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Re: Herbert B. Chermside 14 May 2003 12:43 EST

We, relatively newly, have a specific separate COI form for each sponsored
program and each IRB or IACUC form.  If desired, I'll share it
directly.  The following considerations went into it.

1)      COI that "that might, or might appear to, affect the design,
conduct or reporting of this activity" satisfies the PHS and NSF
regulations, and we have adopted as VCU policy for all sponsored programs
and research subjects matters.

2)      We have another question to cover a state COI law that measures
something slightly different, but still a COI.

3)      We collect the unique number of the sponsored program or subject
protection protocol.  We are developing a way to ensure that we do not
duplicate submissions to our committee.

4)      We ask "Is this research for the purpose of regulatory approval,
including clinical trial?" with the definition: ""Regulatory approval,
including clinical trial" means a study known to be intended for use by the
Federal Government in developing an agency action that has the force of
law."  This is because we have established the PHS/NSF standard of $10,000
or 5% equity as the threshold for financial conflict of interest EXCEPT for
these matters, which we consider especially deserving of absence of the
merest hint of COI so use a threshold of $0.

5)      We also ask questions related to publication control, specifying
supply sources, supervisory COI influence, and privileged access to
research results.  I am not yet fully persuaded that they are necessary,
but they can't hurt.

We had a "check box" on our internal routing sheet in the past, but we now
feel this is not enough to ensure that the University is making the
strongest efforts to ensure that our research is clearly objective.  We
also find that the question sheet is a useful educational tool.

Chuck

At 10:50 AM 5/14/2003 -0500, you wrote:
>What kind of form or statement do you have faculty members sign
>regarding Significant Financial Conflict of Interest as part of the
>grant approval process?  Any examples? We have PIs sign a standard
>statement as part of the Grant Approval Form.  A while back one
>institution noted that they have a separate form for Conflict of
>Interest.  Please advise. Thank you.
>
>Sincerely,
>Heather Dragoo
>Senior Administrative Assistant
>Sponsored Research Office
>University of Southern Indiana
>8600 University Blvd.
>Evansville, IN 47715
>(812) 465-1126
>xxxxxx@usi.edu
>http://www.usi.edu/gr&res/ogsr.asp
>
>
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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:
 Biotech One, Suite 113
 Virginia Biotechnology Research Park
 800 East Leigh Street
 Richmond, VA 23219
Voice:  804-828-6772
Fax     804-828-2521
OFFICE e-mail   xxxxxx@VCU.EDU
Personal e-mail xxxxxx@vcu.edu
http://www.research.vcu.edu/ospa.htm

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