Campus Community Health • HEERF I, II & III

Conflict of Interest Archive 5_16_17

I. Purpose

The purpose of this policy is to promote objectivity in research by establishing standards that provide a reasonable expectation that the design, conduct and reporting of research, including those supported by grants, cooperative agreements, and contracts, will be free from bias resulting from Investigator Financial Conflicts of Interest. In particular, the Public Health Service (PHS) has promulgated regulations on “Promoting Objectivity in Research.” This Policy is premised on the Public Health Service (PHS) regulations and the TBR Policy on Conflict of Interest regarding research.

II. Review

This policy will be reviewed every three years or whenever circumstances require review, whichever is earlier, by the Associate Vice President for Research or his or her designee with recommendations for revision presented to the Vice President for Research and Economic Development, Administrative Council, and University Assembly.

III. Policy

  1. Tennessee Tech hereby adopts TBR Policy 1:02:03:10 on Conflict of Interest regarding research, including but not limited to pertinent definitions found in TBR Policy 1:02:03:10, as may be amended from time to time.
  2. Researchers must familiarize and comply with applicable policies and guidelines, including but not limited to:
    a.  Tennessee Tech Policy 132 (Conflict of Interest)
    b.  Tennessee Tech Conflict of Interest Possibly Resulting From Outside Employment Policy 
    c.  Tennessee Tech Purchasing Policy and Procedures 
    d.  Tennessee Tech Policy 732 (Intellectual Property)
    e.  Tennessee Tech Policy 131 (Preventing and Reporting Fraud, Waste or Abuse)
    f.  TBR Policy 1:02:03:10 (Conflict of Interest Policy)
    g.  TBR Policy 4:02:10:00 (Conflict of Interest policy on Procurement and Contracting) 2
    h.  TBR Policy 5:01:05:00 (Outside Employment policy).
    i.  Tennessee statutes pertinent to conflict of interest, as may be amended from time to time.
    j.  Federal requirements in selecting sub-recipients and awarding procurement contracts (2 CFR 200.112)
  3. All researchers must comply with federal policies and regulations regarding conflict of interest in research, including but not limited to federal regulations 42 CFR 50.601 et seq. and 45 CFR 94.1 et seq., as may be amended from time to time.
  4. Before applying for grants and contracts, all researchers must take and pass the Responsible Conduct of Research on-line training program (found here), and follow Tennessee Tech Policy 750 (Responsible Conduct of Research).
  5. Each investigator must make a disclosure of a potential or a real conflict of interest at the time of proposal submission by answering the questions contained on the Proposal Endorsement Form (PEF). Signatures on a completed PEF (found here) identifying no conflict of interest with the external organization shall suffice for negative disclosure.
  6. Positive disclosures must be indicated on the PEF (found here) and detailed by the respective investigator(s) in a separate statement that must be forwarded to the Office of Research at the time of submission of the proposal for funding consideration.
  7. If there is a change in the conflict of interest status of the investigator(s) prior to the time of award or after a contract is issued, the investigator(s) must report change(s) to the Office of Research in writing.
  8. Failure to comply with this or any other policy related to conflict of interest may result in sanctions up to and including termination.

IV. Interpretation

The Vice President for Research and Economic Development and or his/her designee has the final authority to interpret the terms of this policy.

V. Citation of Authority for Policy

Tennessee Tech Policy 735 (Conflict of Interest); TBR Policy 1:02:03:10; TBR Policy 4:02:10:00; TBR Policy 5:01:05:00; TBR Policy 5:01:06:00; Tennessee Statutes pertinent to Conflict of Interest; 42 CFR 50.601 et seq.; 45 CFR 94.1 et seq.; 2 CFR 200.112 3 Approved by: Administrative Council: 2015-02-25 University Assembly: 2015-04-22

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