conflict of interest policy & disclosure process
DESCRIPTION
Conflict of Interest Policy & Disclosure Process. Member Overview. Purpose. ● Overview of the Conflict of Interest Policy ● Requirements for Disclosure ● Steps in the Disclosure P rocess. Policy. IRS Requirement: - PowerPoint PPT PresentationTRANSCRIPT
Member Overview
Conflict of InterestPolicy & 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 #1A 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 #2A 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 E-mail Notification - 15 days to complete
Link Directly in E-mail or:www.conflictpolicy.disclosure.nd.edu
Update Disclosure - within 15 days
www.conflictpolicy.disclosure.nd.edu
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
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
Disclosure
Review
PlanUCC
Oversight
Log-in screen:
Disclosure
Disclosure
Review
PlanUCC
Oversight
Disclosure
Disclosure
Review
PlanUCC
Oversight
Disclosure
Disclosure
Review
PlanUCC
Oversight
Disclosure
Disclosure
Review
PlanUCC
Oversight
Disclosure
Disclosure
Review
PlanUCC
Oversight
Disclosure
Disclosure
Review
PlanUCC
Oversight
Disclosure
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
When a Disclosure is from a Faculty Member, the Reviewer may elect to forward the Faculty Member’s disclosure to the Faculty Conflict Committee (FCC) for review. For additional information on the FCC, refer to the COI policy at http://policy.nd.edu
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 #1A 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 PlanThe 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 #2A 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
E-mail notice annually
Updates on-line
Quick review
Timely follow-up
Communication
Integrity
Additional Resources
Please contact: Office of the General Counsel 631-6411 or [email protected]
● Select in top right corner or visit: http://conflictpolicy.nd.edu1 - Power point slides with narrative comments2 - Navigation Guide3 - Disclosure Guide
Any technical questions regarding the disclosure system may be directed to the OIT Help Desk at 631-8111
Visit http://policy.nd.edu/ to view the University Conflict of Interest Policy in its entirety