ASIST: Why was the policy on Conflict of Interest recently updated?
Angie Solomon: To bring our policy more in line with the expectations of external sponsors and in particular, our federal sponsors.
When did the revised policy go into effect?
June 1, 2020.
What are the biggest changes to the policy?
There are many changes to the policy. The first change individuals will notice is that the policy now includes conflict of commitment. Other revisions/enhancements relate to faculty start-up companies, relationships between faculty and non-faculty members in outside activities and guidance related to dispute resolution.
What question does the COI office get asked most often?
The biggest confusion seems to be in determining what is reportable and what isn’t. Although it is impossible to cover every scenario that someone may encounter, this is the general answer:
You should disclose outside activities that you participate in (paid or unpaid) if the activities relate to your individual responsibilities at the University or if they interfere (or could interfere) with your obligations as a University employee.
We have developed a fairly comprehensive set of Frequently Asked Questions that is available on our web site, https://dosi.duke.edu/conflict-interest/conflict-interest-conflict-commitment-faqs
Is the institution trying to discourage individuals from participating in outside activities?
Absolutely not! The key is transparency. Unfortunately there is no harmonization of sponsor expectations when it comes to the reporting of outside activities. There are also organizations who publicize payments made to individuals. Keeping the institution informed allows us to mitigate bias (or the appearance of bias), to report to sponsors as required by regulation or contract, and to be ready to respond to inquiries from outside agencies.
How often do individuals have to report outside activities or significant financial interests?
Within 30 days of acquiring an outside activity or significant financial interest (or within 30 days of a change in an outside relationship), at grant attestation time if related to the specific project and annually as part of the COI disclosure form requirement.
What should someone do if uncertain of whether something needs to be reported or not?
Again, transparency is key. If you have an outside relationship or significant financial interest that could be deemed by someone from the outside as related to your work or research at Duke, it should be disclosed.
How can the COI Office help?
We have resources available on our website: https://dosi.duke.edu/conflict-interest/research-conflict-interest; as well as a dedicated email address: firstname.lastname@example.org for questions. We regularly meet with individuals and/or research teams to discuss specific cases examples.