Disclosure of Financial Conflicts of Interest in Research
Pomona College is committed to providing a research environment that allows its faculty to pursue excellence in scholarship. In many cases, such excellence can be enhanced by research collaboration between faculty and private industry, and the College supports and encourages such joint enterprises. The College recognizes, however, that from time to time such arrangements may present faculty with opportunities for financial gain that can be exploited only at some cost to the integrity of their research program. To ensure that research is not influenced by financial conflicts of interest in these or other research settings, the College adopts the following policy on financial conflicts of interest in research.
The policy announced here is essentially a replication of one developed by the Independent Colleges Office, in consultation with the National Science Foundation. Changes have been made to reflect the titles of College personnel, to generalize to federal agencies other than NSF, and to reflect the style in which Pomona College policies are written.
A conflict of interest may take various forms, but arises when the significant financial interest may affect the design, conduct, or reporting of research, and/or when an investigator is or may be in a position to influence the business of the College, research, or other decisions in ways that could lead to any form of personal financial gain for the investigator, and/or for any member of the investigator’s family (spouse and/or dependent child).
For the purposes of this policy, an investigator is a principal investigator, a co-principal investigator, or any other person at the College who is responsible for the design, conduct, or reporting of research or educational activities funded or proposed for funding by a federal agency.
III. Monitoring Possible Conflicts of Interest
This Policy on Disclosure of Financial Conflicts of Interest in Research requires that the Associate Dean of the College who sits on the Research Committee determine whether there are significant personal financial interests that would reasonably appear to be directly or significantly affected by the research or educational activities funded or proposed for funding. The Associate Dean is the person responsible for certifying that with each grant proposal:
- the required conflict of interest policy has been implemented;
- to the best of his/her knowledge, all required financial disclosures were made;
- if such conflicts were determined to exist, they were (or will be prior to funding of the award) managed in a manner satisfactory to the College or disclosed to the funding agency as appropriate;
- individual investigators have certified that they have read and understood the College’s conflict of interest policy to the best of their knowledge;
- individual investigators have certified to the best of their knowledge all financial disclosures required by the College’s policy were made; and
- individual investigators will comply with any conditions or restrictions imposed by the institution to manage the actual or potential conflicts of interest.
In addition, the Associate Dean shall:
- as required, certify that;
- The institution is implementing a written and enforced conflict of interests policy that is consistent with agency policies;
- To the best of his/her knowledge, all financial disclosures required by that conflict of interest policy have been made; and
- All identified conflicts of interest have been, or prior to funding an award, will be either satisfactorily managed, reduced or eliminated in accordance with College policy, or disclosed to federal agencies which require such a disclosure.
- Collect, as appropriate, financial disclosure statements from affected individuals at the time of making application to federal funding agencies which require such a statement;
- Secure the certification of the Investigator Financial Disclosure Statement from potential and current principal investigators and co-principal investigators;
- Certify, for the College, on the forms to be submitted with the proposal, that the College has implemented and is enforcing a written policy on conflict of interest consistent with the provisions of the funding agency’s policies; and that -- to the best of his/her knowledge -- all financial disclosures required have been made;
- Review, on an annual basis, certification that all required financial disclosures in regard to funded projects have been made; and
- Maintain records of all financial disclosures and of all actions taken to resolve actual or potential conflicts of interest on an annual basis and when additional information arises until at least three years after the termination or completion of the award to which they relate, or the resolution of a government action involving those records, whichever occurs later;
It is the responsibility of faculty members and professional staff members named in proposals for federal funding to complete the College’s “Disclosure of Financial Conflicts of Interest in Research” statements and return it to the office of the Associate Dean.
IV. Managing Potential Conflicts of Interest
Conflicts of interest frequently are matters of degree and judgment, and the College expects faculty and staff to be alert to the possible effect of outside activities on the integrity of their decisions and on their ability to fulfill their obligations to the College and to funding agencies. As potential or actual conflicts of interest arise, the Associate Dean will determine which conditions or restrictions might be imposed to manage, reduce or eliminate actual or potential conflicts of interest. These may include one or more of the following:
- Making public disclosure of significant financial interest;
- Monitoring of the research activities by independent reviewers;
- Modifying the research plans;
- Disqualifying the investigator(s) from participation in the portion of the agency-funded research that would be affected by the significant financial interests;
- Securing the divestiture of the significant financial interests; or
- Severing the relationships that create actual or potential conflicts.
For National Science Foundation programs and the programs of other agencies that adopt similar guidelines, if it is determined that imposing conditions or restrictions would be either ineffective or inequitable, or have a negative impact on the design, conduct or reporting of the research -- that the potential negative impacts that may arise from a significant financial interest are outweighed by interests of scientific progress, technology transfer or the public health and welfare, or may have a negative impact on scientific progress, technology transfer, or the public health and welfare, the Associate Dean may allow the research to go forward without imposing such conditions or restrictions. His/her responsibility will be to make a judgment (a balancing test) between the potential negative impact of the conflict of interest and the public purpose to be served by the research.