Conflict of Interest

1
Conflict of Interest
Room for Improvement

• Panel
• Matt Ronning
• John Gilligan
• David Broome
• Ericka Kranitz

2
Audit

• Internal Audit Overview - Audit report 11/7/02
• - Who is required to complete?
• - Clarify procedures
• - Complete upon hire
• - Revise COI form
• - Compliance
• - Roles and responsibilities

3
Confusion Abounds

• Who has to complete?
• How do we interpret the forms?
• Where do consulting arrangements fit in?
• What are the legal ramifications?

4
Legal Framework

• State Law NCGS Sec. 14-234
• Prohibits any state employee that receives
  direct benefit from a state contract from (a)
  making or administering the contract or (b)
  attempting to influence anyone who makes or
  administers the contract. Violation is
  misdemeanor.
• Definitiondirect benefit
• Definition making a contract
• Definitionadministering a contract
• Federal Law
• Since October, 1995, both NSF and PHS require
  recipients of federal money to have programs in
  place that require disclosure and management of
  financial conflicts of interest.

5
Management Plans

• What is a real management plan?
• Who reviews management plans?
• Who monitors management plans?

6
Systems Solutions

• Automate disclosure
• Integrate disclosure process into proposal
  submission routine
• Eventually, pop-up disclosure when submitting
  proposal to non-federal sponsor
• Request update and certification that disclosure
  is current and accurate
• Planned implementation August 15, 2004
• Part of Faculty Research Portal

7
Evaluation of Other Schools

• What are some other schools doing?
• Penn State
• UMD
• Boston U
• U.Utah
• VTech

8
Penn State Robust Committee
9
UMD Not much better
10
BU Pretty Good
11
Vtech An Example to Follow?
12
U.Utah A Flow Chart
13
Action

• Establish a COI Committee
• Charge COI Committee to
• Review and revise COI Policy
• Review and integrate Consulting Policy
• Establish a plan for oversight

14
Lunch Service

• Dining Room
• No Food, Drink or even Water outside of Dining
  Area
• Reconvening sharply at 125!
• First round of Gifts start at 125!