VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U015

Institutional Integrity Officer: The institutional official responsible for general oversight in ensuring compliance in VCOM personnel relationships with industry. Medical Vendor Representative: Vendor representatives from pharmaceutical companies, biotechnology companies and manufacturers and distributors of medical device and durable medical equipment. VCOM: The Edward Via College of Osteopathic Medicine. This encompasses all campuses: Virginia, South Carolina and Alabama. VCOM Faculty: For the purpose of this policy, VCOM Faculty refers to research and teaching faculty, both full and part-time, on all campuses. VCOM Personnel: Any employee or appointee of VCOM, whether full-time or part-time, as well as all students currently enrolled at VCOM. This includes full time faculty, including post-doctoral fellows, part-time faculty, faculty who are on leave if the leave is funded at least partially from VCOM sources and students and trainees. 3. APPLICABILITY This policy applies to all VCOM faculty, students and staff. It applies to all VCOM campuses: Virginia, South Carolina and Alabama. 4. RESPONSIBILITIES 4.1 Leadership The Deans and Associate Deans are responsible for review and resolution of conflicts disclosed by VCOM personnel. The President and the Board of Directors are responsible for evaluation and resolution of positive conflict of interest disclosures of administrative officers (Deans, Associate Deans, etc.). The Office of Research Administration is responsible for the collection, distribution and maintenance of records of the conflicts of interest assurances, disclosures and management resolutions. The ORA is also charged with development and management of training modules and programs and policy update. The Conflict of Interest Committee, appointed by the President, will be responsible for reviewing: 1) all new cases referred to it by the Deans or Associate Deans, 2) all new conflicts of interest involving human subjects research and 3) all conflicts of interest that have generated one or more complaints during the past three years. The Committee will conduct a thorough review of each case and will make recommendations for resolution. For any case in front of the Committee, the VCOM personnel will have the opportunity to respond in person and/or in writing to the issues raised in the course of such review, and the response will become part of the record. If the President does not appoint the Conflict of Interest Committee to review a case, the above duties will fall to the Deans and Associate Deans. 4.2 Administrators Individuals in administrative positions have substantial influence over others and must take care to avoid relationships that have the potential to advantage the individual but adversely affect the College’s

VCOM Policy on Conflicts of Interest

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