10 Reasons Your Organization Should Invest in a Conflict of Interest Policy

Interest Policy
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Conflict of interest is a major issue for the National Institutes of Health (NIH). It creates the potential for unfair and biased decisions, as well as the appearance that this could happen. NIH has taken steps to create policies that will help prevent conflicts from occurring, but they are not perfect. At times, some individuals may still feel pressured to make decisions in favor of one person or group over another. A conflict of interest policy is designed to protect against these types of issues. When you invest in one for your organization, it can help avoid costly mistakes and lawsuits!

A conflict of interest policy is designed to protect against these types of issues. When you invest in one for your organization, it can help avoid costly mistakes and lawsuits!

 the main focus of nih’s conflict of interest policy is:

NIH has taken steps to create policies that will help prevent conflicts from occurring … at times some individuals may still feel pressured to make decisions in favor of one person or group over another; a conflict of interest policy is designed to protect against these types of issues. When you invest in one for your organization, it can help avoid costly mistakes and lawsuits!

an individual who might experience pressure like this would be tempted into making biased decisions on behalf the interests of one individual or group over another. This type of conflict can result in mistakes, lawsuits and even the loss of a job.

The NIH Conflict of Interest Policy prohibits a grantee from participating in the design, conduct, or reporting of human biomedical research if he/she has a financial interest that could be affected by the results. The NIH policy applies to an individual’s salary as well as any other interests such as consulting fees or equity holdings.

All employees have been required for many years to report their outside activities and affiliations on form ORI-FDA 2583 annually since 1971) which is filed with the Office of Research Integrity (ORI). Employees are also required to disclose certain conflicts when they arise during the course of employment. A conflict must be reported at its earliest stages because it may result in disqualification from work involving the contract, grants, or cooperative agreement that the conflict may affect.

The NIH policy applies to an individual’s salary as well as any other interests such as consulting fees or equity holdings. This includes ownership of stocks, bonds, and securities; legal consultation on a matter likely to come before the Federal Government (such as patent law); provision of clinical care for which payment is made by the government; receipt of royalties from commercial products developed under federally funded research grants; employment with non-profit organizations potentially affected by the results of biomedical research supported by NIH funds administered through another institution. It does not ordinarily apply when institutions are conducting separate projects in different fields unless there is reason to believe there might be overlap in personnel or scientific information between them. Prior approval must be requested if the NIH-supported research is to be carried out in the same institution as the non-profit organization or entity.

noncompliance with conflict of interest requirements may result, among other things, in a modification or termination of NIH support for the project; loss of eligibility to participate in any federal program that regulates human subjects pursuant to Title 45 Code of Federal Regulations part 46 subpart A (Protection of Human Subjects) and/or participation by those who are engaged in biomedical research regulated under Title 45 Code of Federal Regulations part 46 subpart A from receiving certain grants or contracts awarded by government agencies subject to regulations promulgated pursuant thereto.

In addition, an individual who participates personally and substantially on behalf of her employer’s interests rather than those which devolve to the institution as a whole may be subject to sanctions, up to and including termination of employment.

 the main focus of nih’s conflict of interest policy is:

In addition, an individual who participates personally and substantially on behalf of her employer’s interests rather than those which devolve to the institution as a whole may be subject to sanctions, up to and including termination of employment.

The following are examples that illustrate potential conflicts among institutional interests in biomedical research: membership on committees or boards from companies whose commercial activities involve products regulated by NIH; receipt or acceptance for personal use (or provision) of samples obtained during work with animal models funded by industry; participation in development projects sponsored jointly with industry partners without the approval of the institution or NIH; and serving as a consultant to industry for activities other than the work that is being paid.

The following are examples of potential conflicts among institutional interests in medical research: receipt, acceptance, or provision for personal use (or sale) of samples obtained during work with human subjects funded by industry; participation on committees or boards from companies whose commercial activities involve products regulated by FDA; and serving as a consultant to industry for activities other than the work that is being paid.

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By Ethan Devid

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