May 6, 2009 - New Financial Conflict of Interest Policy

To: All Principal Investigators
From: Rich Linton, Vice President for Research and Graduate Studies
Subject: New Financial Conflict of Interest Policy

Background: In January of this year, UO Senate President Paul van Donkelaar charged a small ad hoc committee to review and suggest changes to the draft UO Conflict of Interest and Commitment (COI-C) policy. During the early stages of the committee's work, the consideration of policies related to Conflict of Commitment (COC) was referred to a Joint Academic Affairs/UO Senate COC Working Group. Similarly, state financial conflict of interest requirements, especially as they relate to procurement, are being addressed by the Purchasing and Contracting Policy Committee,
http://ba.uoregon.edu/ProcurementContracting/PCS%20Policy%202009.htm.

Ad hoc Committee: The efforts of the ad hoc committee specifically focused on policies to identify and manage significant financial conflicts of interest in compliance with federal regulations supporting the ethical conduct of research and other sponsored programs
(http://www.uoregon.edu/~uosenate/dirsen089/COICOCC.html.)

Following several months of careful and collegial work by the ad hoc committee, the new Financial Conflict of Interest Disclosure and Management for Investigators in Externally Sponsored Programs policy was endorsed by the UO Senate on April 8, 2009.

I sincerely appreciate the work of the ad hoc committee, chaired by John Bonine, in bringing forward an excellent policy on FCOI, and the constructive input from various faculty and staff in this important process.

New Policy Requirements: The new policy is focused on the disclosure, management, and resolution of significant financial interests and requires annual disclosure by Principal Investigators (Pis) and those individuals the Pis designate as responsible for the design, conduct, and reporting of their sponsored program at the UO. Beginning May 4, 2009, Principal Investigators will indicate 'responsible' individuals through the Electronic Proposal Clearance System (E-PCS) during the proposal submission process to ORSA.

The new FCOI Annual Disclosure Form, due May 1st of each year, is one page in length and asks only one question to establish whether a significant financial interest exists. If so, a more detailed FCOI Disclosure Attachment (2 pages) must be submitted to address federal requirements. For this year, implementation begins today, May 4, and continues throughout the month of May.

Additional Information and Assistance: Please share this Conflict of Interest update with all faculty members involved with sponsored research or programs. The policy and forms may be viewed and downloaded from the Office for Responsible Conduct of Research (ORCR) web site at: http://orcr.uoregon.edu.

For additional help, you may contact:

• Catherine Coyle, Compliance Coordinator, ccoyle@uoregon.edu
• Meg Rowles, Assistant Director, ORCR, mrowles@uoregon.edu
• Lynette Schenkel, Assistant Vice President, Responsible Conduct of Research, schenkel@uoregon.edu.

Your cooperation is greatly appreciated

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