Policies
Guidelines for Conflict of Interest: Responsibilities
1. Responsibility of the Investigator/Researcher
It is the responsibility of the investigator/researcher to disclose all Significant Financial Interests and business relationships on the Financial Disclosure Statement (FDS) and to continue to complete necessary paperwork regarding potential conflicts of interest or commitment during the period of a grant, contract, or licensing arrangement. The investigator/researcher is responsible for working with the Office of the Vice President for Research, its officers, and the OIR Committee in managing, reducing, or eliminating any conflict of interest or commitment. This includes the completion of a COI Management Plan, the preparation of an Annual Review Report, and any update of a COI Management Plan.
The investigator/researcher is responsible for updating any information relevant to a conflict of interest or commitment during the period covered by the management plan and for notifying the chair of the OIR Committee of any additional potential conflicts of interest or commitment that may arise.
The investigator/researcher must disclose to the relevant dean, associate dean for research, or department chair all current or prospective situations that may raise questions of conflict of interest or commitment as soon as such situations become known to the investigator/researcher.
2. Responsibility of College Deans/Department Chairs
College deans and department chairs are responsible for advising the investigator/researcher of the appropriate resources for guidance in managing a potential conflict of interest or commitment when any potential or perceived conflicts are brought to the chair’s or dean’s attention.
3. Responsibility of the Chair of the Objectivity in Research Committee
The Vice President for Research has charged the chair of the OIR Committee with the responsibility for the implementation of, and compliance with, this policy. The chair of the OIR Committee is responsible for reviewing all Financial Disclosure Statements. The OIR Committee chair will maintain all records received and created pursuant to this policy as well as all records of actions taken with respect to each conflict of interest or commitment at least five years beyond the termination or completion of the research grant or contract, or until resolution of any action by the granting or contracting agency/entity involving the records, whichever is longer.
4. Responsibility of the Office of Sponsored Projects (OSP)
OSP shall forward any Financial Disclosure Statements received during the grant proposal process to the chair of the Objectivity in Research Committee.
In the event that federally funded research at the University is carried out through a subcontractor or collaborator, the University will require the subcontractor or collaborator to certify that its investigator/researcher is in compliance with a policy on objectivity in research that meets requirements of the federal sponsor’s regulations. OSP will also monitor subrecipients for compliance.
5. Responsibility of the Office of Technology Commercialization (OTC)
OTC shall remind the investigator/researcher to submit an FDS to the chair of the OIR Committee when necessary. OTC will provide the chair of the OIR Committee with information requested, including a copy of the license, sale, or release agreement, if applicable. OTC will inform the chair of the OIR Committee prior to the execution of a license, sale, or release agreement.
