(Previous discussion continued)
Re: Conflict of Interest and Financial Disclosure Herbert B. Chermside 28 Jun 2002 07:23 EST

Re: Conflict of Interest and Financial Disclosure Herbert B. Chermside 28 Jun 2002 07:23 EST

We are looking into COI policies at VCU.  We find that many institutions
have an annual reporting requirement administered either centrally or at
the school level.  Others have specific requirements externally imposed and
seek only to satisfy that requirement -- the PHS/NSF rules, for example, or
state regulations (state schools).  Who is covered, the levels of
reporting, who "approves" agreements that may smell of COI, etc. is very
inconsistent.  It also appears that the date of stating  the policy appears
to have some influence on what is covered.  There is no clear industry
standard.  COI is a "compliance" issue that is "hot" these days, much in
the public eye, and the more recent the policy, the broader and often more
stringent the policy.  And the externally imposed standards appear to
vary.  (At the time the PHS/NSF rules were set, COGR was able to get some
measures of "conflict" to fit the same standards as several then existing
state laws.)

It is my personal opinion that the application set by PHS/NSF should apply
to all sponsored  agreements:  "...have the capacity to affect the design,
conduct, or reporting of research or educational activities."  I would add
"public service" to the type of agreement.  This would cover, in principle,
all sponsored programs.  The measure of "personal interest" could be the
PHS/NSF level, or another more stringent one.

Chuck

At 04:58 PM 6/27/2002 -0700, you wrote:
>John,
>
>A good reference (or back-up discussion) on this is the AAU Statement of
>October 9, 2001 which you can find at
>http://www.aau.edu/research/COI.01.pdf.  I am working in this direction
>also, but the sledding is uphill.
>
>Jim
>
>
>"Baumann, John" wrote:
>
> > Our university currently explicitly requires the submission of
> financial disclosure statements for all DHHS/PHS and NSF
> applications.  We do not, however, explicitly require them for
> applications to other federal agencies, to private foundations or for
> industry contracts (although the IRB will require them via a vis FDA
> requirements and the contacts themselves frequently address this point).
> >
> > I am, however, increasingly uncomfortable with not requiring such
> disclosure for non-DHHS/PHS and NSF application.  I am, therefore,
> turning to you for guidance.  What are the policies/practices at your
> institution regarding the submission of financial disclosure
> statements?  Do you require them for all applications?  Grants and
> contracts?   Federal and private funding sources?
> >
> > Thank you.
> >
> > John
> >
> > John R. Baumann, Ph.D.
> > Director
> > Office of Sponsored Programs & Research Support
> > University of Missouri -- Kansas City
> > 5100 Rockhill Road
> > Kansas City, MO 64110
> >
> > 816.235.1303 (v)
> > 816.235.6532 (f)
> > xxxxxx@umkc.edu
> >
> > location: 5211 Rockhill Road
> >
> > -----Original Message-----
> > From: Witt, Carolyn [mailto:xxxxxx@VAI.ORG]
> > Sent: Thursday, June 27, 2002 3:03 PM
> > To: xxxxxx@HRINET.ORG
> > Subject: [RESADM-L] Incentive Programs
> >
> > The Van Andel Institute, an independent non-profit cancer research
> institute, is beginning to investigate mechanisms for incentivizing
> Scientific Investigators (faculty) to seek out and obtain extramural
> funding.  We would like to hear from organizations/institutions who have
> developed incentive plans.
> >         - How does your incentive plan work?
> >         - How is your plan funded, i.e., from internal funds, F&A
> recovery, etc.
> >         - How long has the plan been in operation?
> >         - Have you been able to measure the impact of the plan on
> faculty productivity with respect to    grant activity, e.g., increased
> numbers of grants submitted, increase in total direct
> costs     requested, etc.?
> >
> > The other question we are asking relates to utilization of the internal
> funds released by the direct costs received from grants:
> >         - What does your organization/institution do with the money
> that is freed up from grants?
> >         - Do you return a portion back to
> Investigator/Department/School budgets for expenses,     salaries, etc?
> >         - Do you allow the recovery of salary from grants to increase
> or provide a bonus to the faculty           member's salary?
> >
> > Please feel free to respond to the listserve or directly to the email
> address noted below.  Thank you for sharing.
> >
> > Carolyn W. Witt, MEd, MBA
> > Director of Grants and Contracts
> > Van Andel Institute
> > 333 Bostwick Ave., NE
> > Grand Rapids, MI 49503
> > Phone:  (616) 234-5542
> > Fax:       (616) 234-5543
> > E-mail:  xxxxxx@vai.org
> >
> > ======================================================================
> >  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")
> > ======================================================================
> >
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>
>--
>James R. Brett, Ph.D., Director,
>Office of University Research
>California State University, Long Beach
>562-985-5314  562-985-8665 fax
>http://www.csulb.edu/~research/
>
>
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>  subscription information and a web-searchable archive, are available
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Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Commonwealth University
PO BOX 980568
Richmond, VA  23298-0568
Express Delivery Only:
 Sanger Hall, Rm. 1-032A
 11th & Marshall Streets
 Richmond, VA  23219
Voice:  804-828-6772
Fax     804-828-2521
OFFICE e-mail   xxxxxx@VCU.EDU
Personal e-mail xxxxxx@vcu.edu
http://views.vcu.edu/ospa/

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 via our web site at http://www.hrinet.org (click on "Listserv Lists")
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