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Conflict of Interest: Difference between revisions
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'''Subrecipients.''' Include provisions in PHS-funded subrecipient agreements that: | '''Subrecipients.''' Include provisions in PHS-funded subrecipient agreements that: | ||
#the subrecipient certifies that its FCOI policy complies with PHS regulations or in the alternative that the subrecipient will follow the UNMC COI policy; and | #the subrecipient certifies that its FCOI policy complies with PHS regulations or in the alternative that the subrecipient will follow the UNMC COI policy; and | ||
#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 ''' | #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. | ||
===Associate Vice Chancellor, Business and Finance=== | ===Associate Vice Chancellor, Business and Finance=== | ||
The Associate Vice Chancellor of 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. | The Associate Vice Chancellor of 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. | ||