Conflict of Interest: Difference between revisions

Line 62: Line 62:
== Conflict of Interest Management Roles and Responsibilities ==
== Conflict of Interest Management Roles and Responsibilities ==
# '''COI Officer.''' The UNMC Conflict of Interest Officer shall be responsible for implementing the UNMC COI management program. <br />
# '''COI Officer.''' The UNMC Conflict of Interest Officer shall be responsible for implementing the UNMC COI management program. <br />
The COI management program shall also include review and approval of the "Application for Authorization to Engage in Outside Professional Activity" forms as delegated by the Chancellor with associated management of conflict of commitment under Regents Policy 3.8. and UNMC Policy 1049, "Outside Employment". The COI Officer shall:<br />
:The COI management program shall also include review and approval of the "Application for Authorization to Engage in Outside Professional Activity" forms as delegated by the Chancellor with associated management of conflict of commitment under Regents Policy 3.8. and UNMC Policy 1049, "Outside Employment". The COI Officer shall:<br />
## Ensure UNMC policy meets Board of Regents policy and state and federal regulatory requirements;
## Ensure UNMC policy meets Board of Regents policy and state and federal regulatory requirements;
## Implement annual disclosure requirements for Covered Persons and monitor to ensure compliance. The UNMC electronic Annual Disclosure of Financial Interest form is incorporated into this policy by reference. The Annual Disclosure of Interest and Application for Authorization to Engage in Outside Professional Activity forms are located at: http://net.unmc.edu/rss/  
## Implement annual disclosure requirements for Covered Persons and monitor to ensure compliance. The UNMC electronic Annual Disclosure of Financial Interest form is incorporated into this policy by reference. The Annual Disclosure of Interest and Application for Authorization to Engage in Outside Professional Activity forms are located at: http://net.unmc.edu/rss/  
Line 87: Line 87:
## '''Appeal Rights.''' Covered Persons may appeal adverse decisions made under this policy to the Vice Chancellor for Academic Affairs. The appeal <BR>shall be in writing and contain a description of the adverse decision, justification for why the decision should be changed, and the change <BR>desired. The appeal request shall be submitted to the COI Officer. The VCAA shall respond in writing to the Covered Person with his/her decision<BR>within thirty (30) days of receipt. The VCAA's decision is final.  
## '''Appeal Rights.''' Covered Persons may appeal adverse decisions made under this policy to the Vice Chancellor for Academic Affairs. The appeal <BR>shall be in writing and contain a description of the adverse decision, justification for why the decision should be changed, and the change <BR>desired. The appeal request shall be submitted to the COI Officer. The VCAA shall respond in writing to the Covered Person with his/her decision<BR>within thirty (30) days of receipt. The VCAA's decision is final.  
# '''COI Committee.'''
# '''COI Committee.'''
<p>The UNMC COI committee composition and operating procedures are contained in Appendix A. The COI Officer shall be a member of the COI committee and shall provide administrative support for the committee. The COI committee shall:</p>
:<p>The UNMC COI committee composition and operating procedures are contained in Appendix A. The COI Officer shall be a member of the COI committee and shall provide administrative support for the committee. The COI committee shall:</p>
## Provide oversight over the UNMC COI program, advise the COI officer, and provide guidance on UNMC COI policy matters.  
## Provide oversight over the UNMC COI program, advise the COI officer, and provide guidance on UNMC COI policy matters.  
## Review Significant Financial Interests. Review Disclosures of Financial Interest in the amount of $5,000 and above for research Investigators and determine if these Significant Financial Interests are related to the research, and, if so related, whether the Significant Financial Interest constitutes a Financial Conflict of Interest. A Significant Financial Interest is a Financial Conflict of Interest if it could directly and significantly affect the design, conduct , or reporting of research, including PHS-funded research. ## Create COI Management Plans for Financial Conflicts of Interest.
## Review Significant Financial Interests. Review Disclosures of Financial Interest in the amount of $5,000 and above for research Investigators and determine if these Significant Financial Interests are related to the research, and, if so related, whether the Significant Financial Interest constitutes a Financial Conflict of Interest. A Significant Financial Interest is a Financial Conflict of Interest if it could directly and significantly affect the design, conduct , or reporting of research, including PHS-funded research. ## Create COI Management Plans for Financial Conflicts of Interest.