Revised Conflict of Interest Policy
Date: August 10, 2012
To: All Faculty and Staff
From: Anthony A. Ferrara, CPA, MAS
Vice Chancellor / Chief Financial Officer
Subject: REVISED Conflicts of Interest Procedure
Effective Date – August 24, 2012
The Health Science Center (HSC) is implementing a new COI procedure that resulted from a change in NIH policy which states that an institution applying for or receiving NIH funding from a grant or cooperative agreement must be in compliance with all of the revised regulatory requirements no later than August 24, 2012. The new procedure applies to proposed or currently funded sponsored projects. It establishes an organizational conflicts of interest policy, provides personnel and HSC reporting requirements, and sets enforcement, penalties, and remedies for failure to comply.
NOTE: It is imperative that all Investigators meet the following requirements since the HSC must certify in each application for funding that it has fully complied with all regulations. In addition, PRIOR to the HSC's expenditure of ANY funds under a sponsored project, the HSC must provide to the Awarding Agency a financial conflict of interest report regarding any Investigator's financial interest found by the HSC to be conflicting and ensure that the HSC has implemented a management plan.
At this time, personnel who are not involved in any sponsored activities do not need to complete the new Outside Interest Disclosure Form. Further instructions will be sent out at a later time.
Personnel subject to this procedure include:
- ALL full-time faculty and staff regardless of their involvement in Sponsored Activities;
- Any and all other (e.g. part-time, affiliated, volunteer, adjuncts, etc.) faculty and staff (including post docs) who are involved (with or without compensation) in a proposed or funded Sponsored Activity; and
- Undergraduate, graduate or professional students (including residents and fellows) who are involved (with or without compensation) in any proposed or funded Sponsored Activity.
Some of the major changes are as follows:
- Significant Financial interests (SFI) threshold - The minimum threshold for disclosure has been reduced to $5,000, applies to payments for services and equity interests, and includes any equity interest in non-publicly traded entities.
- Excluded from disclosure requirement - Income from seminars, lectures, or teaching engagements paid for by a federal, state, or local government agency, or an institution of higher education.
- Travel reimbursements and sponsored travel – Personnel must disclose any reimbursed travel or sponsored travel related to Institutional responsibilities (including purpose of trip, sponsor/organizer, destination, and duration).
- COI Training - All Personnel must complete training prior to engaging in any sponsored projects and at least every three years thereafter.
All Investigators who are planning to submit grant/contract applications or those who will receive new funding from current projects on or after August 24, 2012 are required to:
- Complete training prior to engaging in activities related to any sponsored activity. The primary source of training will be conducted through the Collaborative Institutional Training Initiative (CITI) - The CITI Program offers a conflict of interest mini-course that provides training in regulations related to financial conflict of interests. The HSC has requested that CITI add this course to their current modules. However, until CITI completes this process, the Investigator should use the NIH Web Based Tutorial. At the end of the tutorial, please complete and print the "Certificate of Completion" and send it to Finance & Operations, 300 Hyman (Attn: Melanie Burlison). We will notify the campus when the CITI training is available.
- Complete the Outside Interests Disclosure Form and send it to Finance & Operations, 300 Hyman (Attn: Melanie Burlison). Please make sure your department head or immediate supervisor has completed their section on the last page of the form. We are in the process of looking for a more efficient system with a clickable form and database and will notify the campus when such a system is available.
- Updated Campus Procedure for Conflict of Interest (F125) - Effective Aug. 24, 2012
- Updated Outside Interests Disclosure Form
Finance and Operations
62 South Dunlap
Memphis, TN 38163