October 9, 2014
Vanderbilt University
Circa: 1901
Photo Courtesy Library of Congress Photo
Archives
Individual conflicts of interest refer to situations
in which an individual’s or family member’s
financial, professional, or other personal
considerations may directly or indirectly affect, or
have the appearance of affecting, an individual’s
professional judgment in exercising any university
duty or responsibility, including the conduct or
reporting or research.
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Nashville Tennessee Newspaper Delivery boys
in downtown Nashville;
Circa: 1900-1910
Photo Courtesy Library of Congress Archives
Nashville Tennessee Collection
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The public may lose trust and
confidence in Vanderbilt as a
hospital, academic center or
research institution.
Individual and institutional
reputations could be harmed.
Many research sponsors require it
in their contracts or grant terms
and conditions.
The policy serves to protect BOTH
the University’s interests and the
interests of the faculty and staff
who are disclosing.
Who?
Everyone – all VU Faculty and Staff
When?
Every year and ALSO when your
circumstances change
Where?
Online Web-based system
How?
Login with your VUNetID and epassword
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Personal Interests in Vanderbilt Activities
Business Relationships with Vanderbilt
Gifts and Contributions
University Assets
Student Activities
Family Members
Conflict of Commitment
Research Activities
Avoid decisions in
which you have a
personal interest or
an APPEARANCE
of a personal
interest:
Nashville City Hospital
Circa: 1890-1910
Photo Courtesy Metropolitan Government Archives
of Nashville and Davidson County
Hiring
Purchasing
Contracting/Consulting
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Avoid Situations in
which you or a
family member has a
Business
Relationship with
VU
Includes spouse’s,
children’s, parents’
businesses
Nashville Tennessee Maxwell House Hotel on 4th Ave.
Circa: 1890-1910
Photo Courtesy Metropolitan Government Archives of Nashville and Davidson County
No gifts or
accommodations
may be accepted by
the University or
individual members
of the University if
this puts them in a
prejudicial or
compromising
position.
USS Nashville Gunboat
"I Christen Thee"
Circa: 1895
Photo Courtesy Library of Congress Photo Archives
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Gifts in support of the institutional mission
must be directed through the Development
Offices
Individuals may accept gifts, meals,
entertainment, etc. no greater than
$300/year/vendor from NON-HEALTHCARE
INDUSTRY sources
$0 may be accepted from Healthcare by
individuals
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Vanderbilt University
Kissam Hall
Circa: 1900
Photo Courtesy Library of Congress Photo Archives
Misappropriation or
unauthorized use of
University assets in
connection with
external activities not
allowed.
Assets include:
buildings, personnel,
equipment, patents,
technology, and the
University’s
reputation.
Students, postdocs, or
other trainees
should not be
assigned University
projects sponsored
by a business if the
individual or family
member has a SFI in
the business.
Vanderbilt Class of 1912
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Downtown View #4
From the State Capitol
Circa: 1864
Originally Taken by: George N. Bernard
Photo Courtesy Library of Congress Photo Archives
Members of the
University may not
participate in the hiring
process or employmentrelated decisions
regarding their family
members.
Members should not be
in a position to
supervise a family
member or review a
family member’s work.
1.
2.
3.
4.
Yes
No
Maybe
I don’t know
No. You cannot hire, supervise or do job
evaluations for a member of your family. If the
family member is the only person qualified to
do the specific job, another reporting hierarchy
must be established.
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Fort Negley showing Union troops and munitions
Circa: Civil War
Photo Courtesy Library of Congress Archives
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Distribution of effort between
University employment or faculty
appointment and commitment to
external activities.
Staff do not have allotted
consulting days and are required
to take vacation days for
approved consulting time.
Time off for Faculty appointed on
a nine-month basis should not
exceed 40 days (including
holidays) during the academic
year.
Time off for Faculty appointed on
a twelve-month basis should not
exceed 50 days per year
(including holidays).
Southern Turf Saloon
Circa: 1880-1910
Photo Courtesy Library of Congress Archives
Nashville Tennessee Collection
Conflicts of Interest in
Research are
situations in which
Financial,
Professional, or
Personal
considerations may
compromise
judgment in design,
conduct, or reporting
of research.
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You should not be involved in the review,
approval or control of the research if you or a
family member has a SIGNIFICANT
FINANCIAL INTEREST.
This is especially important if you are doing
Human Subject Research as no research will
receive final approval until the conflict of
interest is addressed.
NSF, PHS, and FDA have specific guidelines
regarding conflicts of interest.
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The SFI threshold is $5,000.
Equity interest in any non-publicly traded company is automatically an
SFI.
Travel may also be an SFI, so all travel related to your institutional
responsibilities must be reported (for PHS-funded faculty/staff
only*).
There are specific exclusions from SFIs under the PHS regulations. (See
the PHS website for more details).
Public Accessibility Requirement
-Vanderbilt has chosen to provide a written response to any requestor
regarding SFIs for faculty/staff with PHS funding.
Investigator Training
-FCOI training is required for Investigators before engaging in PHSfunded research, every four years thereafter, and immediately under
designated circumstances.
Many other funding sources now follow the PHS regulations!
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2.
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4.
Yes
No
Maybe
I don’t know
Probably. Since you could receive royalties for
the licensing (as will Vanderbilt) and if your
research will be funded by the same company
(or involves the same technology), a
management plan is necessary to address this
potential conflict of interest. If Human Subjects
are involved, the IRB would also have to
approve, applying further scrutiny. When in
doubt, go ahead and disclose the potential
conflict!
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Initial Review by the Approver
- Senior Associate Dean Cindy Kam has primary
oversight of conflict of interest matters in A&S
- Sharon Buchanan performs initial reviews and
and typically is the first point of contact in the
Dean’s Office
Second Review performed by the Office of Conflict of
Interest and Commitment Management
Third Review may be necessary by UCC
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Does this disclosure constitute a conflict of
interest?
If it is a conflict, can it be managed?
If it can be managed, what requirements should
the management plan contain?
Conflicts that cannot be managed are presented to
the UCC for resolution (ie cease and desist or other
actions).
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Plans are put into place to limit the risks to the
University and the faculty/staff member with the
conflict.
Having a “conflict” does not necessarily mean an
activity is prohibited. In many cases, all that is needed
is a management plan.
Initial oversight of all management plans remains a duty of the
approver.
Questions about implementation of a management plan may
be brought to the COI Office at any time.
https://webapp.mis.vanderbilt.edu/coi/
The Arcade
Photo courtesy Mike Slate
Contact COI@Vanderbilt.edu or
alison.r.cooper@vanderbilt.edu