Member Overview Conflict of Interest Policy & Disclosure Process

Purpose ● Overview of the Conflict of Interest Policy ● Requirements for Disclosure ● Steps in the Disclosure Process

Policy IRS Requirement: – Policy with guidelines and principles for reporting and managing actual, potential and perceived Conflicts of Interest Policy approved September, 2009 Assists faculty, staff and students in maintaining the highest level of integrity in all University endeavors

Members Faculty Staff Post-Doctoral Scholars Students Members In a position to influence or commit University resources

Definition An actual Conflict of Interest arises in a situation where financial or other personal or professional considerations compromise an individual’s: Objectivity Professional Judgment Professional Integrity Ability to perform responsibilities to the University

Issues Gray areas: Potential or Perceived Conflicts of Interest Could appear to others to be a Conflict of Interest Individual, Individual’s family or close relation University commitment to address proactively Eliminate anyone’s integrity from being questioned

Faculty Example Scenario #1 A faculty member involved in sponsored research has a significant financial interest in an entity who stands to gain from the outcome of the sponsored project ● Objectivity ● Professional Integrity

Staff Example Scenario #2 A staff member is to take part in the evaluation and selection of a supplier from a number of bidders. One of the bidding companies is operated by the person’s family member. ● Objectivity ● Professional Judgment

Office of General Counsel Facilitates the Conflict of Interest Disclosure and Management Process Maintains an electronic disclosure system Serves as a resource for the University community

Disclosure Process Overview Individual Completes Disclosure On-line Designated Reviewer Evaluates Disclosure Reviewer Creates Management Plan University Conflicts Committee Reviews Oversight by Responsible Parties

Disclosure Member Disclosure Requirements Access to Electronic Disclosure Annual Notification - 15 days to complete Link Directly in or: Update Disclosure - within 15 days Disclosure Review PlanUCC Oversight To an existing actual, perceived or potential Conflict of Interest When a new interest or activity is identified that may create an actual, perceived or potential Conflict of Interest

Disclosure Review PlanUCC Oversight Update Disclosure examples: Acquiring a new financial interest in a third party entity Proposing new research where the Cayuse system identifies a need for an update Serving in a new capacity at the University where the individual’s interest and activities now may pose a Conflict of Interest

Disclosure Review PlanUCC Oversight Log-in screen :

Disclosure Review PlanUCC Oversight

Disclosure Review PlanUCC Oversight

Disclosure Review PlanUCC Oversight

Disclosure Review PlanUCC Oversight

Disclosure Review PlanUCC Oversight

Disclosure Review PlanUCC Oversight

Disclosure Review PlanUCC Oversight

Reviewer Evaluation Disclosure Review PlanUCC Oversight Reviewer Responsible for: ● Ensuring full and accurate information ● Identifying any actual, potential or perceived conflicts of interest ● Recommending a plan to the UCC to manage any conflicts

Reviewer Evaluation Disclosure Review PlanUCC Oversight Disclosure Questionnaire 15 days All Negative Responses 15 days Disclosure Process Complete Member Reviewer System

Reviewer Evaluation Disclosure Review PlanUCC Oversight Disclosure Questionnaire Up to15 days to complete Any Affirmative Responses Up to15 days to complete Management Plan Typically 1 week Response Up to 30 days Member Reviewer Reviewer and Member University Conflicts Committee

Management Plan Disclosure Review PlanUCC Oversight Scenario #1 A faculty member involved in sponsored research has a significant financial interest in an entity who stands to gain from the outcome of the sponsored project Management Plan The faculty member has parameters in the involvement of the research, additional oversight by faculty without a financial interest, or other steps to eliminate the conflict. Manage, Reduce, Eliminate

Management Plan Disclosure Review PlanUCC Oversight Scenario #2 A staff member is to take part in the evaluation and selection of a supplier from a number of bidders. One of the bidding companies is operated by the staff member’s family member Management Plan The staff member does not take part in the selection and evaluation process that involves her family’s company Manage, Reduce, Eliminate

Management Plan Disclosure Review PlanUCC Oversight

Management Plan Disclosure Review PlanUCC Oversight

Management Plan Disclosure Review PlanUCC Oversight

UCC Review University Conflicts Committee Executive VP; Provost; VP for Research; VP & General Counsel Ensures Proper Management of all COI’s Oversees Training, Education and Policy Modifications UCC will determine whether an actual, perceived or potential Conflict of Interest exists UCC will approve, amend or veto the proposed Management Plan within 30 days Disclosure Review PlanUCC Oversight Request for reconsideration within 15 calendar days Subsequent decision of UCC is final

Oversight Disclosure Review PlanUCC Oversight 12 months Reviewer Oversight Manager Member Management Plan

Disclosure Process Individual Completes Disclosure On-line Designated Reviewer Evaluates Disclosure Reviewer Creates Management Plan University Conflicts Committee Reviews Oversight by Responsible Parties No paper form notice annually Updates on-line Quick review Timely follow-up Communication Integrity

Additional Resources Please contact: Office of the General Counsel or ● Select in top right corner or visit: Power point slides with narrative comments 2 - Navigation Guide 3 - Disclosure Guide Any technical questions regarding the disclosure system may be directed to the OIT Help Desk at Visit to view the University Conflict of Interest Policy in its entiretyhttp://policy.nd.edu/