Institutional Responsibilities

INDIVIDUAL DisclosES

Disclosure review

WHO? Reviewers

Determination of conflict

WHO? Committee

Manage conflict

WHO? Adminstrative Offices

report COnflict

Manages Disclosures

WHO? Administrative Offices

disclosers

Click each hexagon to learn more.

reviewers

Institutions provide guidance and training to ensure investigators understand disclosure responsibilities.

committees

key players

admins

Work together to design, implement, and maintain an effective COI program.

Remember, perceived conflict is as risky as an actual conflict of interest. Disclose all possible conflicts. Institutional officials will decide if there's a COI that needs to be managed.

Mitigation strategies implemented according to risk assessment. Consequences for non-compliance and enforcement are pre-determined.

Effective conflict management plan uses policies and guidelines to define types of conflicts and how to disclose them.

Provide a framework and evaluation processes for review and disclosure with defined roles to assess impact.

Transparency and disclosure to students, staff, and collaborators.Public disclosure Independent review and monitoring of research Peer review, external validation, and open data sharing. Recusal or non-involvement from all or part of project. Severance of relationships. Modification of research plan or design. Oversight by colleague.

Public disclosure

Transparency and disclosure to students, staff, and collaborators.

Mitigation Strategies

Recusal or non-involvement from all or part of project.

Oversight by colleague.

Independent review and monitoring of research

Peer review, external validation, and open data sharing.

Modification of research plan or design.

Severance of relationships.

Conclusion

RESTART

Disclosers

At a minimum, disclosure pertains not only to the lead investigator but also to the potential COIs of all key personnel on the project, their spouses, and dependent children. Some institutions expand disclosure requirements to include domestic partners, any member of the household, and, in some instances, close personal friends or other family members. Disclosers must divulge all outside interests either annually or mid-year as a new COI emerges, when funding is awarded for study-specific research, and when human or animal subjects are involved.

Reviewers

An institution’s conflict of interest policies designates one or more persons to review financial disclosures, determine whether a conflict of interest exists, and determine what conditions or restrictions, if any, should be imposed by the institution to manage, reduce, or eliminate the conflict of interest.

Committees

A committee of faculty, administrators, or others who receive the recommendations and consider a conflict-of-interest management plan.

Administrators

The administrative offices create and implement policy and procedures for collecting disclosures, as well as providing training to their research community.