Re: Managing Conflict of Interest - Sub/Prime Herbert B. Chermside 01 Oct 2003 16:04 EST
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 > > >====================================================================== > 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") >====================================================================== 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 ====================================================================== 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") ======================================================================