IUS POLICY ON CONFLICT OF INTEREST

In response to changes made by the Board of Trustees to Indiana University policy on conflicts of interest, corresponding changes to our conflicts disclosure forms and procedures must take effect this fall. The Research and Grants committee proposes the changes below, with an explanation of the new procedures for disclosure, review and management of conflicts of interest that all IUS faculty must follow.

Prior policy required conflicts disclosures to be completed only by faculty, staff and students who participated in the design, conduct, or reporting of federally funded research. Under current policy, all faculty and staff must complete an annual conflicts disclosure, regardless of whether or not they are engaging in federally funded research. Current policy extends the principle of the prior policy that significant outside financial interests should be disclosed and reviewed to ensure that they are not improperly influencing federally-funded research, or creating the appearance of doing so to all research, regardless of the source of funding, and in the case of faculty members, to University teaching and service activities as well.

Under prior policy, conflicts disclosures were reviewed first by the head of the unit in which the faculty member holds his or her primary appointment (or the unit head’s designee), and if the unit head identified a potential conflict, the disclosure and recommendations for resolving the conflicts were sent to the Assistant Vice President for Research in RUGS for further review and action. Where no potential conflict was identified, the disclosures were filed and maintained solely within the unit.

The Research and Grants committee proposes that conflicts disclosures be reviewed first at the level of the Deans, with all disclosures forwarded to the Assistant Vice President for Research for review. Identified potential or actual conflicts will be sent to the IUS Faculty Affairs Committee, which in consultation with the Associate Vice Chancellor of Academic Affairs and Dean of Research will review and take appropriate action regarding those forms which have been identified as having a potential conflict. The disclosures will continue to be treated with the confidentiality they have in the past.

Disclosures are to be made annually at the beginning of each academic year and updated as changes occur (e.g., where the faculty member has acquired a new financial interest, or where a research project creates the possibility of conflict that did not exist when the investigator last disclosed). All persons engaged in the design, conduct, and reporting of federally supported research, including staff and students, are required to complete disclosures. Faculty who serve as principal investigators on research are responsible for ensuring that all staff, students, and post-docs participating in their research complete a disclosure.

RUGS has drafted a new disclosure form and instructions to account for the changes in University policy. A copy may be obtained from Academic Affairs or from the RUGS website at:

www.indiana.edu/~resrisk/conflict.html

In 2002 this form must be completed by all faculty and turned into the Dean of their respective unit for review no later than November 1, 2002. In 2003 and all subsequent years, the form must be completed by October 15.