Hello,

I have a question regarding the conflict of interest requirements for PHS, NSF,
and AHA funded projects.  Do you require those individuals named as "Other
Significant Contributors" on NIH grants to submit conflict of interest
disclosure forms, even if they are not affiliated with your own institution?
And if so, what conflict of interest policy do you apply (assuming that the
federal limits for significant financial interest are met)?

I ask because while it is clear that we need to process disclosure forms for all
key personnel, it seems that the definition of "Investigator" under the
regulations might be read to also include Other Significant Contributors.
Section 50.603 of 42 CFR Subpart F defines "Investigator" as "the principal
investigator and any other person who is responsible for the design, conduct, or
reporting of research funded by PHS, or proposed for such funding..."  The Grant
Application Instructions for PHS 398 define "Other Significant Contributors" as
"...individuals who have committed to contribute to the scientific development
or execution of the project, but are not committing any specified measurable
effort (in person months) to the project...Consultants should be included if
they meet this definition. This would also be an appropriate designation for
mentors on Career awards."
Any insight you have through your own processes would be very much appreciated.
Thanks,
Gretchen

Gretchen A. Brodnicki, J.D.
Director of Research Compliance
Office of Compliance & Business Integrity
Partners HealthCare System, Inc.
75 Francis Street
Boston, MA  02115
Tel:  617-954-9639
Fax: 617-954-9720
email:  xxxxxx@partners.org

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