Isn't the question one of how the recipient is defined by A-133 Section .210? Academic collaborators (who could be for-profit) providing reagents or lab equipment are also (at least on paper) providing a PI who retains authority over the use of those reagents or equipment and, at least arguably, engages in programmatic decision-making and so are subrecipients rather than vendors subject to the procurement standards. -----Original Message----- From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf Of Charlie Hathaway Sent: Friday, March 12, 2010 12:50 PM To: xxxxxx@hrinet.org Subject: Re: [RESADM-L] conflict of interest? OK...just curious. Do these regs ONLY apply because the company is FOR PROFIT? Certainly, there are many situations in which potential ACADEMIC COLLABORATORS might "encourage" a PI to include their involvement in a project (e.g. sub award to pay for use of laboratory EQUIPMENT and reagents to run an analysis) AND ALSO offer assistance with the preparation of the proposal. In each case the sub-contractor/vendor stands to benefit from the success of the proposal. Isn't the important question whether the proposed research could be compromised by the influence? To what degree can objectivity be assured when everyone involved in a research project stands to gain personally? CH > Check out A-110, part ___.43, Competition, which expressly forbids this > type of practice. "In order to ensure objective contractor performance > and eliminate unfair competitive advantage, contractors that develop or > draft specifications, requirements, statements of work, invitations for > bids and/or requests for proposals shall be excluded from competing for > such procurements." Clearly, you couldn't purchase equipment from them if > they helped. > Jane > > Jane A. Youngers > Assistant Vice President for Research > Office of Sponsored Programs > The University of Texas Health Science Center at San Antonio > 7703 Floyd Curl Drive > San Antonio, TX 78229-3900 > 210.567.2333 > fax 210.567.2344 > xxxxxx@uthscsa.edu > > > > > -----Original Message----- > From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf > Of Gina Betcher > Sent: Friday, March 12, 2010 11:08 AM > To: xxxxxx@hrinet.org > Subject: Re: [RESADM-L] conflict of interest? > > Seems unintentionally unethical but it is most definitely. However > purchase of a kind of equipment is allowed, priced, in a budget. > Source of sale is not. > -----Original Message----- > From: "Nadler, Elsa" <xxxxxx@UTNET.UTOLEDO.EDU> > To: <xxxxxx@hrinet.org> > > Sent: 3/12/2010 11:54:52 AM > Subject: Re: [RESADM-L] conflict of interest? > > If you are truly under no obligation, it is probably OK, although somewhat > shady. If there is any kind of prior agreement, or even a suggestion of > one, I would consider it highly unethical, not just a conflict of > interest. > > Elsa Nadler > 419.383.6967 > > > ________________________________ > > From: Research Administration List [mailto:xxxxxx@hrinet.org] On Behalf > Of Maldve Regina > Sent: Friday, March 12, 2010 11:41 AM > To: xxxxxx@hrinet.org > Subject: [RESADM-L] conflict of interest? > > > Oh Wise Ones, > > Our college was approached by a for-profit organization in regards to a > HRSA program announcement: ARRA-Equipment to enhance training for health > professionals-health careers opportunity program. The company is a > provider of video conferencing systems and we have purchased products from > them in the past. This company reached out to our learning resources > center staff and offered to provide grant writing assistance if they were > interested in submitting a proposal for this application. > Conveniently, they would benefit from this collaboration, given that we > could purchase the equipment from them. My question, is this a conflict > of interest for a for-profit entity to solicit grant awards from > universities, offer grant writing services (presumably at no cost) > provided they are the supplier of equipment. Obviously, we would be > > under no obligation to purchase their product; wink, wink. nudge, nudge. > > Thanks for your insight. > > Reg > > Regina Maldve, Ph.D., CRA > Sr. Grants and Contracts Specialist > Office of the Associate Dean for Research and Graduate Studies The > University of Texas at Austin College of Pharmacy > (512) 232-7511 > > Any fool can make things bigger, more complex, and more violent. It takes > a touch of genius - and a lot of courage - to move in the opposite > direction. > ~Albert Einstein > > > > > > ====================================================================== > > 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") > ====================================================================== > > > > > ====================================================================== > > 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") > ====================================================================== > > > ====================================================================== > 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") > ====================================================================== > > > ====================================================================== > 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") > ====================================================================== > ====================================================================== 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") ====================================================================== This e-mail message (including any attachments) is for the sole use of the intended recipient(s) and may contain confidential and privileged information. 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