Lessons Learned
• Management should be realistic and understanding that risks can
and will exist
• Recognize that it is unreasonable to achieve perfect compliance -
the goal should be to minimize risk
• Institutions should make sincere efforts to achieve compliance
• Researchers need to be “on board” to help mitigate risk
• Institutions should constantly evaluate if their compliance efforts are
– A-133 and other high-level audits are often not sufficient