At VCU we have the following COI matters to consider:
--  State COI law which applies to all employees.
--  Exemption  procedures for one section of state COI law that prohibits
having a "personal interest" in a contract with your own state agency other
than your salary (this prevented our inventors developing their own
inventions, etc., etc. until the exemption was created).
--  University "COI policy" which is really a procurement integrity policy.
--  NIH/NSF COI regs.
--  FDA COI regs, applicable on clinical trials.
We also have a major thrust in support of faculty entrepreneurship.

State COI is law; the AG has directed we not codify it in institutional
policy.  AG also urged we not use the phrase "COI Policy" for anything we
do prepare to avoid conflict with state law.

With all this confusion, we DO NOT try to have a single policy.

For most of the COI stuff, see the bottom of the long web page:
http://views.vcu.edu/views/ospa/OSPA_Guidelines/App_Proc.html

Good luck with this thorny problem!

Chuck

At 03:07 PM 9/24/98 -0400, you wrote:
>How are other organizations addressing the FDA requirements for disclosing
the financial interests of clinical investigators in clinical studies?  I'm
especially interested in how it may be incorporated into an overall policy
that addresses PHS/NSF requirements as well.
>
>Thanks,
>Colleen
>
>
>Colleen Corcoran
>Clinical Research Administrator
>Research Foundation for Mental Hygiene, Inc.
>(518) 474-5663
>(518) 474-6995 fax
>
Herbert B. Chermside, CRA
Director, Sponsored Programs Administration
Virginia Comonwealth University
PO BOX 980568
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http://views.vcu.edu/views/ospa/