Research Conflict of Interest Procedures: Difference between revisions

(Created page with "Review by Policy Owner: '''November 15, 2007''' <big>Research Conflict of Interest Procedures</big> == Introduction == Potential research conflicts of interest arise ...")
 
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'''Conflicts of Interest'''   
'''Conflicts of Interest'''   
   
   
# '''Initial disclosure.''' All faculty members, directors, administrators and department heads (or equivalents) shall complete a UNMC Disclosure of Potential Conflict of Interest Form (Appendix B) within 90 days of initial appointment/hire.  The unit Personnel Action Form (PAF) coordinators are responsible for ensuring forms are completed in a timely manner. (Paragraph under construction; will be implemented at later date)
# '''Initial disclosure.''' All faculty members, directors, administrators and department heads (or equivalents) shall complete a UNMC Disclosure of Potential Conflict of Interest Form (Appendix B) within 90 days of initial appointment/hire.  The unit Personnel Action Form (PAF) coordinators are responsible for ensuring forms are completed in a timely manner. (Paragraph under construction; will be implemented at later date)  
# '''New potential conflicts.''' Covered Persons who propose to engage in an activity that would create a situation defined as a COI shall complete a Disclosure of Potential Conflict of Interest form (Appendix B) and submit it to the COI Officer.  
# '''New potential conflicts.''' Covered Persons who propose to engage in an activity that would create a situation defined as a COI shall complete a Disclosure of Potential Conflict of Interest form (Appendix B) and submit it to the COI Officer.
# '''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 UNMC Disclosure of Potential Conflict of Interest Form(Appendix B) 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 1.11  
# '''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 UNMC Disclosure of Potential Conflict of Interest Form(Appendix B) 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.
# '''Changes in Existing COI.''' Any $5,000 or more increase in the amount of COI must be reported to the COI Officer on a Disclosure of Potential Conflict of Interest form within 60 days of the increase.   
# '''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 1.11
# '''Changes in Existing COI.''' Any $5,000 or more increase in the amount of COI must be reported to the COI Officer on a Disclosure of Potential Conflict of Interest form within 60 days of the increase.  
   


'''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 a UNMC Disclosure of Potential Institutional Conflict of Interest Form(Appendix C) and send it to the COI Officer 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 a UNMC Disclosure of Potential Institutional Conflict of Interest Form(Appendix C) and send it to the COI Officer 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.


== COI Officer Action. ==
== COI Officer Action. ==