Re: Conflict of interest regs
Randall Legeai 13 Jan 1994 18:36 EST
In Message Thu, 13 Jan 1994 15:59:10 -0500,
Liz Mazzella <EAM01%xxxxxx@UGA.CC.UGA.EDU> writes:
>We were just discussing this on another list I belong to for
>tech transfer. No sign of it yet. Apparently they were supposed to
>have it out in December, but received an extension until January.
>Someone on the other list also mentioned that COGR has received infommation
>that the proposed policy being circulated was going to classify
>"significant" financial interest at $5,000!
>
COGR (The Council on Governmental Relations) included a couple of pages
about what they expected the policy to include in their October Meeting
Report. I've attached them as a text file.
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Randall Legeai xxxxxx@mailhost.tcs.tulane.edu
Tulane University (PHN) 504/865-5758
Government/Agency Affairs (FAX) 504/865-5274
327 Gibson Hall, 6823 St. Charles Avenue
New Orleans, Louisiana, 70118-5698, USA
Conflict of Interest Rules Taking Shape
PHS has let it be known that proposed rule making for promoting objectivity in
research may be announced in the Federal Register in the first week of
December. This rule making deals with assuring that PHS-funded research is not
compromised by any significant financial interest. The rules will require PHS
funded applicants to assume full responsibility to ensure that the financial
interests of their employees do not compromise the objectivity with which the
research is designed,
At the same time, PHI, NSF and OMB have concurred that there is merit in the
universities' call for a government-wide policy on this issue. A federal
agency working group has been formed. It has met and identified common core
elements of a policy. Oth
The following specifics seem is emerge:
{SYMBOL 183 \f "Symbol" \s 10 \h} Universities will have to address all
research, including but not limited to clinical trials or product related
studies.
{SYMBOL 183 \f "Symbol" \s 10 \h} Grantee institutions carry full
responsibility. Each institution that applies for federal funding shall
provide an assurance to the government that: 1) it has administrative
procedures in place to identify and resolve si
{SYMBOL 183 \f "Symbol" \s 10 \h} All significant conflicts attributable to an
investigator must be disclosed to and resolved by the institution prior to
submission of an application. "Significant" interests are likely to be defined
as interests valued a
{SYMBOL 183 \f "Symbol" \s 10 \h} "Investigator" means the Principal
Investigator and any other person at the institution who has responsibility for
making decisions regarding the design, conduct or reporting of the PHS-funded
project that could significa
Elements of the institutional policy should include:
1) safeguarding PHS-funded research
2) informing the investigator of institutional compliance:
3) designating an institutional official who will solicit and review financial
disclosure
4) maintaining records of all financial disclosure statements filed and all
actions taken by the institution, on an award by award basis, for at least
three years beyond the termination of an award or until resolution of any
action by the DHHS involving
5) establishing procedures for resolving any allegations of undisclosed
or misrepresented financial interest and establishing a range of appropriate
sanctions for noncompliance with institutional policy: and
6) certifying on each funding application regarding identification and
resolution of significant financial interests and to update PHS within 60 days
about newly arisen conflicts.
The institution must take steps reasonably calculated to remove or limit any
bias in design, conduct or reporting of research. The following steps would
meet this criterion: 1) provide close oversight and review of the research
by an official indep
An institution may develop criteria far waivers. Waivers might be applied in
circumstances such as: 1) the interest is so remote or inconsequential that
there is no probability for bias on the objectivity of research: 2) any
resolution other than
In its administrative procedures, an institution will have to include
measures for sanctioning noncompliant employees. The institutions must
promptly notify PHS of instances at noncompliance, of the corrective action
taken, and the effect, i
We understand that when PHS publishes its rule making, it will be offered for a
60 day comment period. In the case of NSF, the policy will be final and
effective upon issuance.