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Conflict of Interest for Grant Funded Research

Policy Statement: Federal regulations governing NIH and NSF grants require (See regulations at 42 CFR 50.601 and following) that the College adopt, monitor and enforce a Conflict of Interest Policy covering financial conflicts which may arise as a result of research funded by the NSF or NIH. The College recognizes that these conflicts may arise from time to time due to the many interests and investments that faculty and their families may have. The existence of such a conflict is not prohibited in and of itself, but the existence of such conflicts must be disclosed to the College and managed appropriately. Consequently Lewis & Clark College adopts the following Conflict of Interest Policy.

Procedures:

1. Each investigator shall disclose to the Dean of her/his respective school (or the Dean’s designee) all significant financial interests of the investigator (including those of the investigator’s spouse and dependent children) (i) that would reasonably appear to be affected by the research or educational activities funded or proposed for funding by the grant source; or (ii) in entities whose financial interests would reasonably appear to be affected by such activities.

2. The term “investigator” means the principal investigator, co-principal investigators, and any other person at the institution who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding.

3. The term “significant financial interest” means anything of monetary value, including, but not limited to, salary or other payments for services (e.g., consulting fees or honoraria); equity interest (e.g., stocks, stock options or other ownership interests); and intellectual property rights (e.g., patents, copyrights and royalties from such rights).

The term “significant financial interest” does not include:

  • salary, royalties or other remuneration from the applicant institution;
  • income from seminars, lectures, or teaching engagements sponsored by public or non-profit entities;
  • income from service on advisory committees or review panels for public or nonprofit entities;
  • an equity interest that, when aggregated for the investigator and the investigator’s spouse and dependent children, meets both of the following tests: 1. Does not exceed $10,000 in value as determined through reference to public prices or other reasonable measures of fair market value; and 2. Does not represent more than a 3% ownership interest in any single entity; or
  • salary, royalties or other payments that, when aggregated for the investigator and the investigator’s spouse and dependent children, are not expected to exceed $10,000 during the twelve month period.

4. Each investigator shall have provided all required financial disclosures at the time the proposal is submitted to the grant funding agency or institution. Each Investigator shall update disclosures as new reportable significant financial interests are obtained during the term of the applicable grant.

5. The Dean (or designee) shall 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 such conflict of interest. A conflict of interest exists when it is reasonably determined that a significant financial interest could directly and significantly affect the design, conduct, or reporting on research or educational activities.

Examples of conditions or restrictions that might be imposed to manage, reduce or eliminate conflicts of interest include, but are not limited to:

  • public disclosure of significant financial interests;
  • monitoring of research by independent reviewers;
  • modification of the research plan;
  • disqualification from participation in the portion of the research that would be affected by significant financial interests;
  • divestiture of significant financial interests; or
  • severance of relationships that create conflicts.

6. If it is reasonably determined that imposing conditions or restrictions would be either ineffective or inequitable, and that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer, or the public health and welfare, then the research may be permitted to go forward without imposing such conditions or restrictions.

7. Violation of this policy may result in disciplinary actions or sanctions where appropriate.

8. The College shall retain copies of all financial disclosures and of all actions taken to resolve conflicts of interest for at least three years beyond the termination or completion of the grant to which they relate, or until completion of any investigation concerning such records, whichever is later.

Approved by the Executive Council, December 15, 2004.

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