Sponsored Project Administration - SPA
Conflict of Interest
- Frequently Asked Questions - updated 08-24-12
- Investigator User's Guide to the COI On-Line Disclosure System - updated 11-30-12 pdf
- Login to COI On-Line Disclosure System
- Subrecipients Using UVM's Financial Conflict of Interest Policy
- UVM Training Presentation on New PHS FCOI Regulations - Effective August 24, 2012 pdf
UVM Policy Guidelines
UVM has four (4) policies that most directly address potential conflicts of interest in sponsored projects.
- Financial Conflict of Interest in Sponsored Research
- Conflict of Interest and Conflict of Commitment Policy
- Contract Approval and Signatory Policy
- IRB Policy Regarding Investigator Financial Interest
1. Related Significant Financial Interest in Research and Scholarly Activity
UVM’s Financial Conflict of Interest in Sponsored Research Policy was developed in response to specific federal agency requirements for PHS (including NIH, HRSA, AHRQ, FDA, SAMHSA, etc.) and NSF funded research and those agencies that have adopted the PHS policy, most notably the American Cancer Society and American Heart Association. This policy seeks to promote scientific objectivity. You will note as you read on, other policies designed to address other situations of conflict.
This policy requires that all investigators disclose whether or not they have a significant financial interest related to their University responsibilities submitting a proposal. Positive disclosures are reviewed to determine if they constitute financial conflicts of interest related to University research that require certain actions to manage, reduce or eliminate potential conflicts. On-line training is required prior to disclosure
2. Conflict of Interest Policy and Conflict of Commitment
UVM also has a widely applicable Conflict of Interest and Conflict of Commitment Policy that applies to many activities, including sponsored programs. This policy, while not requiring disclosure directly to SPA, does outline situations which are to be avoided and investigators should engage their supervisors in discussion of potential conflicts under this policy.
3. IRB Policy Regarding Investigator Financial Interest
The IRB Policy Regarding Investigator Financial Interest in projects involving human subjects requires disclosure of financial interests when protocol are submitted for committee review. As part of its review, the IRB considers and evaluates whether such interests have the potential to adversely affect the rights or welfare of human research participants.
4. Contract Approval and Signatory Authority Policy
UVM's Contract Approval and Signatory Authority Policy requires an official who otherwise has contract negotiation and/or signatory authority to disclose any conflicts of interest to his/her supervisor before entering into contract negotiations or contract review and to excuse him/herself from any involvement in the contract. Anyone signing a Sponsored Project Routing Form authorizing a grant or contract activity is bound by this requirement.
Additional resources and information
- NIH Financial Conflict Of Interest (FCOI) Tutorial
- Conflict of Interest Resources available on the web
- COGR - Publications - Conflicts of Interest - Council On Governmental Relations - Click Recognizing & Managing Personal Conflicts of Interest > view the pdf version
Last modified September 19 2013 10:45 AM