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Disclosure and Management
Conflicts
of interest can be defined as situations in which a divergence
between personal and professional interests might be
perceived,
such that an individual's professional actions might
be
viewed to be influenced by considerations of personal
gain. Conflicts of interest can erode SCIENTIFIC OBJECTIVITY.
In the modern research university, it is impossible to
avoid conflicts of interest. The goal of UR's policies
in this regard is not, therefore, to eliminate all conflicts
but rather to manage them. The key to UR's conflict of
interest process is DISCLOSURE.
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ALL
UR "investigators" are required to submit to their Chair
or Director an annual financial disclosure in accordance
with the Faculty
Policy on Conflict of Committment and Interest).
Investigator is defined as the PI, Co-PI, or any other
person who is responsible for the administration, design,
conduct or reporting of sponsored research. In addition,
as circumstances may arise during the year, any UR personnel
may be required to complete an ad hoc disclosure.
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Conflicts
of commitment, on the other hand, are situations in which
the individual's time and energy are unreasonably diverted
away from his or her primary professional allegiance,
i.e., away from University responsibilities. Conflicts
of commitment are managed in part through limits on the
amount of time that a faculty member may consult
(see the UR's policy on consulting). Consulting
and outside activities can create real benefits for the
faculty member and for the institutions involved; they
can also create conflicts of commitment, and can precipitate
conflicts of interest. In addition to policies governing
faculty, UR has related policies for staff.
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is often difficult to identify a potential conflict
of interest. As noted, disclosure and communication
is the key. You can analyze hypothetical circumstances
in which potential conflicts may present themselves.
The scenario linked here was developed by the National
Academy of Sciences for this purpose. |
Conflict
of Interest (National Academy of Sciences) |
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In
addition to UR requirements, two of UR's largest sponsors
- the National Science Foundation (NSF) and the National
Institutes of Health (NIH) - have their own requirements
for PI disclosures whenever a proposal is submitted to
either agency. Special attention is focused on conflicts
of interest in BIOMEDICAL research, particularly in the
relationships between faculty and pharmaceutical companies
in the conduct of clinical trials.
Faculty
that conduct clinical trials should note that the
level of disclosure of potential financial conflicts
is zero. Additional guidance on the management strategies
may be found in the URMC Guidelines
for Managing Faculty Financial Conflict of Interest:
Clinical Trials.
Any issues related to conflict of interest should
be discussed with your Chair or School Dean. The
University's Conflict of Interest Committee is
an advisory body that can assist both faculty and
academic leaders recommending appropriate steps
to help to manage and mitigate conflict. The School
of Medicine and Dentistry has its own advisory commitee
to the Dean, the Conflict of Interest Advisory group.
The offices of the ORPA and of OTT are also available
to provide advice and assist in the preparation of
conflict management plans. |
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