IRB, Office of Research Development COOK COUNTY BUREAU OF HEALTH SERVICES
Office of Research Development

      
Friday, Nov 20, 2009
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FEDERAL FUNDERS ISSUE CONFLICT OF INTEREST REGULATIONS
 
The emergence of biotechnological techniques with huge potential for commercial applications has caused concern about researchers' objectivity when their own financial interests may be at stake. As of October 1, 1995, all institutions receiving research funds from the Department of Health and Human Services or the National Science Foundation must have policy and procedures to insure that research is not biased by financial conflicts. The following is a summary of the regulation:

All Investigators Must Disclose Significant Financial Interests

An "Investigator" means the principal investigator and any other person who is responsible for the design, conduct, or reporting of research. For purposes of determining financial interests, the Investigator's interests include those of his/her spouse and dependent children.

What Constitutes a Significant Financial Interest?

Significant Financial Interest means anything of monetary value, including but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interests (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).

Financial interests which are subject to reporting for any given research proposal include those which would reasonably appear to be affected by the specific research proposed; and/or are interests in entities whose financial interests would reasonably appear to be affected by the research.

The term "Significant Financial Interest" does NOT include:

  • Salary, royalties, or other remuneration from the applicant institution;
  • Any ownership interests in the institution, if the institution is an applicant under the Small Business Innovation Research Program;
  • Income from seminars, lectures, or teaching engagements sponsored by public or nonprofit entities;
  • Income from service on advisory committees or review panels for public or nonprofit entities;

  • An equity interest that when aggregated for the Investigator and the Investigator's spouse and dependent children, meets both of the following tests:

    Does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value,

    AND

    does not represent more than a five percent ownership interest in any single entity;
     

  • Salary, royalties or other payments that when aggregated for the Investigator and the Investigator's spouse and dependent children over the next twelve months, are not expected to exceed $10,000.

If a Significant Financial Interest Exists, What Actions Must be Taken?

Investigators are required to report any significant financial interests at the time of applying for institutional approval of a research proposal. Officials appointed by the institution (in the Bureau these are the Scientific Committee or the Institutional Animal Care and Use Committee as applicable) will consider any reported interests, determine if there is a potential conflict of interest, and, if so, will determine how to manage, reduce or eliminate the conflict.

Examples of conditions or restrictions that might be imposed to manage conflicts of interest include, but are not limited to:

  • Public disclosure of significant financial interests;
  • Monitoring of research by independent reviewers;
  • Modification of the research plan;
  • Disqualification from participation in all or a portion of the research funded;
  • Divestiture of significant financial interests; or
  • Severance of relationships that create actual or potential conflicts.

See also:
NIH/PHS Policy on Objectivity in Research
NIH FAQ About Financial Conflict of Interest
Bureau Financial Interest Disclosure Form
Bureau Policy on Financial Conflict of Interest in Research

 
 
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