Presentation on theme: "October 9, 2014 Vanderbilt University Circa: 1901 Photo Courtesy Library of Congress Photo Archives."— Presentation transcript:
October 9, 2014 Vanderbilt University Circa: 1901 Photo Courtesy Library of Congress Photo Archives
Individual conflicts of interest refer to situations in which an individual’s or family member’s financial, professional, or other personal considerations may directly or indirectly affect, or have the appearance of affecting, an individual’s professional judgment in exercising any university duty or responsibility, including the conduct or reporting or research.
The public may lose trust and confidence in Vanderbilt as a hospital, academic center or research institution. Individual and institutional reputations could be harmed. Many research sponsors require it in their contracts or grant terms and conditions. The policy serves to protect BOTH the University’s interests and the interests of the faculty and staff who are disclosing. Nashville Tennessee Newspaper Delivery boys in downtown Nashville; Circa: 1900-1910 Photo Courtesy Library of Congress Archives Nashville Tennessee Collection
Who? Everyone – all VU Faculty and Staff When? Every year and ALSO when your circumstances change Where? Online Web-based system How? Login with your VUNetID and e- password
Personal Interests in Vanderbilt Activities Business Relationships with Vanderbilt Gifts and Contributions University Assets Student Activities Family Members Conflict of Commitment Research Activities
Avoid decisions in which you have a personal interest or an APPEARANCE of a personal interest: Hiring Purchasing Contracting/Consulting Nashville City Hospital Circa: 1890-1910 Photo Courtesy Metropolitan Government Archives of Nashville and Davidson County
Avoid Situations in which you or a family member has a Business Relationship with VU Includes spouse’s, children’s, parents’ businesses Nashville Tennessee Maxwell House Hotel on 4th Ave. Circa: 1890-1910 Photo Courtesy Metropolitan Government Archives of Nashville and Davidson County
No gifts or accommodations may be accepted by the University or individual members of the University if this puts them in a prejudicial or compromising position. USS Nashville Gunboat "I Christen Thee" Circa: 1895 Photo Courtesy Library of Congress Photo Archives
Gifts in support of the institutional mission must be directed through the Development Offices Individuals may accept gifts, meals, entertainment, etc. no greater than $300/year/vendor from NON-HEALTHCARE INDUSTRY sources $0 may be accepted from Healthcare by individuals
Misappropriation or unauthorized use of University assets in connection with external activities not allowed. Assets include: buildings, personnel, equipment, patents, technology, and the University’s reputation. Vanderbilt University Kissam Hall Circa: 1900 Photo Courtesy Library of Congress Photo Archives
Students, postdocs, or other trainees should not be assigned University projects sponsored by a business if the individual or family member has a SFI in the business. Vanderbilt Class of 1912
Members of the University may not participate in the hiring process or employment- related decisions regarding their family members. Members should not be in a position to supervise a family member or review a family member’s work. Downtown View #4 From the State Capitol Circa: 1864 Originally Taken by: George N. Bernard Photo Courtesy Library of Congress Photo Archives
No. You cannot hire, supervise or do job evaluations for a member of your family. If the family member is the only person qualified to do the specific job, another reporting hierarchy must be established.
Distribution of effort between University employment or faculty appointment and commitment to external activities. Staff do not have allotted consulting days and are required to take vacation days for approved consulting time. Time off for Faculty appointed on a nine-month basis should not exceed 40 days (including holidays) during the academic year. Time off for Faculty appointed on a twelve-month basis should not exceed 50 days per year (including holidays). Fort Negley showing Union troops and munitions Circa: Civil War Photo Courtesy Library of Congress Archives
Conflicts of Interest in Research are situations in which Financial, Professional, or Personal considerations may compromise judgment in design, conduct, or reporting of research. Southern Turf Saloon Circa: 1880-1910 Photo Courtesy Library of Congress Archives Nashville Tennessee Collection
You should not be involved in the review, approval or control of the research if you or a family member has a SIGNIFICANT FINANCIAL INTEREST. This is especially important if you are doing Human Subject Research as no research will receive final approval until the conflict of interest is addressed. NSF, PHS, and FDA have specific guidelines regarding conflicts of interest.
The SFI threshold is $5,000. Equity interest in any non-publicly traded company is automatically an SFI. Travel may also be an SFI, so all travel related to your institutional responsibilities must be reported (for PHS-funded faculty/staff only*). There are specific exclusions from SFIs under the PHS regulations. (See the PHS website for more details). Public Accessibility Requirement -Vanderbilt has chosen to provide a written response to any requestor regarding SFIs for faculty/staff with PHS funding. Investigator Training - FCOI training is required for Investigators before engaging in PHS- funded research, every four years thereafter, and immediately under designated circumstances. Many other funding sources now follow the PHS regulations!
Probably. Since you could receive royalties for the licensing (as will Vanderbilt) and if your research will be funded by the same company (or involves the same technology), a management plan is necessary to address this potential conflict of interest. If Human Subjects are involved, the IRB would also have to approve, applying further scrutiny. When in doubt, go ahead and disclose the potential conflict!
Initial Review by the Approver - Senior Associate Dean Cindy Kam has primary oversight of conflict of interest matters in A&S - Sharon Buchanan performs initial reviews and and typically is the first point of contact in the Dean’s Office Second Review performed by the Office of Conflict of Interest and Commitment Management Third Review may be necessary by UCC
Does this disclosure constitute a conflict of interest? If it is a conflict, can it be managed? If it can be managed, what requirements should the management plan contain? Conflicts that cannot be managed are presented to the UCC for resolution (ie cease and desist or other actions).
Plans are put into place to limit the risks to the University and the faculty/staff member with the conflict. Having a “conflict” does not necessarily mean an activity is prohibited. In many cases, all that is needed is a management plan. Initial oversight of all management plans remains a duty of the approver. Questions about implementation of a management plan may be brought to the COI Office at any time.