement with human research volunteers. 
• The PI, the person ultimately responsible for the ethical and regulatory oversight of study conduct, and the student work collaboratively with the OCRE to comply with this policy. 
• The Graduate School through OCRE, and in collaboration with administration of the PI’s department and clinical trials directors, provides guidance and training opportunity for all students that meet the criteria for the training requirement.
• The Office of Clinical Research Education can be contacted 7:30 am – 4:00 pm for assistance at 901–595–4773.

References

• OHRP Federal Wide Assurance
• NIH directive for NIH funding (Notice OD-00-039, August 2000) for new and non-competing awards
• FDA 21 CFR 312.53, 21CFR 312.3 and 21 CFR 812.3
• FDA Guidance: Guidance for Industry: Investigator Responsibilities - Protecting the Rights, Safety, and Welfare of Study Subjects October 2009

Forms and Documents

• Chart for Training Requirements
• Chart should be accessed through the St. Jude Clinical Trials Administration Education Office intranet site
   

80.93.001: Research Misconduct

Purpose and Scope

• To protect scientific research integrity in the Graduate School and St. Jude and to comply with federal regulatory requirements under 42 C.F.R. Part 93 regarding reporting and investigating allegations of Research Misconduct. 
• This policy applies to all research activities conducted under the auspices of the Graduate School and includes but is not limited to “Institutional Members”.
• Entities with which the Graduate School has consortium or contractual arrangements and who receive U.S. Public Health Services (PHS) support through the Graduate School or St. Jude shall have an assurance on file with the Office of Research Integrity (ORI), and internal policies in compliance with 42 CFR 93 regarding procedures for investigating and reporting possible Research Misconduct to ORI. 
• The Graduate School and St. Jude have more stringent standards than the narrow definition of research misconduct defined in the federal regulations and may find conduct to be actionable under its standards even if the action does not meet the federal definition of research misconduct. 
• Conduct that does not meet ORI’s definition of Research Misconduct but warrants investigation and action by the Graduate School and St. Jude under this policy includes: 
  • intentional or reckless disregard for, or significant and substantial departure from accepted research practices, applicable federal regulations, IRB directives on the appropriate and ethical conduct of human subjects’ research, IACUC directives on the appropriate and ethical conduct of animal research, or recognized research ethics; 
  • falsification of academic or professional credentials; and 
  • submission to journals or research sponsors of work product that contains intentional or reckless material misstatements or omissions. 
• A finding of research misconduct may occur if there is a significant departure from accepted practices at the Graduate School and St. Jude that were committed intentionally, knowingly, or recklessly and proven by preponderance of the evidence.
• Research Misconduct occurring more than six years prior to submission of the allegation will not be investigated unless there is compelling reason to do so, including: 
  • the alleged Research Misconduct was not reasonably discoverable at an earlier time; 
  • the Respondent has continued or renewed conduct allegedly constituting Research Misconduct that occurred before the six-year limitation; or 
  • the Research Misconduct poses a current threat to the health and safety of patients, animals, and/or employees.

Acronyms and Definitions

• Ad Hoc Committee of Investigation - Senior faculty members who the RIO, Dean and Deciding Official appoint to examine and evaluate relevant facts and determine whether Research Misconduct has been committed and, if so, by whom. 
• Allegation - Any written or oral statement or other communication of possible Research Misconduct made to a Graduate School or St. Jude Official. The four phases of responding to an Allegation are initial assessment, Inquiry, Investigation, and resolution.
• Complainant - An individual who makes an Allegation of Research Misconduct.
• Deciding Official – The individual at St. Jude who makes final determinations on Research Misconduct proceedings and any responsive St. Jude actions. The Deciding Official at St. Jude is the President and CEO. He/she works with the Dean to coordinate actions and responses.
• Good Faith Allegation - A claim of wrongdoing made with the honest belief that Research Misconduct may have occurred. An Allegation is not in good faith if it is groundless or made with knowing or reckless disregard for information that would negate the claim.
• IACUC - Institutional Animal Care and Use Committee.
• Inquiry - Preliminary information-gathering and initial fact-finding by the RIO and Legal Services in compliance with 42 CFR 93.307-309 to determine whether an Allegation or apparent instance of Research Misconduct warrants an Investigation.
• Institutional Member(s) - A person who is employed by, is an agent of, or is affiliated by contract or agreement with an institution. Here, the institution is the Graduate School, and Institutional Members may include, but are not limited to, graduate students, instructors, faculty mentors, research mentors and staff.
• IRB - Institutional Review Board.
• Investigation - Formal development of a factual record and the examination of that record leading to a decision not to make a finding of research misconduct, or to a recommendation for a finding of research misconduct, which may include a recommendation for other appropriate actions, including administrative actions. 
• ORI - The Office of Research Integrity within the U.S. Department of Health and Human Services that oversees and directs Public Health Service (PHS) research integrity activities on behalf of the Secretary of Health and Human Services and the American public.
• Research - A systematic experiment or study to determine the safety and effectiveness of medications, devices, diagnostic products, and treatment regimens intended for human use (clinical research), or to contribute to general and specific scientific knowledge (basic and applied research) relating broadly to public health. Involves discovering, developing and characterizing the underlying biological mechanism of diseases and their treatments. 
• Research Integrity Officer (“RIO”) - The individual at St. Jude who is responsible for working with the Office of Legal Services (“Legal Services”) to assess Allegations, determine when Allegations warrant an Inquiry, and if there is sufficient evidence of potential Research Misconduct to warrant an Investigation. The RIO oversees Inquiries and Investigations. The Deciding Official appoints the RIO for St. Jude.
• Research Misconduct - is defined by the ORI regulations as fabrication, falsification, or plagiarism in proposing, performing, or reviewing research, or in reporting research results. Research misconduct does not include honest error or differences of opinion. 
  • Fabrication is making up data or results, and recording or reporting them;
  • Falsification is manipulating research materials, equipment, or processes, or changing or omitting data or results such that the research is not accurately represented in the research record; and
  • Plagiarism is the appropriation of another person’s ideas, processes, results, or words without receiving permission and not giving appropriate credit to the creator.
• Respondent - The person(s) against whom an Allegation of Research Misconduct is directed or the person(s) whose actions are the subject of an Inquiry or Investigation. 
• Retaliation - An adverse action taken against a Complainant, witness, or Committee member by St. Jude or one of its employees in response to a Good Faith Allegation of Research Misconduct, or good faith cooperation with a Research Misconduct proceeding.
• St. Jude Official – A St. Jude member with the authority to respond to Allegations of Research Misconduct. Such officials include the President and CEO, Research Integrity Officer, members of Legal Services, and Compliance Office (“Compliance”).

Policy

Research Misconduct issues involving the Graduate School will be investigated by St. Jude officials in consultation with the SVP/COO and Dean. The Research Integrity Officer (RIO) at St. Jude is responsible for assessing Research Misconduct Allegations, determining when Allegations warrant Inquiries, recommending Investigations or administrative actions based on inquiry conclusions, and overseeing Inquiries and Investigations. The Deciding Official appoints the RIO for St. Jude. The RIO works with the SVP/COO, Dean, Legal Services, Compliance, and Human Resources to implement the institution’s Research Misconduct policies and procedures.

Procedure

The procedures and conditions of Research Misconduct proceedings at St. Jude are fully described in policy 70.05.001.

• Reporting Misconduct Allegation
  • When reporting a misconduct allegation, the reporting individual should provide the following: complainant’s name and contact information, a clear description of the problem or complaint, appropriate supporting documentation that is directly related to the complaint, a description of any subsequent actions taken by the complainant or the institution, and a description of the desired outcome.
  • If an individual is unsure whether a suspected incident falls within the definition of Research Misconduct, he or she may confidentially and informally consult the RIO about the suspected misconduct. The RIO will accept any Allegation, discuss the circumstances with the SVP/COO, Dean and Legal Services, and respond to the individual;
  • An individual who is not comfortable bringing his or her concerns to the RIO may direct those concerns to any St. Jude or Graduate School Administrator, who is then required to forward the Allegation to the RIO and SVP/COO; and
  • Institutional Members shall report suspected Research Misconduct to a St. Jude Official or SVP/COO. When an Official or the SVP/COO receives an Allegation, he or she shall notify the RIO immediately. The RIO shall notify Legal Services, and Compliance if the Allegation requires investigation by or input from Compliance.
• Research Misconduct Initial Review and Inquiry 
  • A respondent has a right to a thorough, competent, objective, and fair response to Allegations of Research Misconduct;
  • Complainant, respondent, and witness(es) interviews shall take place privately and may be recorded;
  • If after the initial review of the alleged facts, or after the Inquiry, the RIO, SVP/COO, and Legal Services determine that circumstances described do not meet the definition of Research Misconduct, the RIO will refer the individual or concern to other offices or officials with the responsibility for resolving the concern. If an Allegation is not made in good faith, the RIO, SVP/COO, and Legal Services will work with the Complainant’s advisor, HR, and other departments as appropriate to determine if disciplinary action should be implemented; 
  • If after the initial review of the alleged facts, the RIO, SVP/COO, and Legal Services determine that the Allegation is sufficiently credible and specific and an Inquiry is warranted, the RIO shall notify the Respondent in writing immediately. If the Inquiry results in facts that require further scrutiny, the RIO will recommend to the Dean and Deciding Official that an Investigation should be conducted;
  • An Inquiry shall be completed within 55 calendar days of the initial Allegation, unless circumstances warrant a longer period;
  • The RIO will take custody of the research records, review the evidence, and prepare and submit an Inquiry Report to the Respondent, Dean, and Deciding Official. The Respondent will have five (5) calendar days to review the report and submit a response to the RIO; and
  • After reviewing the Inquiry Report and Response, the Dean and Deciding Official will determine within 30 calendar days of receiving the Report whether the evidence warrants an Investigation, even if the Complainant does not wish to pursue the Allegation.
• Ad hoc Committee of Investigation
  • The RIO, Dean, and Deciding Official appoint the Committee. The Committee consists of senior St. Jude faculty members with appropriate scientific expertise, and who do not have unresolved personal, professional, or financial conflicts of interest with those involved with the Inquiry or Investigation (RIO, Complainant, Respondent, witnesses);
  • The Deciding Official appoints the Committee Chair, who is responsible for maintaining a detailed record of the Committee’s actions;
  • During the Investigation, St. Jude will take necessary action to protect public health and safety, federal funds, the research integrity process, and reputations; and
  • Upon conclusion of the Investigation, the Committee will write its findings in an Investigation Report, which is provided to the Dean, Deciding Officer and Respondent. The Respondent may write a rebuttal within 30 calendar days of receiving the Committee’s Report for the Committee to consider. The Committee may modify its findings in an Addendum to the Report based on new facts provided in the Respondent’s Response. The Committee may recommend administrative actions to the Dean and Deciding Official. The Report, Response, and Addendum, and recommended administrative actions are provided to the Dean and Deciding Official for final determination, and to ORI according to federal regulations.
  • Duty to Cooperate with Research Misconduct Proceedings. Institutional Members are required to participate in Research Misconduct proceedings and shall provide relevant evidence of the Allegations to the RIO and Legal Services. If an Institutional Member refuses to cooperate according to this policy and its related procedures, the Dean and Deciding Official may impose disciplinary actions, up to and including termination from the Graduate School and/or employment at St. Jude.
• Protection of the Complainant, Respondent, and Others
  • Disclosure of the identity of Respondents, Complainants, and records or evidence from which research subjects might be identified in Research Misconduct proceedings is limited, to the extent possible, to those who need to know, consistent with a thorough, competent, objective, and fair Research Misconduct proceeding, and as allowed by law. Provided, however, that St. Jude must disclose the identity of Respondents and Complainants to ORI. The rights and reputation of Respondents, Complainants, and research subjects identifiable from research records or evidence, and all other parties involved in Research Misconduct proceedings shall be protected throughout the proceedings, to the extent possible without compromising public health and safety. Legal Services will work with the RIO and institutional leadership during an Inquiry and an Investigation to determine how best to share information and findings with necessary agencies and parties; 
  • St. Jude prohibits retaliation for making an Allegation. In accordance with institutional policy 70.01.006 “Non-retaliation for Reporting Suspected Non-Compliance,” no one shall suffer Retaliation for making an Allegation in good faith or for providing evidence or testimony during Research Misconduct Proceedings. The RIO and Legal Services will verify that an Allegation is made in good faith;
  • Respondent has a right to an Advisor. At Respondent’s request and faculty’s consent, a St. Jude faculty member in good standing and with no conflicts of interest in the matter may act as an advisor to a Respondent, and with notice to the RIO and SVP/COO, may accompany the Respondent as an observer of interviews or meetings where the Respondent’s presence is requested or required;
  • If at any time during a Research Misconduct Proceeding, information is obtained that reasonably indicates that criminal violations may have occurred, the RIO must notify Legal Services within 24 hours. Legal Services will assess alleged criminal or civil violations on a case-by-case basis to ascertain relevant facts and determine the best course(s) of action. If the violations are likely to have occurred, Legal Services and the RIO will notify ORI, and any other appropriate parties (such as a funding agency or law enforcement), as appropriate; and
  • Resolution of an Investigation by the Dean and Deciding Official may include a finding that administrative action is necessary and a retaliation prevention plan for Committee members, witnesses, and Complainant(s) is needed. If no Research Misconduct is found, a plan to restore the Respondent’s reputation shall be developed.
• Administrative and/or Disciplinary Actions for Findings of Research Misconduct
  o If the Dean and the Deciding Official determine that the alleged Research Misconduct is substantiated, they will decide on the appropriate administrative or disciplinary actions to be taken with the Respondent, up to and including termination from the Graduate School and/or employment at St. Jude. The RIO will notify and make reports of those actions, and any documentation needed to restore the scientific record, to ORI and other parties and agencies as required; and
  • If the Dean and the Deciding Official determine that an Allegation was not made in good faith, they will decide on the appropriate administrative or disciplinary actions to be taken with the Complainant, up to and including termination from the Graduate School and/or employment at St. Jude.
• Record Retention
  • Regardless of the outcome, after completion of a Research Misconduct Investigation and related actions, the RIO and Legal Services will prepare a complete file, including the records of the Inquiry and Investigation and copies of all transcripts, documents, and other materials furnished to the RIO or the Committee (the “Records”), and will transfer the Records to the Office of Legal Services for retention;
  • The Records shall be retained in a secure manner for seven years; and
  • ORI and other authorized government personnel will be given access to the Records as required by law and in accordance with applicable St. Jude policies.

References

• 42 CFR Part 93 Public Health Services Policies on Research Misconduct
• HR Policy 600.020 - Progressive Disciplinary Process https://home.stjude.org/human-resources/Policies/600.020.pdf 
• Office of Legal Services intranet site: https://home.stjude.org/legal/
• Compliance Office intranet site: https://home.stjude.org/compliance

8.38 Related Policies

• Romantic or Sexual Relationships with Students or Trainees (15.10.50)
• Workplace Sexual Harassment (15.20.30)
• St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences Code of Conduct Non-discrimination policy 20.11.008
• St. Jude Children’s Research Hospital Non-Retaliation policy (70.01.006)
• St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences Code of Conduct (80.25.003)
• St. Jude Children’s Research Hospital Graduate School of Biomedical Sciences Student Code of Conduct

8.39 External References

Title IX of the Education Amendments of 1972, 20 U.S.C. §1681 et seq.

8.40 Forms And Other Documents

• Formal Complaint Form
• Title IX Coordinator Desk Reference
• Sexual Harassment Process Checklist
• Investigation Log
• Sexual Harassment Report Intake Form
• Acknowledgement of Report of Sexual Harassment (Complainant)
• Formal Complaint Declined Documentation Form
• Complainant Rights and Options
• Respondent Rights and Options
• Formal Complaint Form
• Notice of Formal Complaint and Investigation to Parties
• Notice of Dismissal Form-Complainant-Pre Investigation
• Notice of Dismissal Form-Respondent-Pre Investigation
• Support Person, Advisor, and Affirmation Form
• Complainant Interview Form
• Respondent Interview Form
• Investigation Witness List
• Witness Interview Form
• Evidence Tracking Form
• Access to Evidence Form
• Investigation Report
• Notice of hearing (Parties)
• TIX Hearing Procedures
• Written Decision Template
• Notice of Appeal Being Filed
• Notice of Appeal Decision
• Agreement to Participate in Informal Resolution
• Informal Resolution Agreement
• Notice of Dismissal Form During Investigation or Adjudication
• Notice of Dismissal of Formal Complaint During Investigation or Adjudication
• Title IX Incident Tracking Template
• Prevention and Awareness Program Tracking Template

80.94.001: Responsible Conduct of Research Training

Responsible Conduct of Research (RCR) is vital to conducting science in a rigorous manner. The St. Jude Graduate School of Biomedical Sciences provides appropriate RCR training for its enrolled students. Each degree program in the St. Jude Graduate School of Biomedical Sciences has specific RCR training requirements for enrolled students.

PhD in Biomedical Sciences

The PhD in Biomedical Sciences program follows the National Institutes of Health’s RCR mandate for scientific trainees. All students enrolled in the PhD in Biomedical Sciences program must complete at least eight (8) hours of RCR training every 4 years. Qualifying RCR training is administered by the Academic Programs Office (APO) in St. Jude Children’s Research Hospital. APO will record attendance for all RCR sessions and forward attendance rosters to the Assistant Dean. The Assistant Dean will notify the Registrar when students have completed their RCR training requirements. The Registrar will note RCR training completion on the student’s official transcript. Completion of RCR training is a mandatory entry on the student transcript.

MSc in Clinical Investigations

Students enrolled in the MSc CI program who are concurrently postdoctoral trainees or otherwise subject to an RCR training mandate separate from their status as a MSc CI student will be responsible for fulfilling RCR training requirements outside of the Graduate School. A student who receives federal funding subject to RCR training mandates will be responsible for fulling that RCR training requirement outside of the Graduate School.

MSc in Global Child Health

Students enrolled in the MSc in Global Child Health program will fulfill the Graduate School’s RCR training requirements by the successful completion of the “Research Methods in Global Health” course.

80.94.002: Collaborative Institutional Training Initiative (CITI)

Students must complete the Collaborative Institutional Training Initiative (CITI) online courses on the protection of human participants and RCR before they can conduct research, see patients or review patient data.
Students must complete CITI RCR Training Program in Biomedical or Social & Behavioral Research, which provides a detailed overview of 10 core areas involved in RCR, within the first four months of the program.

80.95.001: Intellectual Property

The Graduate School follows St. Jude policy 10.04.013 without exception.

80.95.002: Copyright

The Graduate School follows St. Jude policy 70.05.002 without exception.

References

• St. Jude Policy 10.06.005, Purchase Requisition and Purchase Order Policy
• St. Jude Policy 10.08.001, Research Grants & Contracts
• St. Jude Policy 10.06.022, Consultants
• St. Jude Policy 15.10.075, Classification and Tracking Individuals Not on St. Jude Payroll
• St. Jude Policy 10.06.023, Vendor Credentialing

80.97.001: Enterprise Risk Management

Derived from St. Jude policy 10.04.006 (Owner, LaKeisha Sisco-Beck)

Purpose and Scope

• The Graduate School students and employees are responsible for the effective management of risk by notifying the SVP/COO of likely or significant risks, so that those risks may be incorporated into ongoing risk analyses. A risk is formally defined as an event or trend, either positive or negative, which could have a significant adverse impact on operations and/or the fulfillment of the Graduate School strategic objectives if the threat or trend materialized. Enterprise Risk Management (ERM) is conducted independently by the Graduate School and by St. Jude, but efforts and analyses are closely coordinated. ERM involves the identification, prioritization, and mitigation of the most likely and most devastating threats that could impact key assets of both institutions.

Teams and Programs

• Graduate School Enterprise Risk Management Team (GSERMT): Team within the Graduate School developed to manage the Graduate School’s Enterprise Risk Management Program (GSERMP). It identifies and mitigates organizational risks in a systematic manner so that its mission is not jeopardized;
• St. Jude Enterprise Risk Management Team (SJERMT): Team within the OLS developed to manage the St. Jude Enterprise Risk Management Program (SJERMP). It identifies and mitigates organizational risks in a systematic manner so that its mission is not jeopardized;
• GSERMP: Guides the identification and mitigation of organizational risks and brings a systematic approach to evaluating and improving the effectiveness of risk management and control; and
• SJERMP: Guides the identification and mitigation of organizational risks and brings a systematic approach to evaluating and improving the effectiveness of risk management and control.

Roles of the SJERMT

The SJERMT, with input from the GSERMT is responsible for providing information about the following:

• Assets;
• Threats to assets;
• Scores showing the probability of the threats materializing (1 = very remote, 5 = likely);
• Impact scores if the threat occurred (1 = minimal, 25 = catastrophic);
• A standardized list of assets and threats based on previous years’ assessments;
• Arranging threats and assets to eliminate redundancies, consolidate categories, and removing risks no longer present;
• Arranging probability and impact scores; and
• Proposing mitigation strategies and identifying responsible parties.

Ongoing Monitoring and Reporting

• At least once a quarter, the GSERMT and SJERMT will review the Graduate School’s approach to risk management and approve changes or improvements to key elements of the GSERMP based on significant external or internal events;
• At least once a year, the Dean will share the results of the GSERMP with the Graduate School Board of Trustees for discussion and input and the St. Jude President and CEO will share the results of the SJERMP with the St. Jude Executive Committee and Board for discussion and input;
• The GSERMT and SJERMT, will monitor significant risks to reduce the likelihood of a serious threat materializing;
• The GSERMT and SJERMT will oversee the accountability of each risk by ensuring appropriate ownership and informing the Dean of any potential updates; and
• The GSERMT and SJERMT will inform and support the Dean in making critical institutional decisions.

80.98.001: Alcohol Use

Derived from St. Jude policy 10.04.009 

Purpose and Scope

• The Graduate School prohibits the use of alcohol that is inconsistent with federal, state, local, or the Graduate School regulations. The Graduate School has established the following policy governing the possession, sale, serving, and consumption of alcoholic beverages at the Graduate School or at Graduate School events off site. It is the Graduate School’s goal to encourage members of its community to make responsible decisions and to promote safe and healthy patterns of social interaction.
• This policy applies to all Graduate School employees and students and all functions taking place on Graduate School property or at Graduate School events off site.

Policy

• Alcohol may not be used as an inducement to participate in a Graduate School event.
• Alcohol may be served only at special events and not routine meetings.
• Alcohol may not be served at a Graduate School event that requires an Authorization to Serve Alcohol Request Form unless the Dean or SVP/COO has signed an Authorization to Serve Alcohol Request Form located at the  Catering Website (one permit per function).
• The event’s sponsor and individuals serving the alcohol are responsible for compliance with applicable laws, ordinances, and Graduate School policies pertaining to the possession, sale, serving, and consumption of alcohol.
• The consumption of alcohol on Graduate School property is limited to the Graduate School, Danny Thomas/ALSAC Pavilion, and the Global Education and Collaboration Center (GECC).
• Events in which alcohol is served may not take place in any area where patients are located or immediately adjacent to any area where patients are located.
• Under no circumstances may an alcoholic beverage be permitted to leave the approved area of the event.
• An individual may not bring an alcoholic beverage into the event.
• With the exception of dinners or parties at local restaurants and private homes, Graduate School offsite catered events require a contract with the venue and the caterer that has been reviewed by the OLS.
• Food and non-alcoholic beverages must be made available at all Graduate School events where alcohol is served.
• Alcoholic beverages will not be sold on Graduate School property. Alcoholic beverages will be served free of charge at events taking place on Graduate School property or at Graduate School events off site.
• Individuals under the age of 21 are not permitted to possess, serve, or consume any alcoholic beverage at a Graduate School event.
• A Graduate School employee who drinks alcohol at a Graduate School event may not return to work impaired (Policy 15.20.035: Drug Free Workplace).
• Violations of the law or Graduate School policies relating to alcohol use will result in disciplinary action up to and including termination of employment.
• Graduate School policies are consistent with the laws of the state of Tennessee as stated in the Tennessee Code Annotated, and the laws of the City of Memphis, as stated in the Memphis Code of Ordinances.

Procedure

• For events that require Authorization to Serve Alcohol, complete the Authorization to Serve Alcohol Request Form found on the Catering Website.
• After approvals are received and the form signed, submit the form to Catering. Please submit at least seven days in advance so that Catering may obtain a bartender for the event.

References

1. Memphis, Tenn., Municipal Code §§ 7-4-8(A), 7-8-6, 7-4-15(A), 7-8-4(A), 7-8-25
2. Tenn. Code Ann. §§ 57-4-203(a)(1)(A), 57-4-203(h), (h)(2)
3. St. Jude Policy 15.20.035: Drug Free Workplace

80.98.002: Service Animals

Derived from St. Jude policy 10.04.017 

Purpose and Scope

• The purpose of this policy is to meet the needs of Graduate School employees, students, companions, visitors, vendors, and contractors who require the assistance of a service animal, while ensuring that the Graduate School and St. Jude remain free from infection risks associated with the presence of animals.
• The Graduate School is committed to promoting full participation and equal access to programs and activities for individuals with disabilities, and to complying with the Americans with Disabilities Act Amendments Act of 2008 (ADAAA) and the Rehabilitation Act of 1973. Pursuant to these commitments, Service Animals (defined below) are permitted on campus for persons with disabilities in accordance with the requirements of this policy, and so long as they meet the guidelines set forth in this policy. Requests for exceptions to this policy will be considered on a case-by-case basis and in accordance with applicable laws regarding reasonable accommodations.
• This policy applies to employees and students of the Graduate School and visitors, vendors, and contractors who are on the Graduate School campus.

Definitions

• ADA/Workplace Accommodation Committee - A designated group that determines whether the essential functions of the job can be accomplished with or without reasonable accommodation, and what that accommodation will be, after engaging in an interactive process with the employee.
• Handler - A person with a disability using a service dog is called a handler. A handler and his/her service dog are called a Team. The two work as a cohesive unit in accomplishing the tasks of everyday living. A handler also may be the person who temporarily is responsible for the service dog.
• St Jude Graduate School Campus – St Jude Graduate School campus includes the Graduate School facilities in the Marlo Thomas Center.
• St. Jude Campus - Unless otherwise restricted in this policy, St. Jude Campus includes the Hospital inpatient and outpatient waiting and treatment rooms, common areas (Kay Kafe, hallways, gift shops), offices, meeting rooms, auditoriums, lecture halls, grounds, shuttles, Tri-Delta House, Target House, and sponsored housing (Harbor Island and Crosstown).

General Policies

• The ADAAA defines a Service Animal as a dog that is trained to perform specific tasks for a disabled person. The ADAAA does not mandate that service dogs be specifically identified with certification papers, a harness, special collar, or any other form of identification. However, service dogs on the campus will have their photograph taken for a badge to designate that the dog has been screened and cleared to be on the hospital grounds. The work or tasks performed by a service dog must be directly related to the individual’s disability.
• Dogs that are service animals are working dogs, not pets, and perform tasks for disabled individuals including, but not limited to:
  • Assisting sight-impaired individuals with navigation;
  • Pulling a wheelchair;
  • Alerting a handler to the presence of a life-threatening allergen;
  • Providing stabilizing support, and retrieving medications or other items for individuals with mobility limitations;
  • Alerting hearing-impaired individuals to specific sounds;
  • Alerting a diabetic of blood sugar imbalance;
  • Alerting an individual before the onset of a seizure; and
  • Preventing or interrupting impulsive or destructive behaviors by individuals with psychiatric disabilities.
• Dogs that are not trained to perform tasks that mitigate the effects of a disability, including dogs that are used for emotional support, therapy, or comfort, are not service animals under the ADAAA. Such dogs might not be properly trained for the Graduate School environment and could pose a health, welfare, or safety risk. In determining whether to permit a non-service dog on campus, the Graduate School will consider the type, size, and weight of the dog, whether it is housebroken, is under its handler's control, and whether its presence would compromise health or safety requirements. Employee and student requests for emotional support animals in the Graduate School and or the Hospital as a reasonable accommodation under the ADA will be handled in accordance with St. Jude Policy 15.10.065.
• Avian species, amphibians, reptiles, rodents, rabbits, felines, swine, and nonhuman primates are not service animals under the ADAAA and are strictly prohibited on the Graduate School and St. Jude campus because of the associated risks of transmittable diseases.
• Service dogs must be healthy and well-groomed, without fever, gastroenteritis, fleas, ticks, or skin lesions, have a negative O & P (parasite) exam, and be on heartworm and flea and tick prevention regimens. Vaccinations must be current according to vaccination requirements in the Memphis area (rabies, bordetella, DHLPPv, canine distemper, hepatitis - CAV-1, leptospirosis, parainfluenza, Adenovirus-cAVO-2, and parvovirus).
• A service dog is permitted in areas of the Graduate School and St. Jude campus that are accessible to the individual with the disability, if the dog is under the supervision and control of the handler and provided that safety precautions are observed. Admittance of a service dog is strictly prohibited in classrooms, other teaching areas and research laboratories, clean rooms, sterile areas, areas storing clean or sterile supplies or linen, procedure and perioperative areas, areas where personal protective equipment (PPE) is required, the St. Jude Animal Resources Center, mechanical rooms, custodial closets, areas where there is a danger to the service dog, food preparation areas, areas where the service dog could constitute a danger to persons or other animals, and areas where the presence of a service dog would cause or require a fundamental alteration of a Graduate School or St. Jude program or activity. For health and safety reasons, service dogs are not allowed on the furniture in any Graduate School or St. Jude facility.
• A service dog must be harnessed, leashed, tethered, or crated at all times while at the Graduate School and general public areas unless these devices interfere with the service dog’s work, or the individual’s disability prevents using these devices. In that case, the handler must maintain control of the dog through voice, signal, or other effective controls.
• A service dog will be removed from the Graduate School and St. Jude campus at the Graduate School and St. Jude’s complete discretion, if the dog poses a direct threat to the health or safety of others or fails to remain under its handler’s control.
• Any member of the Graduate School can formally object to the presence of a service dog if they feel threatened or have health concerns including allergies. Any such objections must be referred to the SVP/COO for further consideration.

Procedures

• Accommodation of Requests - General
  • The Nursing Coordinator and Security Coordinator or designee should be called to respond to initial requests to bring a service dog by a student, staff member, visitor, companion, vendor or contractor, and for any animals on the Graduate School and St. Jude campus whose status is unknown.
  • The Security Coordinator or designee and Nursing Coordinator will complete the Service Animal Evaluation form and ask the following questions:

i. Is the dog’s presence required because of a disability?
ii. What work or tasks is the dog trained to perform?

A. Once identified as a service dog, the Security Coordinator or designee will confirm with the handler that the dog is house broken.
B. If the dog is not house broken, the Security Coordinator or designee will advise the handler that for health and safety reasons institutional policy does not permit dogs who are not house broken on Graduate School or St. Jude campus or in the St Jude Graduate School or St. Jude housing.
C. If the dog appears ill or unclean, will be staying in St Jude Graduate School housing, or will be on the St Jude Graduate School or St. Jude’s campus for an extended period, the Nursing Coordinator and Security Coordinator or designee may request the handler to provide veterinary records verifying the dog’s health.
D. If veterinary records are provided, the Security Coordinator or designee will review the records for completeness and scan the records into Milli under the legal tab. The Security Coordinator or designee will also send a summary email to the Service Animal distribution list, the SVP/COO and the Graduate School Coordinator.
E. If veterinary records are not available, the Security Coordinator or designee will advise the handler that for health and safety reasons, including those of the dog, institutional policy requires that all vaccination records be up-to-date and completed at the handler’s expense. The Security Coordinator or designee will require that records be brought in prior to allowing the dog access to the Graduate School and St. Jude campuses or housing and will provide the handler with a list of local veterinarians and boarding kennels, if needed.
F. The Security Coordinator will scan the Service Animal Evaluation form into Milli under the legal tab for all patients and caregivers.
G. If the service dog belongs to a student or staff member, the Security Coordinator or designee will issue a St. Jude badge for the service dog to wear at all times while on the St Jude Graduate School and St. Jude campuses and in the St. Jude Graduate School or St. Jude housing. This badge ensures staff that the dog has been identified as a service dog and decreases the chances of the owner being approached about clearance repeatedly.
H. If the service dog belongs to someone other than a student or staff member, the Security Coordinator or designee will issue a temporary, 24-hour St. Jude visitor service dog badge for the dog to wear while on the St Jude Graduate School and St. Jude campuses.
I. All handlers will be provided with the educational handout, ‘Service Animals on the St Jude Graduate School and St. Jude Campuses’. The handout is also available on the Graduate School website
J. When a student or staff member needs to access an area from which service dogs are restricted or must be removed, an alternate room will be made available for the service dog and handler.
K. Due to strict infection control guidelines, additional requirements are needed for service dogs to be outside the outpatient setting. These requests will be evaluated individually and may not be allowed if it is determined the presence of the dog may compromise patient health or safety in any way.

• Accommodation of Requests Made by Students and Staff members

A. A Graduate School student or staff member who requires a service dog or requests the use of an emotional support animal should contact Occupational Health to request the appropriate forms. The forms are to be completed by the student or staff member’s physician and any trainer and returned to Occupational Health. Occupational Health will submit the completed forms to the ADA/Workplace Accommodation Committee for reasonable accommodation review, according to St Jude Policy 200.150.
B. If the ADA/Workplace Accommodation Committee determines that the animal will be permitted on campus as a reasonable accommodation, the owner is required to provide a copy of the dog’s veterinary records. Once that process is successfully completed, the handler will be referred to Security for the appropriate badge, and provided with the educational handout, Service Animals on St. Jude Graduate School and St Jude campuses.
C. If a person in the student’s or staff member’s work area has an allergy to or is fearful of the dog, the person should contact either Employee Relations or Occupational Health. The ADA/Workplace Accommodation Committee will consider the needs of both individuals in seeking an efficient resolution.

• Guidelines for All Service Dog Handlers

A. Upon arrival at the Graduate School and St. Jude, a person with a service dog will be provided with the educational handout, Service Animals on the St Jude Graduate School and St. Jude Campuses.
B. At all times the care and supervision of the service dog is the responsibility of the dog‘s handler. Arrangements with friends or family to care for the dog are the responsibility of its handler. Graduate School and Hospital staff are not responsible for the care of a service dog and are not allowed to supervise, walk, water, feed, or clean up after a service dog at any time.
C. Service dogs must be house broken, and elimination must occur outside a St. Jude building along the perimeter fencing or in an unobtrusive area. The handler must pick up, and if necessary, clean up after the dog and dispose of waste in trash receptacles outside of St. Jude buildings.
D. If a service dog has an elimination accident (urine, feces, or vomit) inside a Graduate School or St. Jude building, the handler must remove the elimination immediately and clean the area using protective gloves and a St. Jude-approved disinfectant. Environmental Services will be contacted for access to an approved disinfectant. Environmental Services is not responsible for cleaning but is responsible for ensuring the cleaning was properly conducted. All materials used in the cleaning process must be disposed of properly per Environmental Services' Standard Operating Procedure (SOP).
E. If the service dog is suspected of posing a direct threat to the health or safety of others, or fails to remain under its handler’s control, Occupational Health should be contacted to complete an Individualized Service Animal Assessment form. This assessment is presented to the Graduate School and St. Jude Administration to determine within 24 hours whether the service dog will be allowed to remain on the Graduate School or St. Jude Campus.

References

1.  Federal Regulations:
   • 28 C.F.R. § 36.104; 28 C.F.R. § 36.302 (c)(2); and 28 C.F.R. § 36.302 (5)
2. Tennessee Statute: T.C.A. § 39-14-216
3. FACT SHEET – Highlights of the Final Rule to Amend the Department of Justice’s Regulation Implementing Title II of the ADA Sarah Price, Esq., Service Animals Under the ADA, 5, September 2006
4. ADA 2010 Revised Requirements: Service Animals
5. St. Jude Policy 15.10.065- Americans with Disabilities Act
6. CDC’s Guidelines for Environmental Infection Control in Health-Care Facilities (https://www.cdc.gov/infectioncontrol/pdf/guidelines/environmental-guidelines-P.pdf)

Forms and Handouts

1. Service Animal on St. Jude Campus
2. Service Animal Evaluation Form
3. Individual Service Animal Assessment Tool
4. Service Animals on the St Jude Graduate School and St. Jude Campuses

Accommodation Policy

Embedded in the core values of the St Jude Children’s Research Hospital Graduate School of Biomedical Sciences (“Graduate School”) is a commitment to ensure equal access to a quality higher education experience for a diverse student population. The Graduate School recognizes disability as an aspect of diversity that is integral to society and the Graduate School community. The Graduate School serves as a partner in fostering an inclusive and equitable environment for all Graduate School students.

The Graduate School is committed to providing equal access to educational opportunities for qualified students with disabilities or disabling condition, in accordance with state and Federal laws. To ensure equality of access for students with disabilities or disabling condition, reasonable accommodations, including auxiliary aids and services, are provided case-by-case through an interactive process with the Graduate School ADA Coordinator (“ADA Coordinator”). As a student with a disability receiving accommodation, it is important to know your rights and responsibilities outlined below.

Graduate Students Have the Right to:

1. Equal access to Graduate School courses, programs, services, activities and facilities with or without an accommodation. 
2. Reasonable accommodations, as determined on a case-by-case basis through an interactive process between the student and the ADA Coordinator. 
3. Appropriate privacy and confidentiality of all records regarding their disability and, except as permitted by law, the choice of whether to disclose information related to their disability or disabling condition to course leader(s), lecturer(s), or anyone else. 

Graduate Student Responsibilities:

1. Notify the ADA Coordinator, in a timely manner, as needing an accommodation related to your disability or disabling condition and complete the Americans with Disabilities Act Student Accommodation Form.   
2. Submit appropriate documentation from a qualified professional, prior to receiving accommodation, verifying the current nature of the disability, the current functional limitations resulting from the disability, the justification for the specific requested accommodation, as well as completion of the Americans with Disabilities Act Medical Accommodation Request Form by a qualified professional.  Student also is responsible for submitting any subsequent or additional information necessary to assess eligibility and/or continuation of accommodations and services.   
3. Submit an Accommodations Notification Letter in a timely manner to the desired course lecturer(s) or lecturers. Should a student feel uncomfortable having this discussion with a particular lecturer, the student should contact the ADA Coordinator to request assistance.
4. Meet with the desired course leader(s) or lecturer(s) to discuss accommodations in their courses.
5. Requests submitted without reasonable advance notice for each requested auxiliary aid and/or academic adjustment may result in delay and/or inability to coordinate and/or implement the service requested.  Contact the ADA Coordinator immediately regarding   any issues, concerns, disputes, or delays in receiving approved accommodations, or if you believe you have been discriminated against.
6. Notify the ADA Coordinator immediately when discontinuing an accommodation (e.g., note taking, etc.) or dropping a course for which alternate format materials are required.
7. Meet the same academic, technical, performance and behavioral standards expected of all Graduate School students.

Graduate School’s Rights and Responsibilities

            Student understands that the Graduate School has the right and responsibility to:

1. Act in accordance with the Graduate School’s academic standards.
2. Request current, comprehensive documentation to verify a student's need for reasonable accommodations in the higher education setting.
3. Discuss a student’s need for reasonable accommodations with the professional source of their documentation (with the student’s signed consent authorizing such discussion).
4. Discuss the nature of course, curriculum, program or degree requirements with Graduate School’s personnel responsible for the particular course, curriculum, program or degree.
5. Coordinate with faculty and staff to ensure recommended accommodations are reasonable on a case-by-case basis in each particular situation and if so, that such accommodations are subsequently implemented.
6. Share information regarding a student’s disability adjustments and/or modifications with Graduate School faculty and/or administrative staff on a need-to-know basis, in order to facilitate the interactive process and assess reasonable accommodations.
7. Designate a student's adjustments from a range of reasonable accommodations including, equally effective alternatives.
8. Periodically review recommended reasonable accommodations to ensure their continued necessity and/or reasonableness in a particular program, course of study, classroom setting or environment, and access to other Graduate School programs, services, or benefits.
9. Deny a request for services and/or specific accommodation if:
   • The requested accommodation is found to pose a direct threat to the health and safety of the student or others,
   • The requested accommodation fundamentally alters a course or program,
   • The requested accommodation is found to be an undue burden.
   • The request is not communicated directly by the student,
   • There is no identifiable relationship between the requested adjustment and the limitations of the disability,
   • The necessary information required as part of the interactive process is inadequate and/or not provided in a timely manner, or
   • If an equally effective accommodation is identified as a reasonable alternative to the requested accommodation.

Procedures

1. To request an accommodation under this policy, students must notify the ADA Coordinator.  The student must then complete the Americans with Disabilities Act Student Accommodation Form and have a qualified professional complete the Americans with Disabilities Act Medical Accommodation Request Form and submit any necessary documentation and/or information.   Information and documentation of the disability should be timely and from appropriate professionals licensed to diagnose the type of disability the student has. Medical documentation will be retained by the ADA Coordinator and will be kept private and confidential.
2. Requests for accommodations should be made far enough in advance to allow staff adequate time to received and review the necessary information and documents, as well as to coordinate needed services. Generally, it is best to request needed services before a semester begins or as soon as a disability becomes known.
3. After submission of the necessary information and documentation, the  ADA Coordinator and the Graduate School ADA Committee will review the information  and documents submitted, request any additional information and documents needed to evaluate the accommodation request, and meet with student and/or the student’s qualified professional to discuss the requested accommodation.
4. Once a student has been approved for, the student will receive a Student Eligibility Letter for their records that encompasses the options and an Accommodation Notification Letter that the student can provide to individuals of their choice.
5. Once faculty have been notified, they will work to find proper means to meet the accommodation. In some circumstances, requested accommodations may not be reasonable in specific courses. If this arises, the ADA Coordinator will engage with faculty and determine what is reasonable. In cases where, based on the nature of the course, a requested accommodation is not reasonable or otherwise unable to be provided for a lawful reason the coordinator may explore alternatives if an access barrier is still present.
   • Students are expected to discuss with their desired course leader(s) and lecturer(s) the need for accommodations in their respective course. Faculty members are expected to discuss such matters privately and maintain confidentiality except to only those who need to know.
   • Students are responsible for notifying the ADA Coordinator if approved accommodations are not being provided in an effective and timely way, if the provided accommodation is not sufficient, or if the student wishes to request additional accommodations. If an accommodation is not implemented in a test-taking or similar situation, the student should address that with the course leader(s)or proctor immediately.  If the information provided is found to be true, the amount of time should be added back to the test time such that the student is not disadvantaged.

F.   Requesting Additional Accommodations

Accommodations are approved initially based on the needs and access barriers the student is encountering at that time. However, needs and barriers can change and/or evolve as a student progresses through an academic program. If a student encounters new barriers, emergent needs, or seeks to modify a current accommodation, the student can request additional accommodations by notifying the ADA Coordinator and completing a new  Americans with Disabilities Act Student Accommodation Form and Americans with Disabilities Act Medical Accommodation Request Form, after which the ADA Coordinator will review and reengage in the interactive process.