Conflict of Commitment Policy Revised

 

Following a review of the conflict of commitment policy outlined in the Emory Faculty Handbook, now under the authority of the Faculty Council, the Council voted at its January 21 meeting to revise the policy. The revision is intended to more accurately reflect both current practices and a philosophical shift toward a greater spirit of engagement of faculty in activities on a local, national, and global scale. For example, the earlier version stated that a faculty member must get prior permission from the dean to deliver a lecture at another school within Emory, even when no compensation was involved. The revised policy distinguishes among levels and types of external professional activity with requirements adjusted accordingly. The policy’s guiding principle now states, in part, “The specific responsibilities and professional activities that constitute an appropriate and primary commitment will differ across schools, but they should be based on a general understanding between the faculty member, department chair (if applicable), and dean.” Some individual schools have more detailed private consulting policies; faculty should consult their schools’ policies and websites for more details. To review the full revised policy, click here.

 

Council Considers Conflict of Interest

In November the Faculty Council reviewed the conflict of interest policies outlined in the Emory Faculty Handbook, which is now under the authority of the Council. Brenda Seiton, Assistant Vice President for Research Administration, spoke on the work of the Conflict of Interest Office. Seiton said that most of the policies in the handbook are administered through the Office of the Provost and the deans’ offices. She also noted that all Emory faculty engaged in research must complete an annual electronic certification in conflict of interest. Faculty not engaged in research should check with their deans’ offices on what is required. The eCOI system, she said, “captures information about financial interests and external activities,” from consulting activities and investments to externally funded research. Her office is responsible for policies for investigators holding financial interest in research and institutional financial interest in human subject research. She put the question to members as to whether guidelines for scholarship needed to be adjusted to respond more effectively to the needs of humanities and social sciences faculty. The Council approved a motion to form an ad hoc committee to review the policies currently in the handbook and present recommendations by the end of this academic year.

 

Conflict of Commitment Policy Also Reviewed

Council past chair Gray Crouse led a discussion on the conflict of commitment policies as currently drawn in the Emory Faculty Handbook. These policies address teaching, research, and service beyond a faculty member’s school at Emory, as well as private consulting and use of university resources. “One of the issues is that as the policy currently reads, if, for example, a faculty member is invited to give a lecture at Emory or another institution, even for no compensation, that faculty member must get prior permission from the dean,” Crouse said. “This policy does not make distinctions between levels of teaching or levels of service.” The discussion concluded with the determination that the Executive Committee would work on a draft revision of the policy and present it in the next Faculty Council meeting.

Faculty Participation in Research Administration

David Wynes, vice president for research administration, presented to the Council in October about encouraging more faculty to participate in research administration. Research committees include Confict of Interest Review, Institutional Animal Care and Use (IACUC), the Institutional Review Board (IRB), and a number of health and safety committees. “We believe strongly that these committees should comprise members of the faculty peer groups,” Wynes said. “For example, animal care committees should be composed of people who use animals in research, and the IRB should be composed of people who use human subjects in research.” Wynes also noted that IACUC has some 760 active protocols at any time, and the IRB has some 3,000.

Council members offered two general recommendations: that the Office of Research Administration work through existing faculty governance bodies around campus to recruit new members to these committees, and that the office draft a core set of principles delin- eating how each of the committees should be composed, according to research activity.

 

New Conflict of Interest in Research Policy

Assistant Vice President for Research Administration Brenda Seiton spoke to the Council on new federal regulations that will directly affect Emory faculty members receiving Public Health Service research dollars. The newly revised conflict of interest regulations go into effect in 2012 and affect awards issued after August 24, 2012. In essence, investigators must now report significant financial interests related to their institutional responsibilities. “Before, it was left to the investigators to determine whether a financial interest was related to their research project,” Seiton explained. “So what they have done is said, let’s take that out of the investigator’s hands and put it into the hands of the institution.” The new regulations lower the threshold of review to a total of $5,000 in income and equity, require the reporting of travel directly reimbursed to an individual and not funded by a US academic institution or the government, require the public disclosure of all conflicts of interest, and mandate training in conflict of interest policies for all faculty receiving external support. For details, visit coi.emory.edu.

 

Changes coming to COI rules

At its January 17 meeting, the Faculty Council heard a report from David Wynes, Vice President for Research Administration, on major changes forthcoming from the government to conflict of interest rules governing individual faculty receiving federal research funding. The new regulations will take effect with grants awarded in August 2012. Among the changes:

  • The threshold for review of interest in outside activity is now $5,000 in combined income and equity;
  • All outside activities related to professional appointment (not just research) must be reported;
  • All travel directly reimbursed to an individual and not funded by an institution of higher education or the government must be reported within 30 days to the institution;
  • The institution is required to either post on a website the names of all individual faculty with a financial conflict of interest or alternatively to provide the information to anyone who requests it within five days;
  • Every faculty member who receives external support must undergo an initial and ongo- ing training every four years in conflict of interest policies.

 

Possible Federal Changes to Individual Conflict of Interest Rules

In a presentation to the Faculty Council on the work of his office, Vice President for Research Administration David Wynes described pending federal regulation that would dramatically overhaul the federal conflict of interest regulations for individual faculty. Among the major proposed changes:

  • The threshold for review for conflict of interest in outside activity would be reduced from $10,000 in stock or income to $5,000 combined;
  • Threshold for review for interest in a private company set at zero equity;
  • Requirement that the university post a website listing all faculty with conflicts of interest, even if the conflict is managed; and
  • Requirement that every faculty member take continuing education in conflict of interest.

Wynes said a final ruling on the proposed changes was expected in late winter 2011.