Public Responsibility

A broad spectrum of public policy requirements applies to grant and contract awards.  Particularly in the case of Federally-sponsored programs, such requirements are based on social, economic or other considerations that are generally attached to the expenditure of Federal funds by grantees, subaward recipients, and contractors, or may relate specifically to the expenditure of Federal funds for research, training, or other specified activities.  In addition to cross-agency requirements that grantees must apply to their programs, grantees are also subject to agency-specific requirements that are contained in an individual agency’s annual appropriation act.   The research administrator must not only understand the relevant regulations, but must also identify resources and strategies to establish and maintain compliance programs.  Beyond these policy requirements, issues of ethics, accountability, and costs move the research institution from areas of hard science to hard choices.

Gary Thompson - Harvard Medical School, SRA Meeting, 6/9/04, Portland, ME

1. Public funding is based on the principle that the public good is advanced by science.
2. The public will support science only if it can trust the scientists and the institutions that conduct the research.
3. Research institutions are expected to be accountable to the public.
4. Fostering an environment that promotes integrity in the conduct of research is an important part of that accountability.

Institute of Medicine of the National Academies – Vaccine Safety Research, Data Access and Public Trust

No description for Public Responsibility: NACUBO has been entered yet.

http://www.ncrr.nih.gov/newspub/Fall04rpt/director.asp

Project Integrity is the promotion of Responsible Conduct of Research (RCR) Two URLs offering further programming are under External Links below.

Conflict of Interest (COI) occurs when members of an institution are in a position to influence a decison on policy or purchases where they might directly or indirectly receive financial benefits or give iproperty advantage to associates. More on this definition can be found under External Links below.

COI required PI disclosures when applying for federal funds at the proposal stage. This action gives the COI Committee (COIC) ample time for managing the response. The COIC should consist of the institution's research administration leaders, the general counsel, and one other senior administrator. Others can be added to this core based on the expertise needed for a matter. COIs must be resolved before spending on Federal Grants.

Under DHHS 45 CFR 94.3 significant financial interest means anything of monetary value, including but not limited to salary, or other payment for services such as consulting or honoraria; equity interests such as stocks, stock options or other ownership interests, and intellectual property rights including patents, copyrights, and royalties from such rights.

COI does not include salaries, royalties or other remuneration from the PIs institution, or any ownership interests in the institution if the institution is an  applicant under the SBIR program. COI does not include income from seminaris, lecture or teaching sponsored by public or nonprofit entities. Nor does COI include income from service or advisory committees or review panels for public or nonprofit entities. It does not include an equity interest when aggregagted for the PI or the PIs spouse and dependent children when both of the following tests are met: does ot exceed $10,000 in value on the local economy (fair market value); and does not represent over 5% ownership interest in any single entity. COI is not a matter when salary, royalties or other payments when aggregated for the PI and the PIs spouse and dependents over 12 months are not reasonably expected to exceed $10,000.

References:
NIH, HSF, and PHS - see External Links below. The NSF and PHS require notification of existence of COI.
MIT and Stanford COI policies - see External Links below.
COGR, "Approaches to Developing a Conflict of Interest Policy," and "Recognizing and Managing Conflicts of Interest," October 2002.
American Association of Universities - see External Link below.

External links:
http://www.ecostudies.org/responsible_conduct.html
http://www.hhs.gov/ohrp/policy/incidreport_ohrp.html
http://ethics.ucsd.edu/courses/integrity/assignments/conflicts.html
http://grants.nih.gov/grants/policy/coi/nih_review.htm http://www.nsf.gov/pubs/2002/nsf02151/gpm5.jsp - 510 http://ori.hhs.gov/policies/fedreg42cfr50.shtml and http://info.gradsch.wisc.edu/research/compliance/coi/coi2005/4.phs.html
http://www.nsf.gov/pubs/stis1996/faqinfin/faqinfin.txt
http://www.access.gpo.gov/nara/cfr/waisidx_02/45cfr94_02.html
http://grants1.nih.gov/grants/policy/coi http://www.cogr.edu/docs/Developing an Institutional Conflict of Interest Policy - OPening Page.doc
http://web.mit.edu/afs/athena/org/o/osp/www/resources_export.htm http://www.stanford.edu/dept/DoR/rph/Chpt4.html
 http://www.aau.edu/research/conflict.html

No description for Public Responsibility: Sarbanes-Oxley Act and Implications for Nonprofit Organizations has been entered yet.

No description for Public Responsibility: Summary of Sarbanes-Oxley Act of 2002 has been entered yet.