From the Office of Research and Sponsored Programs
Fall 1995 Vol. 27, No. 1
With Phil Spina's departure to the Children's Memorial Institute in Chicago this past July, it seemed that the best way that I could support the Office would be to step in as Acting Director. In filling this role for the past three months, I have had reinforced, first hand, the tremendous dedication and professionalism of the entire RSP staff. I thank and commend them for a continuing job-well-done.
This may, however, be my only opportunity to write to you under the above title. Our search for a new director is on schedule, with interviews ongoing, and we look forward to identifying new leadership. My thanks to Dr. Rod Hammond and the Search Committee for attracting a pool of excellent candidates and moving the search forward and to the many faculty and staff who have participated in the interviews to date. I believe that this entire process can strengthen the Office and our commitment to serve the University community.
On another matter, I am pleased to announce that Ms. Ellen Friese has accepted the position of Assistant Director of RSP effective October 23. Ellen comes to Wright State from the Hipple Cancer Research Center with earlier experience at the Texas Tech University Health Sciences Center and the San Diego State University Foundation. Ellen is a resident of Centerville. She will be working primarily on information dissemination and related pre-award activities, but will also help with some post-award activities such as A-21 effort reporting. For this search, my thanks go to Dr. Pat Martin and the search committee (David Fautheree, Gene Hern, Glen Jones, Dan Krane, and Robyn Simmons) for an excellent search and selection process.
A final personnel note: Ms. Joyce Boitnott, Sponsored Program Assistant responsible for the Institutional Review Board for Human Subjects, retired August 31. The position has been filled through an internal promotion of Ms. Robyn Simmons. I hope that those of you who work with human subjects will join me in congratulating Robyn and welcoming her to her new assignment. We hope to announce a replacement for Robyn as Senior Secretary for Compliance Activities very shortly.
As the Office moves from proposal to protocol to award and meets the heavy workload of proposal deadlines, some major, significant events sometimes overlay our day-to-day activities. Such an event is the October 1 implementation of the federally-mandated Conflict of Interest (CoI) policy. You all should have received a memo and sample CoI forms recently through campus mail which I hope you found informative. Here, I would like to provide some background.
We all expect to share a high stand-ard of professional ethics which includes a commitment to avoid real or perceived conflicts of interest. This is obviously a very broad area, and one where there can be reasonable disagreements. One question is - at what point should the university step in to monitor and enforce a common standard?
For the present time, the federal government, through two of its agencies, the Public Health Service (PHS) and the National Science Foundation (NSF), has provided a minimum requirement. These agencies sponsor research and other programs that may lead to commercial applications. There is a concern, therefore, that these programs be conducted according to the highest professional standards for the greatest common good, not for the personal benefit of the investigators. Thus, these agencies have adopted a set of common regulations that require universities to assure that the investigators conducting a project do not have a financial interest that might lead to bias in the design, conduct, and reporting of the project. If the investigators do have such a conflicting financial interest, the university must disclose the existence of such an interest to the funding agency and must assure that a plan to manage, reduce, or eliminate the conflict has been adopted. The details of the plan, however, need not be reported to the agency unless requested at a later date.
The new federal regulations apply only to the PHS (which includes NIH) and the NSF. However, based upon the intent and spirit of the regulations, the Wright State University policy is written to include all federal sponsors. Thus, all WSU investigators applying for federal funds must meet the disclosure guidelines. For investigators applying for non-federal funds, the financial disclosure is optional.
The concern of the federal regulations and WSU policy is that personal financial interests not bias the conduct of a federally sponsored project. However, a personal financial interest may relate to some research topic areas pursued by an investigator but not others. Thus, the WSU policy is to be implemented on a project-by-project basis. Investigators will be asked to complete a Conflict of Interest Statement form for each proposal submitted. The form asks the investigator to disclose any significant financial interests which may reasonably be expected to bias the project proposed. If a financial interest is disclosed, the university designated official (RSP Director) will initially determine whether there is a conflict of interest.
Allow me to propose an example based upon my own discipline, materials science. Professor M is an active researcher. M also has some personal investments: (1) a 25% interest in a small company, M & Friends, that applies protective coatings to automotive components using a proprietary process; (2) stock in General Motors worth $20,000; and (3) an interest in an apartment building worth $50,000. M authors a proposal to the NSF to investigate the mechanism of adherence of coating compounds to a component surface. Faced with the disclosure form, M discloses (1) and (2), but not (3). M reasons that there is no reasonable connection of (3) to this (or any) research, and this is an appropriate decision. The RSP director reviews the disclosures. The Director determines immediately that the stock ownership (2) is not significantly connected to the research and will not lead to a conflict of interest. Interest (3), however, is referred to the Associate Provost for Research for further study and resolution of any conflict . Six months later, M submits another proposal, this time to the Air Force, to study ways to fabricate an airframe part from a new composite material. M again discloses (1) and (2), but not (3). This time the RSP Director immediately determines that neither (1) nor (2) pose a conflict.
There are decisions here for both the investigator and the review officials. For the investigator, it is best to err on the side of disclosure. When a disclosed financial interest is determined not to be a conflict, the university is obligated to support and defend the investigator if the relationship between a financial interest and a sponsored project is ever challenged.
Joseph F. Thomas, Jr., Acting Director