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Conflict of Interest Policy - Public Health Services (includes NIH) Awards
By Admin (on 5/14/2013 @ 15:54:09, in ORSP Announcements, read 979 times)

In accordance with changes to the Public Health Services (PHS)’ Conflict of Interest (COI) Policy, UNO implemented a supplemental COI policy for individuals holding a PHS (which includes the National Institutes of Health) award, either direct or pass-thru award.  The policy was distributed last year and is attached for reference.  All individuals who meet the definition of an investigator must comply with the policy.  An investigator is defined as:  

 “any UNO individual (including faculty, staff, post docs, graduate assistants and students) who is responsible for the design, conduct, or reporting of Sponsored Research or for the proposal of such Sponsored Research. For the purpose of this Policy, the term includes the following members of the Investigator’s immediate family: children, spouses of children, siblings, spouses of siblings, parents, spouse and spouse’s parents” (taken from the main COI policy which can be found on the COI website, link: http://www.uno.edu/compliance/conflictofinterest.aspx)

 

Someone who meets the definition of an investigator does not have to be listed as a Co-PI with the sponsor.

All investigators must complete the PHS Investigator COI Report.  If the individual is listed as a Co-PI on the routing form, the COI report is completed through the form.  All other investigators must complete and sign the paper report and either email, fax or send it to the Office of Research (attention Carol Mitton).  The report is attached and can be found on the COI website, link above.

In addition to the COI report, all investigators must complete the COI training; this training must be done before beginning work on the project and must be done every four years.  The training is done on-line through SharePoint (training link:  https://sharepoint.uno.edu/research/Conflict%20of%20Interest%20Training/Forms/AllItems.aspx). To begin the training, click Add Document on the COI training page.  Questions or problems with the training can be directed to Carol Mitton at 280-5546 or cmitton@uno.edu.  If students must take the training, their names must be sent to Carol Mitton to ensure they have access to the training site.

To enforce the report and training requirement, all payroll paperwork (101, Form 6) for individuals being paid from a PHS (such as NIH) direct or pass-thru award must include a statement in the comments section as to whether or not the individual meets the definition of an investigator. The paperwork will not be approved by Sponsored Programs Accounting without that statement.

At the time of a new PHS award, the Office of Research will send a separate email to the PI summarizing the policy, informing them whether they need to complete the training, and requesting a list of known individuals who meet the definition of an investigator. If necessary, these individuals will be notified of the COI requirements and asked to comply.  This is being done to minimize the potential of delay in processing their paperwork at a later date.  Attached is a procedure document that identifies the responsibilities of our office, Sponsored Programs Accounting and the PI.

Questions can be directed to Carol Mitton.

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