Research OSPA:Conflict Of Interest (COI) Process

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Effective Date

September 1, 2013

Statement of the Issue

Office of Sponsored Projects (OSP’s) role in assuring that PIs submitting grant proposals are in compliance with Office of Research conflict of interest (COI) policies.

Applicable Policy/Regulation

The U.S. Public Health Service (42CFR Part 50) and the National Science Foundation (GPM310) have issued regulations and policies requiring institutions that apply for research funding to assume responsibility for ensuring that the financial interests of the employees of the institution do not compromise the objectivity with which such research is designed, conducted, or reported. (See <a class="wiki external" target="_blank" data-cke-saved-href="http://provost.utdallas.edu/policy/utdpp1029" href="http://provost.utdallas.edu/policy/utdpp1029" rel="external">UTD policy statement</a>.)The Research Investigator Financial Disclosure must be completed by all UT Dallas faculty, principal investigators (PI) and co-principal investigators (Co-PIs), on external grants and contracts, and individuals who have a significant financial interest in an entity in which the university conducts research, development, or scholarship related business.For additional information, see the <a class="wiki external" target="_blank" data-cke-saved-href="http://www.gpo.gov/fdsys/granule/CFR-2014-title2-vol1/CFR-2014-title2-vol1-sec200-112" href="http://www.gpo.gov/fdsys/granule/CFR-2014-title2-vol1/CFR-2014-title2-vol1-sec200-112" rel="external">Office of Management and Budget (OMB) Uniform Guidance, 2 CFR 200.112 – Conflict of Interest</a> and the <a class="wiki external" target="_blank" data-cke-saved-href="http://grants.nih.gov/grants/policy/coi/" href="http://grants.nih.gov/grants/policy/coi/" rel="external">National Institutes of Health policy</a> and the <a class="wiki external" target="_blank" data-cke-saved-href="http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/aag_4.jsp" href="http://www.nsf.gov/pubs/policydocs/pappguide/nsf15001/aag_4.jsp" rel="external">National Science Foundation policy</a>.

Process

A. Proposals

  1. All proposals submitted to Public Health Service (PHS) sponsors require Principal Investigators (PI) to have a current conflict of interest (COI) on file prior to submission of a proposal. All proposals must have a complete COI check prior to completing the file.
  2. When a Grants Specialist is notified of a proposal submission, the Grants Specialist will check the Conflict of Interest spreadsheet on the G: drive, under the Office of Research Compliance (ORC), to see if a current COI is on file for all PIs and Co-PIs.
  3. If the PI/Co-PI does not have a current COI, the Grants Specialist will notify the Conflict of Interest Manager in the ORC, who will work with the PI/Co-PI to obtain the necessary forms and approvals.
  4. Once a conflict of interest is on file, the certification tab in the Proposal Module in Peoplesoft will need to be updated with the COI information: Certification Code = ‘COI’; Indicator = ‘Yes’; Expiration Date will coincide with the expiration date in the ORC spreadsheet on the G: drive.

B. Awards

  1. When an award is received, the Grants Specialist will check the Conflict of Interest spreadsheet on the G: drive, under the ORC, to see if a current COI is on file for all PIs/Co-PIs.
  2. If the PI/Co-PI does not have a current conflict of interest, the Grants Specialist will notify the Conflict of Interest Specialist in the ORC, who will work with the PI/Co-PI to obtain the necessary forms and approvals.
  3. Once a conflict of interest is on file, the certification tab in the Proposal Module in PeopleSoft will need to be updated with the COI information: Certification Code = ‘COI’; Indicator = ‘Yes’; Expiration Date will coincide with the expiration date in the ORC spreadsheet on the G: drive.

For additional information, refer to the Office of Research Compliance process for <a class="wiki external" target="_blank" data-cke-saved-href="http://www.utdallas.edu/research/orc/conflict_of_interest/" href="http://www.utdallas.edu/research/orc/conflict_of_interest/" rel="external">Conflict of Interest</a>.

Definitions

A. Conflict of Interest means anything of monetary value, including but not limited to:

  1. salaries or other payments for services (e.g. consulting fees or honoraria);
  2. equity interests (e.g., stocks, stock options or other ownership interests); and,
  3. intellectual property rights (e.g., patents, copyrights and royalties from such rights).
  4. The term does not include:
    1. salaries, royalties, or other remuneration from UTD;
    2. income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
    3. income from service on advisory committees or review panels for public or nonprofit entities; or,
    4. financial interests in business enterprises or entities if the value of such interest does not exceed $10,000 per annum in salary, fees or other continuing payments or represent more than a five percent (5%) ownership interest for any one enterprise or entity when aggregated for the Investigator and the Investigator's spouse and dependent children.

B. Public Health Service (PHS) is part of the Department of Health and Human Services and includes the Agency for Healthcare Research and Quality (AHRQ), Centers for Disease Control (CDC), Federal Drug Administration (FDA), Substance Abuse and Mental Health Services Administration (SAMHSA), Health Resources and Services Administration (HRSA), and the National Institutes of Health (NIH).C. Uniform Guidance - In effect December 26, 2014 and published by the federal Office of Management and Budget (OMB), this guidance supersedes and streamlines requirements from OMB Circulars A-21, A-87, A-110, and A-122; Circulars A-89, A-102, and A-133; and the guidance in Circular A-50 on Single Audit Act follow-up. This guidance provides a governmentwide framework for grants management which will be complemented by additional efforts to strengthen program outcomes through innovative and effective use of grant-making models, performance metrics, and evaluation. <a class="wiki external" target="_blank" data-cke-saved-href="http://www.whitehouse.gov/omb/grants_docs" href="http://www.whitehouse.gov/omb/grants_docs" rel="external">http://www.whitehouse.gov/omb/grants_docs</a>