Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

4. Conflicts of Interest (COI)

Administrative Responsibilities/Issues:

The University of Rochester's (UR) Faculty Policy on Conflict of Commitment and Interest (http://www.rochester.edu/ORPA/policies/coipolicy.pdf) applies to all members of the UR faculty, students, post-doctoral fellows, residents, and staff. On an annual basis, faculty and investigators (defined as "any person who is responsible for the administration, design, conduct, or reporting of sponsored research; research involving the use of University resources not generally available; internally funded research that involves human subjects; or proposals for funding) are required to submit a University of Rochester Conflict Disclosure Survey. The deadline for completion is March 1st of each year. If an individual has multiple appointments, a copy should be provided to all respective departments.

The University of Rochester has transitioned to an electronic COI survey. Chairs have access to the completed surveys for their departmental faculty, and should review them. All surveys indicating a positive response are reviewed centrally, and those surveys that report significant financial interests relating to an investigator's responsibilities are reviewed by the Dean (or the Dean's conflict of interest committee). The Dean determines whether the financial interest constitutes a financial conflict of interest and whether that can be managed. For those conflicts that require management, a formal conflict of interest plan will be developed and signed by the faculty member. Once the Dean signs the plan, copies will be distributed to the investigator and his/her Chair. The COI system will store the completed surveys in accordance with University and Federal retention requirements.

Although the ultimate responsibilities for the disclosure process rest with the Dean and Chair (or equivalent counterpart), often the administrator can assist with the administrative logistics of the process by performing the following activities:

• Provide a timely reminder to the appropriate supervisor of the annual submission deadline.
  
  
• Be cognizant of situations that may require ad hoc disclosure (i.e. personnel new to the department); bring to the attention of the appropriate individuals.
  
  
• To the extent permitted by law, all disclosure forms, conflict management plans, and related information will be confidential, therefore, use the appropriate discretion when handling (i.e. distributing).