Synopsis
In addition to the required annual disclosures, PIs and PDs are asked to declare whether or not a conflict of interest exists for each project proposed, either on their part or that of others named in the proposal.
The Duke individuals listed below are required to submit a COI* form online if they fulfill any of the following criteria at any point during the disclosure period:
- All individuals with faculty status
- All postdoctoral scholars/affiliates
- Any individuals participating in the design, conduct, and reporting of the research
- All exempt employees who receive(d) any salary support from the following WBS Element codes: 30x-xxxx, 31x-xxxx, 32x-xxxx, 33x-xxxx, 34x-xxxx, 353-xxxx, 383-xxxx, and 393-xxxx
Graduate and Undergraduate Students are exempt from this requirement unless indicated as key personnel on a sponsored program.
PreAward Procedure
|
PROCEDURES: ROLES AND RESPONSIBILITIES
|
|
DEPT*
|
:: Assures the PI*/PD* updates his/her COI* form online, if it is not current
:: Requests that all co-PIs/co-PDs and senior personnel listed in the personnel roster submit or update COI* forms online if they have not done so
:: All individuals who are required to submit an annual COI* Disclosure form sign off on the final page of the DPAF* indicating whether a real or potential COI* exists for the work being proposed
|
|
ORS*
|
:: AD/P* reviews DPAF*(s) and roster and verifies submission of COI* form by PI* prior to signoff
:: If a potential COI* exists and/or if all required DPAF* forms are not submitted with the proposal, AD/P* contacts AD/C* for review and follow up
:: AD/C* secures the remaining DPAF* signatures and reviews any real or potential COI* to determine if it must be addressed prior to award
|
| |
SPECIAL NOTES
|
|
The following link will take you to a website which lists the status of compliance requirements for each of the individuals included in a proposal: COI Compliance Tracker (Duke NetID required) |
PostAward Procedure
|
PROCEDURES: ROLES AND RESPONSIBILITIES FOR NEW AWARD
|
|
DEPT*
|
:: In accordance with the New Award Notification Memo PI*/PD* checks to assure that s/he has a current COI* form filed and approved
:: Checks to see that all co-PIs or co-PDs and senior personnel on the roster also have current COI* forms filed and approved
:: As TBD positions are filled, sends names to AD/C* and requests that new hires fill out COI* forms if they meet the requirements above
|
|
ORS*
|
:: AS* reviews roster and verifies approved COI* forms exist for all personnel listed
:: If TBD positions are listed in the award, file is transferred to the AD/C* for follow-up
:: Within 120 days of award AD/C* asks DEPT* who has been hired and checks that they have filed COI* forms if required
:: AD/C* monitors COI* forms to ensure approval and resolution if a conflict is disclosed
:: If a COI* must be managed, reduced, or eliminated, AD/C* works with the conflicted individual, PI*, and the Campus COI* Committee to address the conflict
:: If required (e.g., for NIH*), AD/C* notifies sponsor whether a COI* has been managed, reduced, or eliminated
|
|
|
|
PROCEDURES: ROLES AND RESPONSIBILITIES FOR NON-COMPETING RENEWAL OF AN AWARD
|
|
ORS*
|
:: AS* processes award and submits the file to the AD/C* for on-going monitoring
:: AD/C* checks with SAP R/3* for personnel changes and additions and verifies COI* status
:: AD/C* contacts individuals who are required to submit a COI* form and have not done so
:: AD/C* monitors forms to ensure approval and resolution if a conflict is disclosed
:: If required (e.g., for NIH*), AD/C* notifies sponsor whether a new COI* has been managed, reduced, or eliminated
|
|
|
|
DOCUMENTATION: OFFICES OF RECORD
|
|
ORS*
|
:: COI* monitoring database with notes
|
| |
SPECIAL NOTES
|
The following link will take you to a website which lists the status of compliance requirements for each of the individuals included in a proposal: COI Compliance Tracker (Duke NetID required)
|