This is only my personal opinion, though I am Executive Secretary of our
Research COI Committee. I feel that nepotism COI's are the most insidious
in our environment. Frequently the professional couple represent two real
experts, and people who work together very well and very productively; yet
on the surface the public perception is that it is the worst sort of
conflict, financial self-dealing.
I think the situation you have requires clear disclosure, at the SP to SP
office or at the COI Officer to COI Officer, to the other institution. The
management plan clearly requires both institutions to be involved. Because
there is no increase in your PI's income, just a redistribution of %
effort, some of the apparent conflict is removed, for those who look that
deeply into it. On the other hand, the awarding institution must look at
preferential offering of the work.
Jointly I am sure you can resolve this, but be clear that you have two
different institutions with two different COI's to deal with, and two
different histories, practices, precedents and passers of judgement.
If you fine a good resolution, share it; we can all learn!
Chuck
At 03:26 PM 10/1/2003 -0400, you wrote:
>A faculty member of ours has approached the Sponsored Programs Office
>with an opportunity to do some work under a sub-contract to a Federal
>grant held by a major research institution. In the course of our
>conversations, it was disclosed that the PI on the prime award was an
>immediate family member of our PI. This activity falls under the
>Federal conflict of interest (COI) regulations as nepotism.
>
>Knowing about this COI requires us to manage it. While managing it
>internally is pretty straight forward, I am looking for guidance on
>disclosing it to the prime institution. Is it our responsibility to
>disclose it to them? What type of disclosure might be appropriate?
>Verbal or written. Should the disclosure be made at a high level within
>the prime institution or at lower departmental levels (where the PI in
>question is the manager) or both?
>
>Responses can be posted to the listserv or directly to me at
>xxxxxx@newpaltz.edu
>
>
>Patrick C. Ryan
>Assistant Director for Grant Services
>Office of Sponsored Programs, HAB 805
>SUNY New Paltz
>75 So. Manheim Boulevard
>New Paltz, NY 12561
>(845) 257-3282
>(845) 257-3284 - FAX
>
>
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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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