Financial Conflict of Interest in Research

Financial Conflict of Interest Regulations

Dartmouth has an obligation under federal law and institutional policy, as well as an ethical duty, to assure that the design, conduct and reporting of Research will not be biased by any conflicting interests of an Investigator. The objectivity of research is of paramount importance and the basis for obtaining and maintaining public trust.  Financial Conflict of Interest regulations related to federally funded research address the increasing complexities of the financial interests held by biomedical and behavioral researchers and the resulting interactions among Government, research Institutions, and the private sector. 

Disclosure Requirements

Before a proposal for research funding is made to a funding agency, federal (NIH & NSF) regulations require each person responsible for the design, conduct or reporting of research sponsored by these agencies to disclose any significant financial interests. Dartmouth College policy applies this standard to all externally funded research. Federal Regulations and Dartmouth policy also require that research involving Human Subjects is reviewed for financial conflicts of interest.  Please familiarize yourself with the Dartmouth College COI policy and any applicable Federal policies (see PHS and NSF).

The Research Integrity Office in the Office of the Vice Provost for Research at Dartmouth oversees all research related Conflict of Interest disclosures, conducts reviews, and works with the Conflict of Interest Committee (COIC) to address and manage conflict of interests related to research. If a Financial Conflict of Interest is identified by the COIC, it does not mean the proposed research cannot go forward. In most cases the conflict can be addressed through a COI management plan. 

If you intend to apply for sponsored research funds through OSP, please visit Rapport.Dartmouth.edu to submit your Annual COI Disclosure through the online disclosure system. The online system contains detailed additional information. 

You will proceed to a login screen and enter your NetID and password.

A Dartmouth NetID account is needed to complete a COI disclosure in the Rapport system. All Dartmouth College faculty and employees have NetID accounts. A sponsored account must be established for other individuals who may need access. If you have questions about your NetID or other access issues, please contact the Dartmouth College Help Desk at 603-646-2999 or Geisel Computing Support at 603-650-1600.)  You can look up your NetID account at the NetID Lookup page. 

Non Research Related Conflict of Interest

You may be asked to report other financial interests in relation to your non-research professional responsibilities (e.g. in relation to DHMC clinical duties or continuing medical education). These processes are separate from the Dartmouth disclosure and review system. Reporting interests related to sponsored research does not eliminate or substitute for other institutional processes related to financial interests including disclosures to DHMC for clinical or other duties.

Mandatory COI Education

COI training is mandatory for all researchers receiving PHS funds. Dartmouth offers COI training through the Collaborative Institutional Training Initiative (CITI) Program. The Conflict of Interest Mini-Course and the refresher module are available on the CITI curriculum (CITI course on-line, also see Guide to Completing CITI RCOI training).

Process and Forms for Subcontractors and Consultants

In cases where Dartmouth is the primary awardee receiving PHS funds, the institution must assure COI compliance for all investigators. In most cases, a subcontractor institution will meet the PHS COI requirements.   If this is not the case additional steps are necessary to assure compliance.  Please review the documents below carefully to avoid delays.

Public Access Requests

Reportable financial conflicts of interest must be made available to the public upon request under PHS regulations if the research is PHS funded. Please do not respond directly to such requests from the public for information. Forward requests to the Research Integrity Office or rcoi@dartmouth.edu

Questions & Help

If you have general questions related to Conflict of Interest in Research, please email rcoi@Dartmouth.edu or contact Henrike Frowein at Henrike.Frowein@Dartmouth.edu or 603-646-0239 or Nicole Hall Hewett at nicole.h.hewett@dartmouth.edu or 603-646-0703.

Questionsconcerning logging in or using the Rapport COI system should be directed to rcoi@dartmouth.edu.

For questions concerning COI disclosures in relation to awards or proposals or disclosures required for grant applications please contact your OSP Grants Officer or sponsored.projects@dartmouth.edu or your Department Research Administrator.

 

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