Office of Research and Project Administration

SPONSORED PROGRAMS COMPLIANCE

4. Conflicts of Interest

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 Form. The deadline for submission to the relevant supervisor is March 1st of each year. If an individual has indicated multiple appointments on the form, a copy should be provided to all respective departments.

The Department Chair (or equivalent counterpart) should review the completed forms for any potential conflicts. Any forms indicating potential conflicts would be referred to the Dean (or equivalent counterpart) for appropriate action (i.e. approval of a conflict management plan developed by the conflicted individual); the Chair would retain all others. All disclosure forms, conflict management plans, and related documents should be retained for a period of five years after the completion of the relevant research or after the conflict has ended.

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.
Maintain a log of individuals for which a form is required and document when received; follow up with any that are delinquent.
Provide copies of the disclosure form to those departments indicated as secondary appointments.
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.
Ensure record retention policies regarding these documents are adhered to.
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. mailing, distributing).
Assist in the completion of an annual summary report that may be required by the Dean's Office.