Research Conflict of Interest Procedures: Difference between revisions

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# '''Grant Applications and Sponsored Programs Agreements.''' Covered Persons who are principal investigators on grant applications or who submit a sponsored program agreement shall submit a current Disclosure of Potential Conflict of Interest Form to Sponsored Programs Administration as a part of the application process. All other Responsible Persons (individuals who are responsible for the conduct, design, or reporting of the research, whether or not salaries are requested) shall submit a current Disclosure of Potential Conflict of Interest Form to Sponsored Programs Administration at the time the grant is awarded. Sponsored Programs Administration shall report the existence of a COI and the management plan to federal grant administering agencies when required by federal regulation or the terms of the research grant.  
# '''Grant Applications and Sponsored Programs Agreements.''' Covered Persons who are principal investigators on grant applications or who submit a sponsored program agreement shall submit a current Disclosure of Potential Conflict of Interest Form to Sponsored Programs Administration as a part of the application process. All other Responsible Persons (individuals who are responsible for the conduct, design, or reporting of the research, whether or not salaries are requested) shall submit a current Disclosure of Potential Conflict of Interest Form to Sponsored Programs Administration at the time the grant is awarded. Sponsored Programs Administration shall report the existence of a COI and the management plan to federal grant administering agencies when required by federal regulation or the terms of the research grant.  
# '''IRB Applications.''' Covered Persons listed in Section I of the IRB application shall submit a conflict of interest disclosure form as a part of the application process to the Office of Regulatory Affairs pursuant to UNMC Human Research Protection Program Policy 1.22.  
# '''IRB Applications.''' Covered Persons listed in Section I of the IRB application shall submit a conflict of interest disclosure form as a part of the application process to the Office of Regulatory Affairs pursuant to UNMC Human Research Protection Program Policy 1.22.  
# '''Changes in Existing COI.''' Any increase that would make the total remuneration greater than $5,000 would elevate the financial interest to a significant financial interest and requires disclosure within 30 days of increase.  
# '''Changes in Existing COI.''' Any increase that would make the total remuneration greater than $5,000 would elevate the financial interest to a significant financial interest and requires disclosure within 30 days of increase.
# '''Foreign support and activities supported by foreign entities.''' Pursuant to UNMC Policy No. 8014, [[Disclosing Foreign Support and International Activities]], Covered Persons who participate in activities supported by foreign entities or who otherwise receive foreign support must disclose the nature of the activities and/or support on an Annual Disclosure of Financial Interest Questionnaire and submit it to the COI Officer.
===Institutional Conflict of Interest===
===Institutional Conflict of Interest===
In order to avoid real and perceived favoritism in long-term or repeated dealings with research sponsors, each/every potential Institutional COI shall be reported. Any Covered Person that has knowledge of potential Institutional COI shall complete an [https://unmc.coi-smart.com/ Annual Disclosure of Financial Interest Questionnaire] for review. The COI Officer shall convene a group of senior UNMC officials appointed by the Chancellor to review the disclosure and implement a management plan if appropriate. Sponsored Programs Administration shall report the significant Institutional COI to federal grant administering agencies when required by federal regulation or the terms of the research grant.  
In order to avoid real and perceived favoritism in long-term or repeated dealings with research sponsors, each/every potential Institutional COI shall be reported. Any Covered Person that has knowledge of potential Institutional COI shall complete an [https://unmc.coi-smart.com/ Annual Disclosure of Financial Interest Questionnaire] for review. The COI Officer shall convene a group of senior UNMC officials appointed by the Chancellor to review the disclosure and implement a management plan if appropriate. Sponsored Programs Administration shall report the significant Institutional COI to federal grant administering agencies when required by federal regulation or the terms of the research grant.  
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== Management of COI ==
== Management of COI ==
The following is a non-exhaustive list of '''example''' Management Plan strategies provided to serve as guidance to the COI Officer and the COI Committee.  
The following is a non-exhaustive list of '''example''' Management Plan strategies provided to serve as guidance to the COI Officer and the COI Committee.  
# Take no action beyond disclosure of the COI to UNMC and/or the research sponsor.
# Take no action beyond disclosure of the COI to UNMC and/or the research sponsor.
# Disclose the COI to the academic and professional communities in presentations and publications; the research sponsor through written notification; and research participants through informed consent documents when human subjects are involved.
# Disclose the COI to the academic and professional communities in presentations and publications; the research sponsor through written notification; and research participants through informed consent documents when human subjects are involved.