PROCEDURES: ROLES AND RESPONSIBILITIES

DEPT

:: Assures the PI/PD updates his/her COI form online, if it is not current

:: Requests that all co-PIs/co-PDs and senior personnel listed in the personnel roster submit or update COI forms online if they have not done so

:: All individuals who are required to submit an annual COI Disclosure form sign off on the final page of the DPAF indicating whether a real or potential COI exists for the work being proposed

ORS

:: AD/P reviews DPAF(s) and roster and verifies submission of COI form by PI prior to signoff

:: If a potential COI exists and/or if all required DPAF forms are not submitted with the proposal, AD/P contacts AD/C for review and follow up

:: AD/C secures the remaining DPAF signatures and reviews any real or potential COI to determine if it must be addressed prior to award

PROCEDURES: ROLES AND RESPONSIBILITIES FOR NEW AWARD

DEPT

:: In accordance with the New Award Notification Memo PI/PD checks to assure that s/he has a current COI form filed and approved

:: Checks to see that all co-PIs or co-PDs and senior personnel on the roster also have current COI forms filed and approved

:: As TBD positions are filled, sends names to AD/C and requests that new hires fill out COI forms if they meet the requirements above

ORS

:: AS reviews roster and verifies approved COI forms exist for all personnel listed

:: If TBD positions are listed in the award, file is transferred to the AD/C for follow-up

:: Within 120 days of award AD/C asks DEPT who has been hired and checks that they have filed COI forms if required

:: AD/C monitors COI forms to ensure approval and resolution if a conflict is disclosed

:: If a COI must be managed, reduced, or eliminated, AD/C works with the conflicted individual, PI, and the Campus COI Committee to address the conflict

:: If required (e.g., for NIH), AD/C notifies sponsor whether a COI has been managed, reduced, or eliminated

PROCEDURES: ROLES AND RESPONSIBILITIES FOR NON-COMPETING RENEWAL OF AN AWARD

ORS

:: AS processes award and submits the file to the AD/C for on-going monitoring

:: AD/C checks with SAP R/3 for personnel changes and additions and verifies COI status

:: AD/C contacts individuals who are required to submit a COI form and have not done so

:: AD/C monitors forms to ensure approval and resolution if a conflict is disclosed

:: If required (e.g., for NIH), AD/C notifies sponsor whether a new COI has been managed, reduced, or eliminated

DOCUMENTATION: OFFICES OF RECORD

ORS

:: COI monitoring database with notes