VCOM Institutional Policy and Procedure Manual

V COM Policy and Procedure

Policy # R 013

In addition to the requirement above, a Research Financial Conflict of Interest Disclosure Form must be updated within 30 days of discovering changes that may: a. Give rise to a potential conflict of interest or appearance of a conflict of interest, b. Eliminate a potential conflict of interest previo usly disclosed, c. Result in an affirmative answer to any question on the Research Financial Conflict of Interest Disclosure Form previously answered in the negative. For federal awards , all collaborators, subcontractors, subrecipients and visiting scientist s must either comply with this Policy or be subject to a written agreement that states their institutions are in compliance with pertinent federal conflict of interest policies, and that they are in turn compliant with their own institutional policies. Se e Section 10 for additional information and procedure . 6. A SSESSING & D ETERMINING FINANCIAL CONFLICT O F I NTEREST IN R ESEARCH Prior to the College’s expenditure of any funds under an externally - sponsored research project, the designated officials shall (cons istent with 42.CFR. 50.604(f) ): a. Review all Investigator disclosures of significant financial interests, b. Determine whether any significant financia l interests related to research and c. Determine whether a financial conflict of interest exists . The above steps must be completed within 60 days of disclosure of a Significant Financial Interest. In addition, within those 60 days, the College must also implement, on at least an interim basis, a management plan that shall specify the actions that have been, and will be, taken to manage such financial conflict of interest. 6.1. Review Procedure The College shall designate an institutional official to receive and review all Research Financial Conflict of Interest Disclosure Forms from each Investigator who is planning to participate in, or who is participating in, research as defined in Section 3 above. This individual, the Institutional Integrity Offic er, shall be appointed annually by the President and Provost. The Institutional Integrity Officer shall be responsible for maintaining a file of all submitted forms and associated documentation . If a potential financial conflict of interest is identified, the Institutional Integrity Officer will contact the Investigator and further document the details concerning any potential significant financial interests in research. If the Institutional Integrity Officer determines that there are significa nt financial interests in research, those interests shall be reviewed by the Chair of the Conflict of Interest Committee and the Responsible Institutional Official . Upon review, these officials shall determine and document: a. The Investigator is not a Finan cially Interested Individual, b. The Investigator is a Financially Interested Individual; however, the conflict can be managed by full disclosure of the interest to the public, or to the research subjects in the informed consent documents, or c. The Investigator is a Financially Interested Individual and the conflict should be referred to the Conflict of Interest Committee for further review .

The Conflict of Interest Committee, appointed by the President and Provost, will be responsible for reviewing all conflic ts referred to it by the Chair and the Responsible Institutional Official.

Financial Conflicts of Interest in Research Policy

Page 6 of 13