Enhancing Conflict of Interest Disclosure Processes
Changes to conflict of interest disclosures aim to reduce liabilities, clarify requirements, and improve operational efficiency in research. Reasons for the changes include helping employees comply with policies and state ethics laws, and institutional implications. Implementation plans target an annual disclosure process for all employees to address potential conflicts related to board roles, financial interests, personal relationships, and more. Guidelines for management plans are provided if conflicts are identified, with Research Integrity overseeing research-specific plans. The role of Research Integrity involves collecting and monitoring all research disclosures, coordinating management plans, and providing support to investigators and research administrators.
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Presentation Transcript
Office of Audit, Compliance & Privacy Office of the Vice President for Research
Changes to Conflict of Interest Disclosures Goals Reduce employee, investigator & institutional liability Clarify disclosure requirements Streamline & Standardize Improve operational efficiency in research disclosures
Reasons for changes University wide COI/COC disclosure Help employees avoid violations of AU Policy Comply with AL State Ethics Law R1 status and elevated profile Institutional implications & central monitoring Capture ALL research disclosures (PHS, NSF, other) in the general employee disclosure.
Implementation Plans Target start date October 1, 2019 ALL employees disclose annually Researchers will complete one disclosure annually that satisfies research COI requirements and Auburn COI requirements Update new SFI, COI, or COC within 30 days Research Integrity will address research specific COI OACP and Research Integrity will collaborate as needed for Management plans
Disclosures ALL Fulltime Employees disclose: 1. Board/leadership roles, financial interests in business entity or related to AU expertise/responsibilities Applicable Research related SFIs 2. Outside employment/professional activities (w/in 12 mo.) 3. Personal relationships that could affect administrative decisions (employment, pay, purchasing, etc.) 4. Immediate family working at AU (AUM, AAES, ACES) 5. Any other potential conflicts of interest
Management Plans If conflict identified that needs management, employee and supervisor will be notified via email Template management plans and guidance provided One management plan per employee as needed Supervisor work with employee to tailor to that situation Periodically review and monitor to ensure plan is followed Research Integrity develops plans related to research only COI
Role of Research Integrity Collect & monitor all Research SFI disclosures (PHS, NSF, other) Coordinate COI management plans with OACP Communicate directly with investigators if desired Resource & support for CLDs, other research admins, & faculty
Role of Compliance & Privacy Collect & monitor all COI disclosures Implement management plans as needed Communicate with employees and supervisors Resource & support for staff, A&P, faculty, admin Consult University COI Committee as needed Preserve public trust in Auburn University operations Promote a culture of compliance and ethics at AU
