Hi Sheryl, The University of Washington has a “Policy Regarding Regent Conflicts of Interest<http://www.washington.edu/admin/rules/policies/BRG/RP13.html>,” that will meet the institutional definition you’ve supplied (although it does not apply to senior management or other UW entities, beyond the University President). We have another policy for individual employee conflicts of interest.
My best, Rebecca Rebecca Goodwin Deardorff Director of Rules Coordination Office of the President Box 351210 Seattle, WA 98195 206-543-9219 www.washington.edu/rules [http://www.washington.edu/marketing/e-communications/wsignature.gif] From: [email protected] [mailto:[email protected]] On Behalf Of Rippke, Sheryl L [U CSL] Sent: Wednesday, December 10, 2014 3:02 PM To: Association of College and University Policy Administrators Subject: RE: [acupa-l] Institutional Conflicts of Interest Policy Thanks, Theresa. Your policy is an individual COI policy. Here’s a definition from COGR’s “Approaches to Developing an Institutional Conflict of Interest Policy” http://www.cogr.edu/Pubs_Conflicts.cfm In its examination of financial conflicts of interest, the AAU defined conflicts of interest as: The term individual financial conflict of interest in science refers to situations in which financial considerations may compromise, or have the appearance of compromising, an investigator’s professional judgment in conducting or reporting research. The bias such conflicts may conceivably impart not only affects collection, analysis, and interpretation of data, but also the hiring of staff, procurement of materials, sharing of results, choice of protocol, involvement of human participants, and the use of statistical methods. In discussing institutional conflicts of interest AAU sets its definition in the context of how these conflicts may occur: An institutional financial conflict of interest may occur when the institution, any of its senior management or trustees, or a department, school, or other sub-unit, or an affiliated foundation or organization, has an external relationship or financial interest in a company that itself has a financial interest in a faculty research project. Senior managers or trustees may also have conflicts when they serve on the boards of (or otherwise have an official relationship with) organizations that have significant commercial transactions with the university. The existence (or appearance) of such conflicts can lead to actual bias, or suspicion about possible bias, in the review or conduct of research at the university. If they are not evaluated or managed, they may result in choices or actions that are incongruent with the missions, obligations, or the values of the university. Not nearly as many universities have institutional COI policies as individual COI policies! Sheryl Rippke Policy Administrator 4-1385 From: [email protected]<mailto:[email protected]> [mailto:[email protected]] On Behalf Of Theresa Rowe Sent: Wednesday, December 10, 2014 3:48 PM To: Association of College and University Policy Administrators Subject: Re: [acupa-l] Institutional Conflicts of Interest Policy I'm not sure what you mean by "institutional" conflict of interest. Our policy is here: http://www.oakland.edu/policies/406/ It was written by attorneys working with our publicly appointed Board of Trustees, written to be compliant with specific State of Michigan legislation, and is only updated when initiated by that body. Theresa On Wed, Dec 10, 2014 at 4:13 PM, Rippke, Sheryl L [U CSL] <[email protected]<mailto:[email protected]>> wrote: Good afternoon, ACUPA, Does your institution have an Institutional Conflicts of Interest Policy (as opposed to the usual personal COI policy)? If so, could you send me a link to or file of it? I would also welcome any commentary about the policy’s adoption, compliance efforts, special challenges, etc. Our interest is prompted by the OMB Uniform Guidance, Subpart D § 200.318(c)(2), which says we “must maintain written standards of conduct covering organizational conflicts of interest.” Thanks! Sheryl Sheryl Rippke, Policy Administrator Office of University Counsel Iowa State University 3550 Beardshear Hall Ames, IA 50014 515-294-1385 [email protected]<mailto:[email protected]> Policy Library<http://policy.iastate.edu/> ATTN: Please be aware that when you respond to an ACUPA-L e-mail, the reply will be distributed to the ENTIRE list of members. If you do NOT want to send an e-mail to everyone, please reply directly to the individual who initiated the query (their e-mail address appears in the "From" line of their original e-mail). If you wish to remove yourself from the ACUPA e-mail list, please go to the following website and complete the form. We will remove you from the list within 24 hours, during normal business hours. http://www.acupa.org/MembershipForm_Discontinue.html If you have questions about the ACUPA e-list, please contact Jamie Parris at [email protected]<mailto:[email protected]?subject=ACUPA%20e-list%20assistance> or 607-255-6837. -- Theresa Rowe Chief Information Officer Oakland University ATTN: Please be aware that when you respond to an ACUPA-L e-mail, the reply will be distributed to the ENTIRE list of members. If you do NOT want to send an e-mail to everyone, please reply directly to the individual who initiated the query (their e-mail address appears in the "From" line of their original e-mail). If you wish to remove yourself from the ACUPA e-mail list, please go to the following website and complete the form. We will remove you from the list within 24 hours, during normal business hours. http://www.acupa.org/MembershipForm_Discontinue.html If you have questions about the ACUPA e-list, please contact Jamie Parris at [email protected]<mailto:[email protected]?subject=ACUPA%20e-list%20assistance> or 607-255-6837. ATTN: Please be aware that when you respond to an ACUPA-L e-mail, the reply will be distributed to the ENTIRE list of members. If you do NOT want to send an e-mail to everyone, please reply directly to the individual who initiated the query (their e-mail address appears in the "From" line of their original e-mail). If you wish to remove yourself from the ACUPA e-mail list, please go to the following website and complete the form. We will remove you from the list within 24 hours, during normal business hours. http://www.acupa.org/MembershipForm_Discontinue.html If you have questions about the ACUPA e-list, please contact Jamie Parris at [email protected]<mailto:[email protected]?subject=ACUPA%20e-list%20assistance> or 607-255-6837.
