Conflict of Interest

Conflicts of Interest exist when financial or other personal interests or considerations of the Investigator, or members of his or her immediate family, may directly and significantly affect, or have the appearance of directly and significantly affecting, an Investigator’s professional judgment in exercising any University duty or responsibility, including the design, conduct or reporting of research. Investigator financial Conflicts of Interests occur when the Investigator, or any member of that person’s immediate family (spouse, or domestic partner, and any other person residing in the same household as the researcher, who is a dependent of the Investigator or of whom the Investigator is a dependent), possesses a financial interest in a research activity that involves his or her University responsibilities. For some activities, such as human subjects research, any financial interest may give rise to a finding of Competing Financial Interests whereas in other situations, only a Significant Financial Interest will give rise to a Conflict of Interests. See the VCU Conflicts of Interest Policy for more information.

Conflict of Interests Committee (for research) is a standing committee of the University, composed of faculty and administrative personnel, as needed, and convened under the authority of the Vice President for Research by his or her designee. The Committee is charged to evaluate investigator reports of research related financial interests and determine an appropriate resolution, including the development of a management strategy, as appropriate. Committee members are responsible for adhering to applicable rules of privacy and confidentiality when commencing conflict of interest assessments.

NIH Conflict of Interests page: 

http://grants1.nih.gov/grants/policy/coi/index.htm

FINAL RULE ("Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractors") published in the Federal Register on August 25, 2011 regarding financial conflicts of interest in research. This document is available as a PDF at: http://federalregister.gov/a/2011-21633 )

This policy has been developed over the past 2 years, and replaces regulations that have been in place since 1995. The new regulations have a major impact on the identification, reporting, and management of financial conflicts, especially for individuals who are involved in research sponsored by the National Institutes of Health (NIH) and other agencies of the Public Health Service. The NIH has compared the 1995 and 2012 regulations, highlighting selected changes and this document can be downloaded at: http://grants.nih.gov/grants/policy/coi/summary_of_major_changes.doc.

On May 21, 2010, the Department of Health and Human Services published in the Federal Register a Notice of Proposed Rulemaking (NPRM) concerning, "Responsibility of Applicants for Promoting Objectivity in Research for which Public Health Service Funding is Sought and Responsible Prospective Contractors." The full NPRM is available on-line at: http://edocket.access.gpo.gov/2010/pdf/2010-11885.pdf.

NPRM Table is a very useful side-by-side comparison, prepared by NIH, of the current financial conflicts of interest regulations and the proposed regulations as described in the NPRM.

In addition, Drs. Francis Collins and Sally Rockey of NIH, have written a commentary on the proposal that was posted by JAMA on its web site. It has been made available to all at: http://jama.ama-assn.org/cgi/content/full/jama.2010.774.

The Department of Health and Human Services’ (HHS) Office of Inspector General (OIG),  How Grantees Manage Financial Conflicts of Interest in Research Funded by the National Institutes of Health (NIH) (OEI-03-07-00700), November 19, 2009.  The report is available on the OIG’s website at: http://www.oig.hhs.gov/oei/reports/oei-03-07-00700.pdf