SUMMARY of Policies and Procedures

 (PDF version available here)

SUMMARY OF POLICIES AND PROCEDURES
RELATED TO CONFLICTS OF INTEREST AND COMMITMENT
University of Arizona
Introduction: Conflicts of Interest exist when an individual’s personal financial relationships could influence the execution of his/her University responsibilities. Conflicts of Commitment exist when an individual’s outside activities could interfere with the execution of his/her University responsibilities. Conflicts are not unethical or evidence of misconduct; rather, conflicts are situations that must be identified and managed to prevent damage to the individual, the research, and the institution.
Who must report to the University?
  • All Covered Individuals, paid or unpaid, and their immediate family members;
  • All graduate students or undergraduate students in a supervisory position.
What should be reported to the University?
  • Salary or other payments from private/for-profit entities for services, including honoraria and consulting income (disclosure is not required if income is received for lectures, seminars, or teaching engagements sponsored by a public or nonprofit entity, or if income is received for service on an advisory committee or review panel of a public or nonprofit entity);
  • Equity interests in outside entities, including stocks, stock options, and other ownership interests (disclosure is not required for financial interests resulting from ownership of shares in a mutual fund or membership in a retirement plan or similar pooled funds if you have no control over the selection of investments);
  • Management positions with outside entities, including membership on the Board of Directors, Scientific Advisory Board, or other officer positions;
  • Intellectual property (IP) rights, including patents, licenses, copyrights, or royalties;
  • Gifts made to an employee or his/her family by an outside entity related to research.
When should an employee report interests to the Office of the Vice President for Research?
  • Submission of a new grant, contract or protocol;
  • Addition of a new investigator on an existing grant, contract or protocol;
  • Changes to an existing financial interest or commitment.
When should an employee report outside interests to their Department Head or Supervisor?
  • Prior to entering into a new consulting relationship;
  • Annual reports to the department should be submitted each year during February.
What happens when an employee reports an outside interest related to research?
  • All disclosures will be reviewed by Conflict of Interest staff.
    • Reports of substantial interests (income >$5000, equity interest >0.1%, gifts totaling over $400, management positions, IP rights) will be forwarded to the Institutional Review Committee (IRC).
    • Reports of any outside interests related to research involving human subjects will be forwarded to the IRC.
  • The IRC will recommend a management strategy to mitigate, reduce, or eliminate conflicts of interest.
  • The VPR will notify the employee of the final determination.
What might the IRC recommend to manage a conflict of interest?
  • Disclosure of the interest in all publications and presentations of the research;
  • Appointment of a third-party oversight committee;
  • Removal of students and trainees from the project;
  • Removal of the PI from the project;
  • Reduction in equity holdings;
  • Rejection of the project funds.
The full policy is posted online at www.vpr.arizona.edu/COI-policy

 

 

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