August 16, 2012

RE: Federal Conflict of Interest Rule Changes – OSPA procedures coming soon!



Please expect new OSPA procedures related to the revised PHS COI regulations in the next few days for a short review period before we finalize and implement for the August 24, 2012, effective date. Should you have questions in the meantime, please don’t hesitate to call me. 
                                                                                                                                                      
June 13, 2012
Research Community,

The Public Health and Services (PHS), which includes the National Institutes of Health (NIH) and the Food and Drug Administration (FDA), has revised the regulations that govern Conflict of Interest (COI).  The regulation has new requirements for both MU as a PHS-funded Institution and the Investigators who work on those projects.  Implementation of these new processes will begin on August 24, 2012.  The COI Office is taking the lead on ensuring these regulations are met. 
We will be giving a detailed presentation about these changes for all Investigators and Staff who are interested on June 26, 2012 from 1-3pm in the Monsanto Auditorium in the Bond Life Sciences Center. We encourage all to attend, especially those who currently have PHS funding.

Please feel free to forward this email as you deem appropriate.  If you have any immediate questions about how these changes will impact your role in the research award process, or if you would like a more detailed presentation of the changes for your department specifically, please contact the COI Office at: 884-3317 or coi@missouri.edu

Below is a summary of the changes that impact Investigators and the proposal/award process. 

At Proposal-

·         PIs must submit a form identifying all Investigators for each PHS or NSF project.
o    This form will replace the previous COI form used on these projects and will be distributed soon. 
·         BEFORE the proposal can be submitted, all Investigators listed on the form must have a current COI form submitted within the previous 12 months. NO proposals will be submitted until OSPA can verify that all Investigators have filed a current COI form.  
·         All Subcontracts on these proposals will require a certification from the subcontractor that they have a COI policy that complies with PHS regulations and will submit reports to MU as appropriate.  OSPA is drafting a Letter of Commitment that contains the appropriate language. MU is not currently permitted to accept a subcontractor who will not make this certification. 
All Investigators, including the PI, listed on a project at proposal will be contacted after the submission to inform them about the requirements that need to be completed prior to the expenditure of funds. 
At Award-
PRIOR TO THE EXPENDITURE OF FUNDS (including pre-award spending accounts and spending under expanded authorities) the following must occur:
¡  The Conflict of Interest Committee (COIC) must review and determine whether any Outside Interests of the Investigators impact the project.
§  If yes: A management plan must be created and approved by the COIC, Investigator, Department Chair, and Dean.  A Financial Conflict of Interest report must then be submitted to PHS. 
¡  All Investigators must complete COI training through eCompliance electronically.  Please note that this training module is not yet available.  Once available, the Research Community will be notified.   
¡  All Investigators must report all Sponsored Travel within 30 days of the trip.  Sponsored Travel is any travel paid for by an entity other than MU.
¡  Any new/changed Outside Interests must be reported within 30 days.
During an ongoing PHS-funded project-
·         NO new Investigators may be added to a project until they have completed all the above requirements.  Notify the COI Office before adding personnel to these projects. 
As mentioned above, please plan to attend this presentation to learn more about this process.  If your department would like a more detailed presentation about these changes, please contact the COI Office to set up a time.  Please call if you have any other questions or concerns.