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Disclosure of Conflicts of Interest and Commitment

Disclosure of Conflicts of Interest and Commitment. Why do we collect COI disclosures, and from whom do we collect? A note about our system of collection, and how it came to be that way

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Disclosure of Conflicts of Interest and Commitment

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  1. Disclosure of Conflicts of Interest and Commitment • Why do we collect COI disclosures, and from whom do we collect? • A note about our system of collection, and how it came to be that way • Authority to collect disclosures is established by the Conflicts Policy, which charges University Conflicts Committee with implementation. • Resource: Conflicts Policy http://www.policy.cornell.edu/Conflicts_Policy.cfm

  2. COI Statistics • In 2003, our compliance rate was 98.2 percent. There about 3,500 filings, and only 39 non-respondents; none with current grants or contracts. • Fourteen percent of the filers also submitted a part II form, resulting in 17 managed conflicts. • The 2004 season has just closed, and the current compliance and part II filing trends look about the same.

  3. COI Process • Roles and Responsibilities -Dean of Faculty & Vice Provost for Research -Deans and Designated Representatives -Department Chairs • Resource: Administrative Procedures, COIhttp://web.cornell.edu/UniversityFaculty/docs/2004ConflictsProcess/AdminProcedures/2004.pdf

  4. Collection of COI Data • Part I form, available electronically and in paper • Part II form, available only in paper • Resource: University Faculty website has electronic copies of Part I and Part II forms, http://web.cornell.edu/UniversityFaculty/

  5. Review of Part II Forms • Review of Part II forms is different in each college, and ranges in complexity from one person reading form to full committee review • Management of Part II forms is similarly specific to the colleges • Resources: -Guidance for Department Chairs -Attachment A of the Cornell Conflicts Policy

  6. Reporting of COI Data • Designated Representatives in the Colleges report to Vice Provost Richardson by mid-June. • Two status reports are posted to Sponsored Program Services on July 1. • Report 1: Status with regard to the policy: list of personnel and whether they are in compliance or not. • Report 2: Status of Part II filers: includes list of personnel with managed conflicts and the name of the manager of the conflict.

  7. What happens when someone is not in compliance with COI policy? • SPS will neither submit sponsored project proposals nor accept funding awards for individuals who have not filed an annual disclosure statement. • Just-in-time filing of COI disclosures is discouraged, but is a solution when a proposal needs to go out the door. Remember, however, that the filing must be reviewed and recorded before SPS can move forward.

  8. Impact of New Compliance Office on COI Process • Office of Research Integrity and Assurance (ORIA), will be staffed with a director, associate director, and several staff members. It will manage several compliance functions, including conflicts of interest. • It is likely that the system of collection of annual disclosures of conflicts of interest and conflicts of commitment will change. • Questions?

  9. Contact Information Lesley Yorke Office of the Vice Provost for Research 222 Day Hall; 4-4906 LAB14@cornell.edu

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