Your questions suggest a propensity to be very limiting and controlling with the policy currently envisioned. COI is a VERY complex issue, usually confounded by multiple policies imposed by multiple external ources. It is an exercise in regulating behavior according to some standard of morality/ethics -- and we all know that it is impossible to reach a strong agreement an to what is moral and what immoral. Or, as to what is germain to a given situation and what not. Certainly there is some agreement among many individuals as to what a minimum standard should be; if you are very lucky, you will create a COI policy, and system for enforcing it, which is acceptable to a sufficient majority of your constituents that it will be followed rather than ignored or circumvented. Caveats having been stated, our answers are interspersed. Also I have posted at http://views.vcu.edu/views/ospa/dwnloads/coisrava.ppt a copy of a PowerPoint presentation I gave recently on the subject. I will leave it posted there one week. See VCU's OSPA web page for discussion of all COI relevant to our PI's. Go to http://views.vcu.edu/views/ospa/OSPA_Guidelines/App_Proc.html and scroll down near bottom (page is too long, but will be a while till we can spend time revising!) At 06:08 PM 1/25/99 EST, you wrote: >We are reviewing our conflict of interest policy and would appreciate >receiving the following information. We will be happy to submit copies >of responses to the participants of this survey. Please do. Please list your >institution, your name and your title. If you are not the person >responding directly, please let us know who provided the information. > >1. Does your university have a standing committee which reviews >conflict of interest cases? No What level university official was (is) >responsible for developing the policy? Title Director, Sponsored Programs ensured that it was done and managed most of the process, to the extent that the University had any discretion. > >2. Which university office screens awards and proposals to determien if >there is a possible conflict? List office and person's title which >screens. PI self report is prime notice of need for any review. Office of Sponsored Programs a) requires a "declaration of interest" form for each sponsored project with a for-profit sponsor (relates to state COI law), b) has question regarding financial interests on internal approval sheet (relates to policy engendered by PHS/NSF regulations). Suggest that checking out each proposal by some central staff is waste of resources and will be perceived by PI's as police state activity. > >3. If you use a committee, does the committee screen all cases, or only >those that indicate there is a possible conflict? No Committee Could we have a copy >of the screening form via email? What benchmarks are used to determine >a possible conflict? Dollar amount or other. $10,000/yr income and/or 3% ownership in entity -- luckily, we were able to influence levels selected by PHS/NSF to meet state regs, or we'd have differing standards!! > >4. If a faculty memeber indicates that he many have a conflict, how is >the conflict managed-- examples. Re State COI law, there is a procedure by which the VP Research can make a determination that it is to the benefit of the University to undertake the contract which would otherwise be prohibited under COI law. Under policy responsive to PHS/NSF regs, conflict can be managed. Follow up would be part of management plan. We have set it up so that PI suggests management plan and central authority ( a small committee set up to support director, Sponsored Programs) approves or rejects. Concept is that PI is pest placed to know how to manage the conflict, and, unless the PI is trying to get away with something,it will be a good plan. If the PI is not acting in good faith, the subcommittee is expected to detect that and veto plans until one appears to meet the communal expectation of "ethical behavior". So far, PI's seem to think that is a reasonable process. Is there any routine follow up to >determine if he follows through with the management plan? Examples. > >5. Does the form indicating a possible conflict go the the Chair, >Provost, Dean, Counsel's office? All above, other? There is awareness by these academic managers (but not Counsel) of the possible conflict, because they see the internal routing sheets, but they do not become privy to the financial details of a possible conflict. The faculty members involved in creating one policy were explicit that such financial details should not be given to chairs or deans, as a way to avoid having the setting of salary influenced by knowledge of any other inclme the individual PI might have. If reporting on state form (state COI law) is involved, those forms are explicitly designed to show only a few ranges of value, rather than specific value -- I believe it is because the legislators, who designed the form (and have to report on iot themselves) wanted to minimize the detail available. > >6. What fields of research are most often involved with potential >conflicts? For us, life sciences/health sciences, for the two reasons that those are our big fields of research and that those fields have (and the University encourages) much professorial entrepreneurship. > >7. How many cases were reviewed last year for potential conflicts? Several How >many were considered conflicts? About half involved a possible conflict or a clear appearance of conflict. Were there any awards turned down >because the conflict couldn't be managed? No. > >8. What steps do you consider most helpful in managing conflicts? Enlisting the conflicted person in developing the management plan. > >9. What are the most significant issues universities need to address in >managing potential conflicts? a) avoid witch hunts b) always use the "[insert name of your most yellow journalism daily paper] Test", i.e., do you want it reported on the front page, either that your PI is "getting away" with something, or that Nasty U. is improperly restraining its faculty members. c) Times change, perceptions change, etc. Don't cast in stone something which would hurt if dropped on your toe! d) do not set the level of ethical behavior any higher than society's lowest mean acceptable standard. > >10. What complaints, if any have faculty had in filling out forms >relative to conflicts? "Too much @#$%*&#$ bureaucracy!" > >If you wish to fax your responses, our fax is 215/204-7486. Thanks for the opportunity to put in my two cents worth on a subject that concerns me. Thirty five years ago I "knew" what a scientist's ethical standards were. I haven't changed my expectations. But I am distressed a) that some people apparently never learnmed any standards, and b) there are so many prople out there who think you can legislate morality/ethics. It's a MESS!! out there. Chuck > >I want to thank you for your assistance in this and I look forward to >your responses. > >William R. Tash, PhD >Vice Provost for Research >Temple University >Philadelphia, PA 19122 > > >====================================================================== > 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") >====================================================================== > Herbert B. Chermside, CRA Director, Sponsored Programs Administration Virginia Comonwealth University PO BOX 980568 Richmond, VA 23298-0568 Express Delivery Only: Sanger Hall, Rm. 1-073 11th & Marshall Streets Richmond, VA 23219 Voice: 804-828-6772 Fax 804-828-2521 OFFICE e-mail xxxxxx@VCU.EDU Personal e-mail xxxxxx@vcu.edu http://views.vcu.edu/views/ospa/ ====================================================================== 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") ======================================================================
