The University has four policies that most directly address potential conflicts of interest in sponsored programs:
These are described briefly below.
1. The University's Policy on Related Significant Financial Interest in Research and Scholary Activity 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. Recently, the policy has been extended to all sponsored research projects. 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 the disclosure of significant related financial interest to the Office of Sponsored Programs (OSP). Disclosures are reviewed by a committee which may require certain actions to manage, reduce or eliminate potential conflicts.
The complete policy may be found here.
Click here for Frequently Asked Questions.
Click here for the Disclosure Form.
2. The University 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 OSP, does outline situations which are to be avoided and investigators should engage their supervisors in discussion of potential conflicts under this policy.
The complete policy may be found here.
3. 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.
This policy may be viewed here.
4. The University'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 an OSP routing form authorizing a grant or contract activity is bound by this requirement.
This policy may be viewed here.
Additional resources and information:
NIH
Web-based Tutorial on Financial Conflict of Interest
The Council on Governmental Relations (COGR) - Recognizing & Managing Personal Conflicts of Interest (once at site, select Educational Materials, then select Research Administration, then select Recognizing & Managing Personal Conflicts of Interest, view the PDF Version)
Last modified June 12 2009 09:52 AM
