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Conflict of Interest

* Special Note* As of March 15,2020, all PIs and Co-Is must complete a Conflict of Interest in Research Disclosure BEFORE an IRB protocol application can be submitted for review and approval.  To reduce unnecessary COI reporting and comply with institutional and federal reporting requirements, please review the definition of "Investigator" and ensure that personnel designated as a PI or Co-I meet this definition when listed on the Personnel Tab of a research protocol application in WVU+kc.  

Federal regulations require the University to manage any potential conflicts of interest through an appropriate management process which is initiated and generally resolved through disclosure.

An investigator is anyone responsible for the design, conduct, or reporting of research, regardless of their title or role on the project or the receipt of funding (this definition includes adjunct faculty, students, volunteers, subcontractors, consultants, collaborators, research coordinators, research assistants, and other research staff).

For conflict of interest in research disclosure purposes, the PI is responsible for determining who they consider to be an “investigator” using the above definition. Please call our office for further guidance on the matter, but as a general rule, any person listed as a PI or a Co-I on a project or protocol, is considered an "investigator".

* For WVU Policy and Federal Regulations, graduate and undergraduate students are generally not considered Investigators. Postdoctoral scholars and fellows may be considered Investigators if designated as such by the Principal Investigator on a case-by-case basis.  In most instances, students, residents, fellows, and others seeking to fulfill degree, program, or rotation requirements should be designated as "Study Personnel" rather than a Co-I.

Conflict of Interest in Research Disclosure

Membrs of the WVU research community designated "Investigators" are required to file a disclosure at least annually, and on an ongoing basis within 30 days of discovery or acquisition of a new financial interest. Further, Investigators should review and make any necessary revisions to a disclosure:

  1. With each new, continuation, or revised grant or contract application submitted to the Office of Sponsored Programs,
  2. Before submitting each new protocol involving animal or human subjects, and;
  3. When there is a new or previously unrecognized financial interest not previously reported.

Please access the WVU+kc portal to create or update your Conflict of Interest in Research Disclosure.

Institutional Conflict of Interest Disclosure

Earlier this year, the West Virginia University Board of Governors (BOG) adopted BOG Governance Rule 1.4 – Ethics, Conflict of Interest and Outside Consulting, which provides guidance on real and perceived conflicts of interest – both in general and in the context of research activities.

The rule also offers guidance on the solicitation and acceptance of gifts by WVU faculty and staff and defines when it is permissible to enter into consulting arrangements with third parties outside of a faculty or staff member’s employment with the University.

In accordance with the rule, certain University Officials are required to submit annual disclosures wvuresearch.wufoo.com on significant financial interests they or their family members hold. As a reminder, “University Officials” is defined within the rule to mean:

·         University Board Members

·         President

·         Campus Presidents

·         Vice Presidents

·         Vice Provosts

·         Deans

·         Associate and Assistant Vice Presidents and Provosts

·         Assistant and Associate Deans

·         General Counsel

·         Director of Internal Audit

·         All employees within the Office of Technology Transfer

 If you haven’t already, be sure to submit your annual disclosure form wvuresearch.wufoo.com before the July 31 deadline.

Conflict of Interest in Research Training

Those named as a WVU Investigator are required to complete Conflict of Interest in Research Training every 4 years. We will no longer be utilizing the CITI Conflict of Interest course to facilitate the training requirement. The training requirement has been built in to the disclosure process and can be completed by simply following the instructions found on the first page of the disclosure.

If you have questions, concerns, or would like to submit a form, please contact:

Joy Edwards, COIR Director
joy.edwards@mail.wvu.edu
(304) 293-5475