OSU Conflict of Interest Policy – Briefing Document March 27, 2005
Intent of This Document To inform interested individuals about the draft OSU Conflict of
Interest (COI) policy. We must have an updated policy but do have options in implementation.
Background A faculty committee appointed by the Vice Provost for Research and the Vice
Provost for Academic Affairs and International Programs (see reverse of this page for
membership) was appointed in February 2003 to develop a COI policy. Both COI and Conflicts
of Commitment (COC) were discussed by the group. University acknowledgement of the
potential for COC is needed, but a COC policy should be developed and managed through
existing Academic Affairs procedures. COI requires on-going management and oversight
through the Office of Sponsored Programs and Research Compliance.
What is a COI policy? An administrative policy that outlines concepts of COI, details reporting
requirements, and describes decision-making and resolution processes.
Why must we have a COI policy? Oregon State University has long supported outside
professional activities of faculty and staff. These outside activities, collaborations, and
relationships enrich the academic environment and the quality of education of students. As the
university promotes and encourages new and varied collaborations, it is natural that relationships
can appear to become tangled and questionable, regardless of whether or not that is the case.
Heightened attention both nationally and locally on these relationships, as well as increased
federal regulations and scrutiny directed at management of conflicts of interest and commitment,
now dictate that we adopt a greater level of documented accountability in this area. Additionally:
•
The Public Health Service and National Science Foundation (OSU’s two largest federal
grant funding agencies) require that a policy be in place and that the University be
proactive in its use. A federal-wide policy is being formulated.
•
An established COI policy is required for some other accreditation processes.
•
The State Board of Higher Education requires us to have a policy.
•
Most other research institutions have a COI policy that applies to all relationships
regardless of whether or not federal funds are involved.
Who will be affected? All University employees are covered by the policy. Only professorial
rank faculty, regardless of title, must annually file a COI report. Supervisors may require other
employees to file reports as well.
Reporting COI Committee intent is to create a two-step reporting system. We envision that
80+% of faculty will only need to complete a “short-form” as the work they are doing does not
pose a COI. Faculty who default out of the short-form would need to complete a more detailed
form that requires extra levels of administrative scrutiny. COI reports would be available to
Sponsored Program staff who can verify that faculty have filed a COI report prior to approving
new proposals. Our goal is to have the COI policy in place by the end of the 2004-05 school
year, to implement paper reporting in fall 2005 and electronic reporting as soon as possible.
(over)
What happens if a potential conflict is identified? A determination will be made by the COI
Officer as to whether a true COI exists. The COI will consult with the COI Committee as
needed. If a conflict is identified, the COI Officer will work with the staff member and their
immediate supervisor to determine if a management plan can be developed or if the conflict
cannot be managed and other action is needed.
Next Steps We have received Interim Provost Randhawa’s and the Provost’s Council approval
to proceed with adoption of the policy. We are working with the faculty Senate Executive
Committee on several minor concerns. We are hoping for President Ray’s approval in April, to
begin OSU community education about the policy in spring term 2004-05 and to implement the
policy by the start of the 2005-06 school year.
OSU Conflict of Interest Committee Members
Name
Current Members
Bell, Chris
Burns, Leslie
Harmon, Mark
Heidel, Jerry
Ishmael, Jane
Karow, Russ
King, Nancy
Lowry, Peggy
McCubbin, Jeff
Nielsen, Roger
Sheward, Craig
Service dates
Chair
Department
Feb 03 - present
June 03 - present
Feb 03 - present
June 03 - present
Feb 03 - present
Feb 03 - present
Feb 03 - present
Feb 03 - present
Feb 03 - present
Feb 03 - present
July 04 - present
Oct 03 – Dec 03
Engineering
Apparel, Int. Housing
Forestry
Veterinary Medicine
Pharmacy
Crop &Soil Science
Business
Research Office
HHS
Ocean. & Atmsph. Sci
Tech. Transfer Office
Advisory
Reeves, Meg
Feb 03 - present
Policy & Legal Svs.
Former Members
Hostetler, Bill
Manore, Melinda
Taylor, Michael
Walker, Alexis
Walker, Gregg
Feb 03 – June 04
Feb 03 – May 03
Feb 03 – May 03
May 03 – June 03
Feb 03 – May 04
Tech. Transfer Office
Nut. & Food Mgmt
Veterinary Medicine
Human Dev & Family
Speech Communications
Jan 04 - present
Feb 03-Sept 03