Background:

Conflict of interest concerns have been raised at the national level. In direct response to a Congressional mandate, the Department of Health & Human Services (DHHS), including the National Institutes of Health (NIH) and the National Science Foundation (NSF) issued regulations on July 11, 1995 regarding investigators conflict of interest.

This policy applies to all research sponsored by DHHS/NIH and NSF. It is consistent with regulations, "Objectivity in Research," 42 CFR Part 50 and 45 CFR Part 94, with NSF regulations, "Investigator Financial Disclosure Policy".

Purpose:

VMRF established safeguards to prevent principal investigators, co-investigators, employees, consultants, members of governing bodies, and others from using their positions for purposes that are, or give the appearance of being, motivated by a desire for private financial gain. These safeguards are reflected in written standards of conduct.

Any person involved with a VMRF sponsored research or education project who is responsible for the design, conduct, or reporting of activities funded or proposed for funding must disclose any and all financial interest or legal ties that could directly or indirectly affect the project.

Application:

At the time of submission, every project must be accompanied by a conflict of interest form. Completed forms must be submitted to the appropriate VMRF Contracts & Grants Administrator.

For federally sponsored projects: all individuals listed as key personnel on the proposed project, must complete the Disclosure of Financial Interests Form 2000. Individuals who have a financial interest related to the work to be conducted must also complete the 2000-U Description of Financial Interest Form. For non-federally sponsored projects, such as industry sponsored clinical trials, foundation funded studies, donations, and education activities the principal investigator and co-investigators must complete the Research Conflict of Interest Statement.  

The VA/VMRF Conflict of Interest Independent Review Committee (IRC) will review situations of apparent and/or real conflicts of interest in order to assess circumstances under which outside activities or interest may inappropriately conflict with the PI's responsibilities to the VA, VMRF and the research or education activity.

In the event the IRC concludes that a conflict or potential conflict could directly affect the design, conduct, or reporting of the project, the project is placed in suspense until the IRC can recommend a management plan acceptable to the VASDHS Director, VMRF Chief Executive Officer, the PI and (if applicable) the sponsor. VMRF will report to any Public Health Service Awarding Component the existence of a conflicting interest (but not the nature of the interest or other details) that is found. VMRF will also assure the Awarding Component that the interest has been managed, reduced or eliminated.

All Disclosure of Financial Interest must be updated during the period of an award as new reportable significant financial interests are obtained.

No funds will be released by VMRF without documented IRC review.

Approved by the VMRF Board of Directors: May 16, 2008