Who Might Be Involved in Managing a Conflict of Interest?
Always:
Conflict of Interest Committee. Managing conflicts of interest is the primary
role of the Conflict of Interest Committee. No other individual or office
is authorized by the Conflict of Interest Policy to perform this function.
The Committee may request the assistance of others either in creating the
Management PlanManagement Plan
The document describing the methods by which conflicts of interest will be mitigated or eliminated. or in overseeing
its implementation.
As May Be Appropriate to the Situation:
The sponsored programs office may be asked to provide information about sponsored project funding and conflict of interest disclosures. This information would be used to track the historical record of compliance with sponsor and institutional policy as well as in the implementation of the Management Plan. The sponsored programs office may also be asked to provide copies and/or interpretations of sponsor policies and regulations.
The researcher’s Department Chair may be asked to advise the Committee regarding external consulting arrangements the researcher may have reported or may report in the future.
At some institutions, it may be the Dean who performs the function noted above for the Department Chair.
The General Counsel may or may not be amember of the Conflict of Interest Committee. The General Counsel would be asked to provide legal opinions on such matters as the application of institutional policy as well as statutes such as tax and employment laws.
The sponsorSponsor
The organization providing funds for the project may be asked to verify the existence and/or nature of any consulting
arrangements or other forms of financial remuneration (including equity) that
it has or will provided to the researcher.
When a researcher owns, holds an executive position, or has significant equity in a company that may benefit from the conduct or results of the research, the company may be asked to provide verification of how it may benefit. The company may also be asked to agree to certain actions that may serve to maintain a proper "arms-length" relationship with the institution.
As noted previously, the IRB may be involved in terms of reporting potential conflicts. The IRB may also be asked to provide a report of what actions it has taken when approving the research protocol to ensure that the Management Plan is implemented properly.
