VCOM Institutional Policy and Procedure Manual

VCOM Policy and Procedure

Policy #U015

those for all VCOM personnel regardless of employment role and setting (see Enforcement and Sanctions section).

9. ENFORCEMENT AND SANCTIONS 9.1 Enforcement and Monitoring

Oversight of the conflict of interest disclosures and management shall be the responsibility of the Institutional Integrity Officer. The Institutional Integrity Officer shall work in conjunction with the Office of Research Administration to monitor for compliance. Any requests related to a VCOM personnel’s outside compensated professional activities will be made to the individual from the Institutional Integrity Officer. Annually, the Institutional Integrity Officer, in conjunction with the Office of Research Administration, shall provide a monitoring report to the President and Associate Deans. This report will include verification that any outside compensated professional activities have been reported and approved and verification that all external disclosures have been made in publications, lectures or on the VCOM web page. Should the Institutional Integrity Officer identify non-compliance related to VCOM personnel secondary employment or a compensation arrangement, he will address this in writing and submit to the President and Associate Deans, who will review the report and determine if the VCOM personnel is compliant with this policy. If non-compliance is evident, sanctions will be addressed. The President, Associate Deans and, if applicable, the Conflict of Interest Committee will decide upon sanctions for the non compliant VCOM personnel. 9.2 Assessing Non-Compliance and Sanctions When the Institutional Integrity Officer identifies any instances of non-compliance related to this policy, he or she will report this to the President and appropriate Associate Dean via a written report. The President and Associate Dean will conduct an assessment and determine as to whether the VCOM personnel failed to comply and the extent of the non-compliance. The President and Associate Dean may discuss the potential non-compliance with the VCOM personnel, or others as necessary. The President and Associate Dean may also convene the Conflict of Interest Committee for their assessment. Examples of non-compliance include failure of VCOM personnel to: • Adhere to the VCOM Policy on Conflicts of Interest guidelines on allowable and unallowable Specific Activities, • Submit a Disclosure Form, • Disclose his/her outside compensated professional activities to his/her Associate Dean. • Cooperate or respond to the Institutional Integrity Officer or Associate Dean’s requests for more information, • Agree to manage his/her conflicts of interest and/or • Take the necessary steps to manage his/her conflict of interest as agreed to the management plan. If the President and Associate Dean determine non-compliance has occurred, a written assessment will be completed and corrective actions will be taken. Corrective actions and sanctions as deemed appropriate will be determined by the President in consultation with the appropriate Associate Dean. In addition, if the non-compliance involves federally-sponsored research, additional reviews will be required. Please see the VCOM Financial Conflict of Interest in Research Policy.

VCOM Policy on Conflicts of Interest

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