Conflict of Interest Policies Charles E. Graham, Ph.D. 01 Mar 1995 10:30 EST

Response to Pamela Webb's question.

My colleagues and I have attended the excellent workshops by Robert
Killoren et al. of Penn State at SRA and NCURA on this subject. At
NCURA there was considerable discussion of who the disclosure policy
should apply to. My impression was that the majority took the same position
as Pamela, requiring disclosure from named PI's and Co'PI's only. In our
discussion we realized there is no readily definable end to the list of
individuals who _could_ have a disclosable conflict of interest, including
not-yet-recruited graduate students. One of the problems becomes how to
ensure these unidentified individuals consider whether they should make a

As we consider this issue here, I am wondering whether to extend the
disclosure requirement to named investigators "and other key personnel".
To make this work, the PI would sign an assurance on the Proposal Routing
and Approval Form saying "I have read the financial disclosure policy
will ensure that my associates on this project are informed of the
requirements for disclosure" (I recognise the language needs refinement).
Given the difficulties, I don't see much alternative to shifting some of
the burden to the PI, as in fact we do for some other compliance issues
(e.g. disbarment), if we wish to be more inclusive.

I would be interested to know if others think this is a
workable and reasonable improvement on the minimalist "named investigator
approach" that at least shows a genuine effort to cover other personnel.

Charles E. Graham, PhD., Director, Office of Sponsored Research
117D David Boyd Hall, Louisiana State University
Baton Rouge, LA 50310     504-388-8692;  FAX 388-6792