Here's our policy, hope this helps you out! The University of Connecticut POLICIES Policy on Conflict of Interest in Research Introduction The purpose of this policy is to outline an institutional approach (applicable to all campuses of the University) to the identification and management of conflicts of interest, in a fashion which will foster both the conduct of scholarly activities and ensure compliance with federal and state regulations. Applicable Regulations At present, there are at least three sets of existing regulations (both state and federal) which serve as the basis for this policy. Copies of these regulations are available to all University faculty and staff from the appropriate offices of the University. The Code of Ethics for Public Officials, Connecticut General Statutes, Sec. 1-79 through 1-89 stipulates what types of activities are allowable for state employees who may have financial interests in companies which do business with the State of Connecticut. The National Science Foundation (NSF) Investigator Financial Disclosure Policy and the U. S. Public Health Service (PHS) regulations in 42 CFR Part 50, and 45 CFR Part 94, under the heading of Objectivity in Research become effective October 1, 1995, and carry the weight of federal regulation. The federal policies stipulate requirements for: annual financial disclosures on the part of ALL research investigators; institutional certification that all proposed and ongoing NIH/NSF sponsored research is either free of conflicts of interest, or that such conflicts are adequately managed; the implementation of an institutional mechanism for managing conflicts of interest in research; keeping NIH/NSF informed if the University is unable to satisfactorily manage actual or potential conflicts of interest; sanctions where appropriate; and, maintenance of records relating to this policy, for at least three years following the termination of a given project. Key Elements of the Policy It is the policy of the University of Connecticut to identify actual or potential sources of conflicts of interest in research; and to either eliminate, reduce or manage such conflicts. As such, the following elements comprise the general procedures which will be followed to assure compliance with this policy, and all applicable state and federal regulations related to conflicts of interest. All campuses of the University shall individually develop procedures for implementing this policy. Each campus' policy will conform to the requirements of all applicable regulations, and contain procedures for: Notification of investigators of the policy and procedures; Annual financial disclosure; Review of financial disclosure and certification of conflict of interest status; Resolution and/or management of conflicts of interest; Operation of a conflict of interest management committee; Maintenance of records; Notification of research sponsors. Appeals Sanctions Other Applicable Laws and Regulations Investigators may not engage in research activities sponsored by businesses in which those investigators have an ownership interest equalling 5% or more of the outstanding stock (or other ownership interests) of that business, as required by the Connecticut General Statutes. Definitions Business means any corporation, partnership, sole proprietorship, firm, franchise, association, organization, holding company, joint stock company, receivership, business or real estate trust, or any other legal entity organized for profit or charitable purposes. Conflict of Interest means a situation in which significant financial interests in a business, or other personal considerations provided by a business, may compromise, or have the appearance of compromising, an investigator's professional judgement in conducting or reporting research, the results of which could affect the aforementioned business, either directly or indirectly Immediate Family means the investigator's spouse, minor children, and any other persons living in the same household. Investigator means the principal investigator and any other person at the University who is responsible for the design, conduct or reporting of research, and the investigator's immediate family. This shall include faculty and research staff (research associates and assistants, postdoctoral fellows, graduate students, visiting scientists, and medical or dental students engaged in research conducted in the department). Participate means to be part of the described activity in any capacity, including but not limited to serving as the principal investigator, co-investigator, research collaborator or provider of direct patient care. The term is not intended to apply to individuals who provide primarily technical support or who are purely advisory, with no direct access to the data (e.g., control over its collection or analysis) or, in the case of clinical research, to the trial participants, unless they are in a position to influence the study's results or have privileged information as to the outcome. Significant Financial Interest means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights). The term does not include: 1. Salary, royalties, or other remuneration from the University; 2. Income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities; 3. Income from service on advisory committees or review panels for public or non-profit entities; or 4. An equity interest that when aggregated for the investigator and the investigator's spouse and dependent children, meets both of the following tests: Does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value, and does not represent more than a 5% ownership interest in any single entity; or, 5. Salary, royalties or other payments that when aggregated for the investigator and the investigator's spouse and dependent children over the next 12 months, are not expected to exceed $10,000. Research means a systematic investigation designed to develop or contribute to generalizable knowledge relating broadly to public health, including behavioral and social sciences research. The term encompasses basic and applied research, and product development. > -----Original Message----- > From: Barbara Bralver [SMTP:xxxxxx@ALPHA.LEHMAN.CUNY.EDU] > Sent: Thursday, March 02, 2000 8:49 AM > To: xxxxxx@HRINET.ORG > Subject: Re: Conflict of Interest > > NCURA.edu > > > > At 09:53 PM 3/1/2000 -0500, you wrote: > >Greetings: > > > >Does anyone know of a good site to find Conflict of Interest policies? > >I'm looking to find a source that will tell us if we are following the > >proper procedures. > > > >Thank you, > > Eleanor Cicinsky > > Temple University > > > > > >====================================================================== > > Instructions on how to use the RESADM-L Mailing List, including > > subscription information and a web-searchable archive, are available > > via our web site at http://www.hrinet.org (click on "Listserv Lists") > >====================================================================== > > > > > ^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^^ > Barbara Bralver > mailto:xxxxxx@alpha.lehman.cuny.edu > For up to the minute grant information online: > http://www.lehman.cuny.edu/grants/ > > > ====================================================================== > Instructions on how to use the RESADM-L Mailing List, including > subscription information and a web-searchable archive, are available > via our web site at http://www.hrinet.org (click on "Listserv Lists") > ====================================================================== ====================================================================== Instructions on how to use the RESADM-L Mailing List, including subscription information and a web-searchable archive, are available via our web site at http://www.hrinet.org (click on "Listserv Lists") ======================================================================
