Conflict of Interest: Difference between revisions

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Policy No.:  '''8010'''<br />
Policy No.:  '''8010'''<br />
Effective Date:  '''09/04/07'''<br />
Effective Date:  '''09/04/07'''<br />
Revised Date:  '''07/13/19 '''<br />
Revised Date:  '''12/05/19 '''<br />
Reviewed Date:  '''08/23/18'''
Reviewed Date:  '''08/23/18'''
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#the subrecipient shall report identified FCOIs for its Investigators in a timely manner so UNMC can report identified FCOIs to the PHS in the time frames in '''Report FCOI to PHS''' and '''Conduct retrospective review''' above.
#the subrecipient shall report identified FCOIs for its Investigators in a timely manner so UNMC can report identified FCOIs to the PHS in the time frames in '''Report FCOI to PHS''' and '''Conduct retrospective review''' above.


===Assistant Vice Chancellor, Business and Finance===
===Vice Chancellor for Business, Finance and Business Development===
The Assistant Vice Chancellor for Business and Finance shall manage business conflict of interest by reviewing all Annual Disclosure of Financial Interest questionnaires completed by Covered Persons with contract signature authority under Executive Memorandum 13 and 14; Covered Persons with purchasing authority; Covered Persons who identify family member(s) with a financial interest with the University of Nebraska; and any other potential business-related financial interest identified by the COI Officer through the annual COI disclosure process or by any other person at UNMC. Business COI management plans shall be created to minimize the appearance of bias in decision-making and ensure state and federal regulations and University of Nebraska business-related policies are followed. Business COI management plans shall be reported through the UNMC COI committee and reported on the Annual COI report to the Board of Regents Audit committee. <br />
The Vice Chancellor for Business, Finance and Business Development shall manage business conflict of interest by reviewing all Annual Disclosure of Financial Interest questionnaires completed by Covered Persons with contract signature authority under Executive Memorandum 13 and 14; Covered Persons with purchasing authority; Covered Persons who identify family member(s) with a financial interest with the University of Nebraska; and any other potential business-related financial interest identified by the COI Officer through the annual COI disclosure process or by any other person at UNMC. Business COI management plans shall be created to minimize the appearance of bias in decision-making and ensure state and federal regulations and University of Nebraska business-related policies are followed. Business COI management plans shall be reported through the UNMC COI committee and reported on the Annual COI report to the Board of Regents Audit committee. <br />


No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award or non-federal entity if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.
No employee, officer, or agent may participate in the selection, award, or administration of a contract supported by a Federal award or non-federal entity if he or she has a real or apparent conflict of interest. Such a conflict of interest would arise when the employee, officer, or agent, any member of his or her immediate family, his or her partner, or an organization which employs or is about to employ any of the parties indicated herein, has a financial or other interest in or a tangible personal benefit from a firm considered for a contract.

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