conflict of interest policy & disclosure process

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Member Overview Conflict of Interest Policy & Disclosure Process

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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 Presentation

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Page 1: Conflict of Interest Policy & Disclosure Process

Member Overview

Conflict of InterestPolicy & Disclosure Process

Page 2: Conflict of Interest Policy & Disclosure Process

Purpose

● Overview of the Conflict of Interest Policy

● Requirements for Disclosure

● Steps in the Disclosure Process

Page 3: Conflict of Interest Policy & 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

Page 4: Conflict of Interest Policy & Disclosure Process

Members

Faculty Staff

Post-Doctoral Scholars Students

Members

In a position to influence or commit University resources

Page 5: Conflict of Interest Policy & Disclosure Process

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

Page 6: Conflict of Interest Policy & Disclosure Process

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

Page 7: Conflict of Interest Policy & Disclosure Process

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

Page 8: Conflict of Interest Policy & Disclosure Process

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

Page 9: Conflict of Interest Policy & Disclosure Process

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

Page 10: Conflict of Interest Policy & Disclosure Process

Disclosure Process Overview

Individual Completes

Disclosure On-line

Designated Reviewer Evaluates Disclosure

Reviewer Creates

Management Plan

University Conflicts

Committee Reviews

Oversight by Responsible

Parties

Page 11: Conflict of Interest Policy & Disclosure Process

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

Page 12: Conflict of Interest Policy & Disclosure Process

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

Page 13: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Log-in screen:

Page 14: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 15: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 16: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 17: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 18: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 19: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 20: Conflict of Interest Policy & Disclosure Process

Disclosure

Disclosure

Review

PlanUCC

Oversight

Page 21: Conflict of Interest Policy & Disclosure Process

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

Page 22: Conflict of Interest Policy & Disclosure Process

Reviewer Evaluation

Disclosure

Review

PlanUCC

Oversight

Disclosure Questionnaire

• 15 days

All Negative Responses

• 15 days

Disclosure Process

Complete

Member

Reviewer

System

Page 23: Conflict of Interest Policy & Disclosure Process

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

Page 24: Conflict of Interest Policy & Disclosure Process

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

Page 25: Conflict of Interest Policy & Disclosure Process

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

Page 26: Conflict of Interest Policy & Disclosure Process

Management Plan

Disclosure

Review

PlanUCC

Oversight

Page 27: Conflict of Interest Policy & Disclosure Process

Management Plan

Disclosure

Review

PlanUCC

Oversight

Page 28: Conflict of Interest Policy & Disclosure Process

Management Plan

Disclosure

Review

PlanUCC

Oversight

Page 29: Conflict of Interest Policy & Disclosure Process

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

Page 30: Conflict of Interest Policy & Disclosure Process

Oversight

Disclosure

Review

PlanUCC

Oversight

12 months

Reviewer

Oversight Manager

Member

Management Plan

Page 31: Conflict of Interest Policy & Disclosure Process

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

Page 32: Conflict of Interest Policy & Disclosure Process

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