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Policies
Guidelines for Conflict of Interest: Initial Review of the COI Management
Plan
The investigator must provide to the OIR Committee the following information for review:
- All relevant financial interests that exceed the threshold of significance as defined in the Conflict of Interest policy.
- All external commitments and documentation that involvement does not exceed permissible levels as defined in the Conflict of Interest policy.
- Description of the facts and circumstances regarding the investigator's financial involvement with the sponsoring organization and measures that will be taken to ensure that the financial involvement will not affect or impair the conduct of the research in accordance with the applicable University policies and the highest professional standards.
- Documentation of how the interests of the University will be maintained in consideration of the investigator's interest in the sponsor.
- Evidence that the research project will lead to the advancement of knowledge rather than to merely benefiting the sponsor.
- Evidence that the research project will contribute to the University's mission of teaching, research, and public service.
- When applicable, evidence that the best interests of the University and the public will be served by granting an exclusive license to the sponsor.
- Descriptions of any patent applications that have been filed, or any intent to file patent applications, related to or arising from this research program. If any patent applications have been filed, what was the filing date and applicant name?
- All relevant information concerning the faculty member's activities have been acquired (i.e., there been full disclosure).
At a minimum, the University's OIR Committee will determine whether a Significant Financial Interest could affect the design, conduct, or reporting of the research activities funded or proposed for such funding and determine what conditions or restrictions, if any, should be imposed to manage such interests. Any conditions or restrictions to resolve or manage conflicts of interest must be determined and implemented before the expenditure of any funds awarded under a grant or contract. Examples of conditions or restrictions that may be imposed to manage actual or potential conflicts of interest include:
- Public disclosures of Significant Financial Interests;
- Monitoring of the research by independent reviewers;
- Modification of the research plan;
- Disqualification from participation in all or a portion of the research project in question;
- Divestiture of Significant Financial Interests;
- Severance of relationships that create actual or potential conflicts;
- Appointing an impartial person to monitor the use of students;
- Removing purchasing decision authority;
- A leave of absence for the faculty member with or without pay; or
- The conflict cannot be managed and, therefore, the agreement cannot be approved.
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