Conflict of Interest Review Committee Roles and Responsibilities
The Conflict of Interest Review Committee (CIRC), formerly the Disclosure Review Committee (DRC), helps to assure compliance with federal regulations and university and sponsoring agency policies and procedures governing financial conflicts of interest. In accordance with this objective, the CIRC evaluates personal financial interests disclosed by university investigators and staff. In addition, the CIRC provides communication and education regarding conflicts of interest to raise community awareness and assure that conflicts are identified, disclosed, and managed properly.
The Research Education and Compliance Office supports the CIRC and reports to the Associate Vice Chancellor for Research Administration.
Principles, Standards, and Guidance
- Develops and implements policies and procedures pertaining to financial conflicts of interest.
- Formulates guidelines that identify the types of potential conflicts of interest in academic-industrial relationships that will be considered material.
- Develops procedures to manage, reduce, or eliminate material conflicts of interest.
- Assures confidentiality of the disclosure, review, and management of conflicts of interest, to the extent possible.
Education and Awareness
- Provides communication and educational resources for researchers and staff related to identifying, disclosing, and/or managing financial conflicts of interest.
Administration and Management
- Represents the university to federal regulatory agencies.
- Develops and maintains electronic systems and technology solutions related to conflicts of interest.
- Reviews all disclosures of individual financial conflicts of interest and determines whether the conflicts are material.
- Recommends strategies to manage, reduce, or eliminate individual financial conflicts of interest.
- Assists the vice chancellor for research to monitor compliance with approved CIRC financial conflict of interest management strategies.
- Supports and endorses cooperation with University compliance and monitoring efforts and reports instances of noncompliance to the appropriate compliance office
- Recommends sanctions or other corrective actions in response to violations of university conflict of interest policies, procedures, and management strategies to appropriate compliance offices.
- Recommends the suspension or termination of protocol and/or funding for research that is not being conducted in accordance with CIRC requirements, federal regulations, and university and sponsoring agency policies and procedures to appropriate compliance offices.
Coordination Among Entities
- Coordinates with the Center for Clinical Studies (CCS), the Office of Technology Management (OTM), and the Office of Sponsored Research Services to help ensure that potential financial conflicts of interest are disclosed and effectively managed, reduced, or eliminated prior to award acceptance.
- Coordinates with the Human Research Protection Office (HRPO) to help ensure that financial conflicts of interest are disclosed and effectively managed, reduced, or eliminated in accordance with federal regulations and university and sponsoring agency policies and procedures instituted to protect the rights and welfare of human research participants.
Records and Reporting
- Coordinates with the Office of Sponsored Research Services to help ensure that sponsoring agencies are notified of significant conflicts of interest in accordance with federal regulations and university and sponsoring agency policies and procedures.
- Creates and revises financial disclosure review forms.
- Maintains records for all individual financial conflict of interest disclosures.
- Reports the management of material conflicts of interest in accordance with federal regulations and university and sponsoring agency policies and procedures.
- Creates and maintains records for all CIRC proceedings.