ConflictofInterest Current Procedures at MU Academic

1
Conflict-of-InterestCurrent Procedures at MU-
Academic Business -

• Lisa J. Wimmenauer, Administrative Services
• Robert D. Hall, Office of Research
• University of Missouri
• Columbia, Missouri, USA

2
Conflict-of-Interest

• Moved from Office of Research to Deputy
  Chancellor in 2002 (COI Officer)
• Day-to-day operation/coordination remains in
  Office of Research Compliance
• Public Registry is maintained in Office of
  Research Compliance
• MU News Bureau knowledgeable

3
Forms Used at MU

• Potential Conflict-of-Interest Disclosure Form
• Disclosures under 330.015
• Financial Disclosure Form
• Disclosures under 420.030
• Associated with Grant Data Form (GDF)
• Available on Office of Research Web Site, by hard
  copy in Office of Research, or in Sponsored
  Program Administration
• Forms are used as principal means to track or
  manage the potential conflict
• Disclosure at department, division and campus

4
Schedule for Disclosure

• Disclosure required when potential conflict
  perceived by employee
• Typically when research grant/contract is
  proposed
• When research program implicates contracts in
  other areas
• New disclosure required if employees financial
  situation changes during the contract period
• Disclosure required when entering into
  overlapping business activities
• MUs teaching, research or service missions

5
Schedule for Disclosure (cont)

• Disclosure required when full-time employment is
  implicated (Conflict of Commitment)
• Annual Report of Consulting Activities for
  Faculty and Exempt Personnel
• Teaching activities potentially competing with
  the University must be disclosed
• Faculty-authored textbooks/educational materials
  may be assigned (royalties forfeit)
• Employee (usually Principal Investigator)
  completes appropriate forms

6
Personnel Involved in COI

• Office of Research administers day-to-day
• Bryan Ross, Administrative Assistant, receives
  disclosures under 330.015
• Disclosures are administered through Office of
  Research Compliance
• Public Registry is maintained by the Office of
  Research Compliance
• Files kept permanently at present (e-versions?)
• Disclosures under 420.030 come through OSPA to
  COI Committee via O.R.

7
COI Review Process

• Conflict-of-Interest Committee reviews all
  disclosures and makes recommendation to Deputy
  Chancellor regarding existence of conflict
• Final decision is made by Deputy Chancellor
• Disclosures are made public through the Registry
• Coordination with the IRBs is done through the
  Office of Research Compliance

8
MU Conflict-of-Interest Committee

• Established by Vice Provost Jack Burns
• Revised in 2002
• Current membership reflects input from Faculty
  Council
• Approval by majority of quorum of voting members
• Input from nonvoting members

9
COI Committee Membership (2003-04)

• Mike Middleton, Deputy Chancellor (Chair)
• Mike Devaney, Faculty Council nominee
  (Vice-Chair)
• Bob Bailey, Faculty Council nominee
• Lisa Wimmenauer, Administrative Services
• Rob Hall, Office of Research
• Keith Politte, Development
• Kelly Mescher, General Counsels (non-voting)
• Tom Sharpe, OTSP (non-voting)
• Mike Warnock, OSPA (non-voting)

10
COI Committee

• Meets monthly on average
• Transacts business by e-mail when required
• Coordination through O.R. administrative
  assistant
• Public Registry
• Coordination with Business Services for
  contracting authority
• Maintenance of disclosure file

11
Outcome of COI Review

• No COI detected letter to that effect
• COI detected
• Unmanageable activity not permitted
• Manageable divestiture or management plan
• Typical management plan (discloser, COI
  Committee, OTSP, etc., may draft)
• Oversight committee
• Department Chair
• Associate Dean
• Knowledgeable faculty member
• Approved by Deputy Chancellor
• Annual report to Deputy Chancellor

12
Areas for Improvement

• Oversight/audit of Management Plans
• Deputy Chancellor has authority to terminate
  noncompliant activities
• Dispute resolution process (currently
  face-to-face meeting with COI Committee)
• Review of procedures/practices (current system
  has been in place for short time)
• How should audits/reviews be accomplished?

13
Public Registry

• Currently 3-ring binder
• Web site under development
• Disclosures posted for ten business days prior to
  award of contract
• Open for public review
• One request for inspection to date
• RADIL prompted one focused request

14
COI Disclosures

• No annual requirement for COI disclosure
• MU averages about 35 disclosures annually
• Consultation by faculty and exempt personnel
  requires annual recap and report to System
• Education about COI policy its importance
• Office of Research web site
• New faculty orientation workshops
• Council of Research Administrators
• Other advisory groups serviced by O.R.